Welcome to Inuka’s Privacy Policy!

Your privacy is important.

  1. PARTIES
    1. This Privacy Policy describes how INUKA, (“INUKA”, “we”, or “us”) collects, uses, stores, shares and protects your information in connection with services offered by INUKA as a data controller and/or processor including, but not limited to, services provided at or using the domain INUKA.io (the “Site”); tools or applications including, but not limited to, mobile and other software applications related to the Site (the “Applications”); and images, text, playlists, metadata, and other material available through the Service (the “Content”) (collectively, the “Service”).
    2. This Privacy Policy applies when you (“you”, “User” or “Respondent”) access, visit or use any portion of the Service. For the purposes of this Privacy Policy, a “User” is a person who is a Guide or a Client.
    3. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in the INUKA Terms of Use.
  2. AGREEMENT TO TERMS OF PRIVACY POLICY
    1. Before you engage in any part of the Service INUKA provides and before any personal information is gathered, you will always be asked for your explicit and informed consent.
    2. Any Service provided by INUKA is purely voluntary. You are not required to provide any personal information to us unless you choose to access features of the Service that require such information. If you do not agree with the terms of this policy or INUKA’s Terms of Use related to the Service, then please do not provide us with personal information, exit the Applications immediately, and refrain from using the Service.
    3. Accordingly, by creating an INUKA Account (as defined in the Terms of Use), or by otherwise accessing, visiting or using the Service, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy and in the INUKA Terms of Use.
  3. CHANGES TO THE PRIVACY POLICY
    1. We may amend this Privacy Policy from time to time. You may be required to accept the amended Privacy Policy upon logging in to your INUKA Account in order to keep using the Service. Alternatively, we may post any material changes to this Privacy Policy on the Site with a notice advising of the changes in advance of the effective date of the changes. We may also notify you of material changes to this Privacy Policy, before the effective date of the changes, by sending an email or in another conspicuous manner reasonably designed to notify you. If you do not agree to the new Privacy Policy, you may terminate using the Service within the applicable thirty (30) day period and you will not be bound by the new terms. Otherwise, the new terms will take effect after thirty (30) days.
  4. RIGHTS TO ACCESS, RECTIFICATION OR ERASURE, RESTRICTION AND OBJECTION, OF PROCESSING
    1. You have the right to access, rectification, opposition, erasure (“right to be forgotten”), and right to restriction of processing of your personal data by directing any such requests to INUKA, through privacy@inuka.io. In order to make things easier for you, and without prejudice to the legal requirements INUKA must comply with under the laws, INUKA allows you to exercise the above-mentioned rights by sending a request per e-mail to the aforementioned e-mail address.
  5. PERSONAL INFORMATION ABOUT USERS AND RESPONDENTS
    • INUKA is used by INUKA “Guides” and by INUKA “Clients”. The information we receive from Guides and Clients and how we handle it differs, as set out below.
      1. INUKA Guides: As a Guide, we collect information relating to you and your use of our Services from a variety of sources:
        1. Information we collect directly from the Guide
        2. Registration information: information you provide to us when you register for an account.
        3. “My Account” settings: you can view and edit various preferences and personal details on “My Account” settings. For example, your default language, registered email, non-transactional communication preferences, username and avatar.
        4. INUKA data we store for you:
          • Data used when interviewing for the job: Full name
          • Phone number
          • E-mail address
          • Date of birth
          • Physical address
          • Country
          • CV
          • Motivation letter
          • Empathy test results
          • AMREF Health Africa training results
          •  Education level
          • Gender
          • SRQ results
        5. Data for personal contact details (employee information):
          • Full name
          • E-mail address
          • Phone number
          • Birth date
          • Gender
          • Education level
          • Physical address
          • Country
          • Bank account number
          • Payment details
        6. Data for personal contact details (employee information):
          • Full name
          • E-mail address
          • Phone number
          • Birth date
          • Gender
          • Education level
          • Physical address
          • Country
          • Bank account number
          • Payment details
        7. Data stored related to coaching & supervision:
          • Display name
          • Avatar picture
          • Session planning schedule
          • Chat transcripts
          • Action Cards
          • Offline message transcript
          • Ratings & average rating
          • Red flags
          • Sessions date and start & end times
          • No-shows
          • E-mail address
          • Gender
          • Aggregated anonymous meta-data on usage & in-app analytics
        8. Other data you want to share: We may collect your personal information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial, this data will be collected by us.
