Privacy Policy

1. Who We Are

Innovo Markets Inc. ("Innovo," "we," "our," or "us") is a Delaware corporation headquartered at 330 North Wabash Avenue, Chicago, IL 60611. We operate the website at www.innovomarkets.com (the "Site"). For questions about this Privacy Policy, you may contact us at legal@innovomarkets.com.

2. Scope of This Policy

This Privacy Policy applies to personal information we collect through the Site, including when you:

• Browse or view pages on the Site.
• Submit a contact, inquiry, or demo-request form.
• Subscribe to email communications or newsletters.
• Correspond with us by email or other means originating from the Site.
• Interact with any cookies or tracking technologies deployed on the Site.

This Policy does not apply to information collected through Innovo's platform, application, or services, which are governed by separate agreements entered into with registered users.

3. Information We Collect

3.1 Information You Provide Directly

We collect information you voluntarily provide when you interact with the Site, including:

• Contact and inquiry information: your name, email address, phone number, company name, job title, and the content of any message you send us through a contact or demo-request form.
• Subscription information: your email address when you sign up to receive communications from us.
• Correspondence: any information you include in emails or other messages you send to us.

3.2 Information We Collect Automatically

When you visit the Site, we and our service providers may automatically collect certain information about your device and browsing activity, including:

• Log data: IP address, browser type and version, operating system, referring URLs, pages viewed, date and time of your visit, and time spent on pages.
• Device information: device type, unique device identifiers, and hardware model.
• Usage data: clickstream data, links clicked, and search terms entered on the Site.
• Location data: general geographic location inferred from your IP address (city or country level only; we do not collect precise geolocation).

3.3 Cookies and Similar Tracking Technologies

We use cookies, web beacons, pixel tags, and similar technologies to operate and improve the Site, remember your preferences, and understand how visitors use the Site. Cookies are small data files placed on your device. We use the following types:

• Strictly necessary cookies: required for the Site to function and cannot be switched off.
• Analytics cookies: help us understand visitor behavior in aggregate, such as which pages are most visited.
• Functionality cookies: remember choices you make (such as language or region) to improve your experience.
• Marketing/targeting cookies: may be used to deliver content relevant to your interests. We will obtain your consent before placing non-essential cookies where required by law.

You may control cookies through your browser settings or by using the cookie preference tool on our Site (where provided). Note that disabling certain cookies may affect Site functionality. For more information about cookies and how to manage them, visit www.allaboutcookies.org.

3.4 Information from Third Parties

We may receive information about you from third-party sources, such as analytics providers, advertising partners, or publicly available sources, and may combine this with information we collect directly. We handle all such information in accordance with this Policy.

4. How We Use Your Information

The table below summarizes how we use the information we collect, and the reason or legal basis for each use.

We do not use personal information for automated decision-making that produces legal or similarly significant effects without human review.

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

5.1 Service Providers

We engage third-party companies and individuals to perform services on our behalf, such as website hosting, analytics, email delivery, and customer relationship management. These service providers access your information only as needed to perform their services and are contractually obligated to protect it and use it only for the purposes for which we disclose it to them.

5.2 Legal Obligations and Protection of Rights

We may disclose your information if we believe in good faith that such disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or governmental request (including subpoenas, court orders, and regulatory inquiries).
• Enforce our Terms of Use or other agreements.
• Protect the rights, property, or safety of Innovo, our users, or the public.
• Detect, prevent, or address fraud, security, or technical issues.

5.3 Business Transfers

If Innovo is involved in a merger, acquisition, asset sale, financing, or similar transaction, your information may be transferred as part of that transaction. We will notify you via the Site or email of any change in ownership or use of your personal information, and of any choices you may have.

5.4 With Your Consent

We may share your information with third parties for purposes not described in this Policy when we have your consent to do so.

5.5 Aggregated or De-Identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, or other business purposes.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting obligations, resolve disputes, and enforce our agreements. The specific retention period depends on the type of information and the purpose for which it was collected:

• Inquiry and contact form data: retained for up to three (3) years from the date of your last interaction with us, or longer if required by law or needed to manage an ongoing business relationship.
• Email subscription data: retained until you unsubscribe or request deletion, plus a reasonable period thereafter for suppression purposes.
• Log and analytics data: typically retained for up to twenty-four (24) months in identifiable form, after which it may be aggregated or deleted.
• Legal hold data: retained for the duration of any applicable legal obligation, investigation, or dispute.

When personal information is no longer needed, we delete or de-identify it in accordance with our data retention practices.

7. Security

We implement reasonable and appropriate technical and organizational measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (TLS/HTTPS), access controls, and regular security reviews.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at legal@innovomarkets.com.

8. Your Rights and Choices

8.1 All Users

Regardless of your location, you have the following choices:

• Email communications: you may opt out of marketing emails at any time by clicking the "unsubscribe" link in any email or by contacting us at legal@innovomarkets.com. You may still receive transactional or relationship emails even after opting out of marketing.
• Cookies: you may manage your cookie preferences through your browser settings or our cookie preference tool (where available). See Section 3.3 for more detail.
• Do Not Track: some browsers transmit "Do Not Track" signals. Because there is no uniform standard for these signals, we do not currently respond to them, but we will continue to monitor developments in this area.

8.2 California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may provide you with additional rights regarding your personal information, including:

• The right to know what personal information we collect, use, disclose, and sell.
• The right to delete personal information we have collected, subject to certain exceptions.
• The right to correct inaccurate personal information.
• The right to opt out of the sale or sharing of personal information. We do not sell or share personal information as those terms are defined under the CCPA/CPRA.
• The right to limit the use and disclosure of sensitive personal information.
• The right to non-discrimination for exercising your rights.

To exercise your California privacy rights, please submit a request to legal@innovomarkets.com with the subject line "California Privacy Request." We will verify your identity before processing your request and respond within the timeframe required by applicable law. You may also designate an authorized agent to make a request on your behalf.

8.3 Virginia, Colorado, Connecticut, and Other U.S. State Residents

Residents of certain U.S. states may have rights under their state's privacy laws, such as the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), or the Connecticut Data Privacy Act (CTDPA), including the right to access, correct, delete, and obtain a copy of their personal information, and the right to opt out of certain processing. To submit a request, contact us at legal@innovomarkets.com. We will respond in accordance with applicable state law.

8.4 EEA, UK, and Swiss Residents

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you may have rights under the General Data Protection Regulation (GDPR) or equivalent local law, including the right to access, rectify, erase, restrict, or object to processing of your personal information, and the right to data portability. To exercise these rights, contact us at legal@innovomarkets.com. You also have the right to lodge a complaint with your local supervisory authority.

Our legal basis for processing your personal information in these jurisdictions is: (a) your consent, where we have obtained it; (b) performance of a contract or pre-contractual steps at your request; (c) our legitimate interests (provided those interests are not overridden by your rights); or (d) compliance with a legal obligation.

9. Third-Party Websites and Services

The Site may contain links to third-party websites, plug-ins, and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

10. Children's Privacy

The Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have inadvertently collected personal information from a child under 13, we will promptly delete that information. If you believe we may have information about a child under 13, please contact us at legal@innovomarkets.com.

11. International Data Transfers

Innovo is based in the United States. If you access the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using the Site, you acknowledge and consent to the transfer of your information to the United States. Where required by applicable law, we implement appropriate safeguards for international data transfers, such as standard contractual clauses.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Last Updated" date at the top of this Policy and post the revised Policy on the Site. If we make material changes, we will provide more prominent notice (such as a banner on the Site or an email notification). We encourage you to review this Policy periodically. Your continued use of the Site after any changes take effect constitutes your acceptance of the revised Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Innovo Markets Inc.

Attn: Legal / Privacy

330 North Wabash Avenue

Chicago, IL 60611

Email: legal@innovomarkets.com

Website: www.innovomarkets.com