        9. Information we collect about the Guide indirectly or passively when interacting with us
          • Usage data: INUKA collects usage data about Guides whenever they interact with our services, including information they have elected to make publicly available.
          • Device and application data: INUKA collects data from the device and application the Guide uses to access our services, such as the IP address and browser type. We may also infer the geographic location based on the User IP address.
          • Referral data: if the Guide arrives at an INUKA website from an external source (such as a link on another website or in an email), we record information about the source that referred the Guide to us.
          • Information from third parties: INUKA may collect Guide personal information or data from third parties if the Guide gives permission to those third parties to share such information with others or the data is extracted from publicly accessible sources. For example, INUKA may share minimal service data with a select third-party for data enrichment purposes, provided that Guide has given prior permission to those third parties to share such information with other parties (i.e. INUKA may share Users’ email addresses with a third party to obtain some information like company name etc) or it comes from publicly accessible sources like social media profiles. Enriching data allows us to analyse a deeper subset of data from which we may present personalized content. Prior to sharing data with any data enrichment vendor, INUKA signs the corresponding Data Protection Agreement with the vendor to ensure that the data is adequately protected, that it has been lawfully obtained by vendors enabling INUKA to use such data in connection with the Services, and to ensure vendors adopt adequate security controls.
          • Information from cookies and page tags: INUKA uses third party tracking services that employ cookies and page tags (also known as web beacons or web bugs) to collect aggregated and anonymous data about visitors to our websites. This data may include usage and User You can obtain full information about our cookie policy here.
      2. INUKA CLIENTS
        As a Client, when you use the service provided by INUKA, we collect information relating to you and your use of our services from a variety of sources:

        1. Information we collect directly from the Client: We collect and store the INUKA chat transcripts and offline transcripts from Clients. The INUKA Data Privacy Officer is responsible for that data and manages it. Transcripts are anonymously recorded and saved for 12 months after you deleted the INUKA app, in order to be able to provide the Guide that took part in the chat with feedback on his or her performance.
        2. When engaging in an INUKA chat with a guide you should provide as little personal information or data as possible. INUKA offers anonymous chat service through pseudonyms and separation of data streams, which is only possible is you don’t share data that could link you to your screen name pseudonym.
        3. Information we collect about the Client from other sources:
          • Usage data: on behalf of INUKA, INUKA collects usage data about Clients whenever they interact with our services.
          • Device and application data: on behalf of INUKA, INUKA collects data from the device and application the Client uses to access our services, such as, among other, the IP address, browser type and operating system. We may also infer the geographic location based on the Respondent IP address.
          • Referral data: on behalf of INUKA, INUKA records information about the source that referred the Client to INUKA (i.e. a link on a website or in an email).
          • Information from cookies and page tags: INUKA uses third party tracking services that employ cookies and page tags (also known as web beacons or web bugs) to collect aggregated and anonymous data about visitors to our websites. This data may include usage and Client statistics. You can obtain full information about our cookie policy as described in Section 7 below
          • Banking information: Client banking details are needed to accept Client payments to use the Service provided by INUKA.
          • E-mail address: INUKA records the e-mail address in order to contact the Client if needed.
        4. INUKA’S obligations as data processor when processing Users’ data: When INUKA is processing Users’ data, INUKA is the Data Controller in relation with the data of clients using the INUKA services, and INUKA is also the Data Processor of such data (hereinafter, User shall be referred to as the “Data Controller” and INUKA as the “Data Processor”). For the processing of Clients’ data on behalf of INUKA, INUKA undertakes to fulfil the following obligations:
          1. To treat the personal data only to carry out the provision of the contracted Services, in accordance with the terms and conditions of INUKA.
          2. To maintain the duty of secrecy with respect to the personal data to which the INUKA has access, even after the termination of the contractual relationship, and to ensure that their employees have committed in writing to maintain the confidentiality of the personal data processed.
          3. To ensure, taking into account the available technology, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the risks of varying probability and severity for the rights and freedoms of natural persons, that they will apply adequate technical and organizational measures to ensure a level of security appropriate to the risk, including, where appropriate, among other things:
            • The pseudonymisation and encryption of personal data;
            • The ability of ensuring the continued confidentiality, integrity, availability and resilience of the systems and services;
            • The ability of restoring the availability and access to personal data quickly in the event of a physical or technical incident;
            • A process of regular verification, evaluation and assessment of the effectiveness of the technical and organizational measures in order to ensure the safety of the processing.
            • The management and training of all INUKA personnel handling personal and sensitive data, including instalment of work flow protocols to ensure uniform performance and consistency.
        5. When evaluating the adequacy of the security level, special account shall be taken of the risks presented by the data processing, in particular as a consequence of the destruction, loss or accidental or unlawful alteration of the personal data transmitted, stored or otherwise processed, or the communication or unauthorized access to such data. In the event that the implementation of specific and concrete security measures is needed, those measures will be added to this Agreement by means of an Annex.
          1. To keep under their control and custody the personal data to which they have access in relation with the provision of the Service, and to not disclose them, neither transfer nor otherwise communicate them, not even for their preservation, to persons unrelated with the provision of the Service covered by this Agreement.
          2. However, the Data Controller may authorize, expressly and in writing, the Data Processor to use another data processor (hereinafter, the “Subcontractor”), whose identification data (full company name and fiscal identification number) and subcontracted services must be communicated to the Data Controller, prior to the provision of the service, at least with one (1) month in advance. The Data Processor will also inform the Data Controller of any change envisaged in the incorporation or substitution of the Subcontractors, giving thus to the Data Controller the opportunity to object such changes.
          3. In case of making use of the power recognized in the previous paragraph, the Data Processor is obliged to transfer and communicate to the Subcontractor the whole obligations that for the Data Processor derive from this Agreement and, in particular, the provision of enough guarantees that he will apply appropriate technical and organizational measures, so that the processing complies with the applicable regulations.
          4. In any case, access to the data made by natural persons who render their services to INUKA, acting within the organizational framework of the latter by virtue of a commercial and non-labour relationship, is authorized. In addition, access to the data is granted to companies and professionals that the Data Processor has hired in their internal organizational framework in order to provide general or maintenance services (computer services, consulting, audits, etc.), as long as such tasks have not been arranged by the Data Processor with the purpose of subcontracting with a third party all or part of the Services provided to the Data Controller.
          5. To delete or return to Clients or Guides, at their choice, all personal data to which they have had access in order to provide the Service. Likewise, INUKA undertakes to delete the existing copies, unless there is a legal rule that requires the preservation of the personal data. However, employees and other personnel working for INUKA are entitled to access Clients and Guides data as required to carry out their obligations under the terms of their contract.
          6. To notify the Users, without undue delay, of any personal data security breaches of which we are aware, giving support to the User in the notification to the Dutch Data Protection Agency or other competent Control Authority and, if applicable, to the interested parties of the security breaches that occur, as well as to provide support, when necessary, in the carrying-out of privacy impact assessments and in the prior consultation to the Dutch Data Protection Agency, where appropriate, as well as to assist the Data Controller so they can fulfil the obligation of responding the requests to exercise certain rights.
          7. To bring, in writing, a record of all categories of processing activities performed on behalf of the User.
          8. To cooperate with the Dutch Data Protection Agency or with other Control Authority, at its request, in the fulfilment of its power.
          9. To make available to the User the whole information necessary to demonstrate the fulfilment of the obligations established under this Agreement, as well as to allow and contribute to the performance of audits, including inspections, by the User or by a third party authorized by them.
      3. If INUKA or any of our Subcontractors violates this Agreement or any regulation when determining the purposes and means of the processing, they shall be held responsible for such processing. Furthermore, if such Subcontractors are based in countries which do not have a legislation on data protection which is equivalent to the EU legislation (“Third Countries”), INUKA shall establish all safeguards required by the EU legislation in order to comply with all obligations arising from transfers of data to Third Countries, and shall promptly inform the User about such safeguards if so requested.
  6. PURPOSES AND LEGITIMATE BASIS OF THE USE AND SHARING INFORMATION
    • PURPOSES OF PROCESSING
      1. We use the information we collect from you to perform the services requested in connection with the “INUKA Account” selected for the purposes described in the Terms of Use.
      2. We also use your information to review, investigate and analyse how to improve the services provided. We may also collect and analyse your anonymous data to monitor, maintain and improve our services and features.
      3. We may share anonymous user data with third parties such as university and other research institutes to perform analyses on the dataset in order to expand the public knowledge on the effectiveness of our services. Any third party analysis of INUKA data purely serves the purpose of improving public health, in accordance with GDPR Article 23(1)e. INUKA nor the third party university or research institute will profit financially from abovementioned research, or its publication. Any user data in such publications is completely anonymous and untraceable. Any third party university research institute is bound by the same level data privacy protection as INUKA, which we will actively validate.
      4. We may internally perform statistical and other analyses on information we collect (technical and meta data) to analyse and measure user behaviour and trends, to understand how people use our services, in order to improve and optimise our performance of such Services, and to monitor, troubleshoot and improve our Services, including to help us evaluate or devise new features.
      5. We may use your information for internal purposes designed to keep our Services secure and operational, such as testing purposes, troubleshooting, to prevent abusive activity (i.e. fraud, spam, phishing activities), and for Service improvement, research and development purposes.
      6. We do not sell your INUKA data to third parties without your permission. We share your information with our service providers who help us to provide our services to you and with third party researchers that focus on public health, in which case those third parties are required to comply with our privacy policy and any other adequate technical and organisational measures, and the shared information is kept to a minimum so that your privacy is safeguarded. We contractually bind these service providers and researchers by the corresponding Data Processing Agreements to keep your information confidential and to use it only for the purpose of providing their services or research and pursuant to the applicable privacy legislation in the EU. Your name and your data will never be linked.
      7. INUKA is based in the EU and complies with the GDPR framework as set forth by the EU regarding the collection, use, and retention of personal data from EU member countries. If you are located outside the EU and choose to use the Service or provide your information to us, please note that your information may be transferred, processed and stored by our service providers in other non-EU countries. Privacy laws of the European Union and third countries may not be as protective as those in your jurisdiction. Your agreement to the terms of this Privacy Policy followed by your submission of information in connection with the Service represents your agreement to this practice. If you do not want your information transferred to or processed or stored in the EU or in the United States, you should not use the Service. If you are located in the EU, we guarantee that we will only transfer your data to companies that have signed our Data Privacy Agreement or that are registered with the Privacy Shield, to ensure a level of data protection compliant with the GDPR.
      8. Your data is not disclosed to any third party except (i) for providing the services you requested and for which INUKA collaborates with third parties, (ii) when we have your permission, (iii) when it is required by a competent authority in the exercise of its duties (for example in order to investigate, prevent or take action regarding illegal activities), (iv) for scientific research regarding public health, or (v) as otherwise required by law.
      9. We do not use your INUKA data other than as described in this Privacy Policy and the Terms of Use.
  7. LEGITIMATE BASIS OF PROCESSING
    • INUKA use of your data for the purposes described above is based on the following legitimate basis:
      1. Users’ Data. If you are a User, we are entitled to use your data in order to fulfil our contractual obligations with you. In addition, we will never use any of your data for direct marketing purposes, in order to send you commercial communications related with INUKA products or services that are similar to the service provided by INUKA.
  8. COOKIES
    1. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity throughout the INUKA website and that information helps us to understand your preferences and improve your experience.
    2. For a detailed description of the types of cookies we use and on how you can control the use of cookies, please see our Cookie Policy.
  9. CANCELING YOUR ACCOUNT, OPTING OUT OF EMAIL, AND MODIFYING PERSONAL INFORMATION
    1. You may cancel your account and you may opt out of receiving any emails from INUKA at any time by changing the settings in your account settings page. Deleting your account will cause all the INUKA data in the account to be permanently deleted from our systems within a maximum of 15 working days, as permitted by law and will disable your access to any other services that require an INUKA account. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfil requests to delete personal data unless the request is not technically feasible, or such data is required to be retained by law (in which case we will block access to such data, if required by law).
    2. You may modify your personal information by logging in and visiting your settings through the INUKA platform, where you can access your personal information.
    3. We encourage you promptly to update your personal information when it changes. Information concerning your past behaviour with the Service may be retained by INUKA as long as necessary for the purposes set out below.
  10. RETENTION OF YOUR INFORMATION
    1. We retain information for active INUKA Accounts as long as it is necessary and relevant for our operations. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce the INUKA Terms of Service and take other actions permitted by law.
    2. The information we retain about you will be handled in accordance with this Privacy Policy during the maximum terms permitted by law and will exclusively be used for the purposes described in section 9.1 above. After those terms, your information will be fully deleted or, alternatively, will be anonymised.
  11. HOW TO CONTACT US
    • Send a request to privacy@inuka.io. Also, you can send us a letter by using the following address:
      • Inuka B.V.
      • Rapsodieplantsoen 11,
      • 1312EJ Almere,
      • The Netherlands.
  12. COMPLAINTS
  13. If you consider that any use of your data might breach any of your rights, you can lodge a complaint at any time by sending us an e-mail or letter, or, alternatively, by filing a complaint before the Dutch Privacy Authority (see: https://autoriteitpersoonsgegevens.nl/)