Privacy Policy

1. Introduction
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Welcome to In2America (“we, “our” or “us”). We are committed toprotecting and respecting your privacy. Any mention of “Our Group” means our subsidiaries, our ultimate holding company and its subsidiaries, and our associated companies. 

This notice sets out the basis on which any Personal Informationwe collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it. 

This Privacy Policy applies globally, but we have included additional information for residents of the European Economic Area, the United Kingdom and California.

This Privacy Policy does not apply to pseudonymised, anonymous, or business contact information.

2. Who are In2America?

‍We are an employment services provider, encompassing professional employer organisation (PEO), employer of record (EOR) and agent of record (AOR) solutions (our “Service”).

3. What information do we collect?

‍We collect information about you to carry out our core business and ancillary activities.  This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our site, enter our database, purchase our Services, attend our events and when you report a problem with our site.

‍Information you give to us, or we collect about you, may include your name, address, private and corporate e-mailaddress and phone number, employment information, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

‍Information collected automatically. Regarding each of your visits to our site wewill automatically collect the following information. Technical information, including the Internet protocol (IP) address used to connect yourcomputer to the Internet, browser type and version, information about yourvisit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction, and any phone number used to call us. 

Cookies. Our website uses cookies todistinguish you from other users of our website. This helps us to provide youwith a good experience when you browse our website and also allows us to improve our site.

We will also process Personal Information about our suppliers, employees, independent contractors, advisors, partners and professional experts. 

4. How is my information used?

We use information held about you in the following ways:

Providing you with our Service. To get in touch with you when necessary to provide you with our Service. For example, emails may be sent to you throughout the implementation process to inform you of the status of your onboarding and to seek additional information that is requested as part of that process. We may notify you of changes to our Service, contact you regarding satisfaction with our Service or make suggestions and recommendations to you about Services that may interest you. 

Please note that the provision of certain Personal Information ismandatory to comply with client due diligence requirements and consequently to provide the Services. If you are unable to provide the relevant Personal Information required to comply with our legal obligations and/or our terms of business, we may not be able to provide the Services to you. 

‍Operating our business. T operate our business, which includes, without limitation, using your information to process payroll and payroll/tax payment transactions; to comply with applicable legal and regulatory requirements, industry standards or guidelines, and our internal policies and procedures; to monitor and enforce compliance with applicable contractual obligations; to detect and prevent fraud or detect criminal activity, unauthorized claims, or other liabilities; to operate, evaluate and improve our business and the Service we offer, including developing new Services, managing our communications, and for auditing purposes. 

‍Administering our site. Resolve complaints, troubleshoot our website, analyze data, test new features, or for research, statistical andsurvey purposes. You may opt out of receiving these additional communications from us by following the opt-out procedures described in this policy. 

For any other purpose for which you expressly authorize us to useyour information. 

5. What is our legal basis for processing?

Our legal basis for the processing of Personal Information is our legitimate interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data. 

We will rely on contractual obligations if we are negotiating or have entered into an agreement with you or your organisation or any other contract to provide Services to you or receive Services from you or your organisation. 

We will rely on legal obligation in some cases, where we are required by law or regulation to process your data. 

We will in some circumstances rely on consent for particular uses of your data, for example for marketing purposes. Where we rely on consent, you will be asked for your express consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. 

‍Our Legitimate Interests

We process Personal Information where necessary to pursue our legitimate interests as an employment services provider. This includes administering employment relationships, such as onboarding, payroll, benefits and leave management. We also process data to comply with employment, tax, and social security obligations, maintain accurate records, and ensure operational continuity. 

Additionally, we use Personal Information to safeguard our systems, prevent fraud, and manage legal risk, including retaining information to establish, exercise, or defend potential legal claims. As part of our business operations, we may process data to conduct audits, improve our services, and communicate effectively with employees and client representatives. We have carefully assessed these activities to ensure they are necessary and proportionate, and we strive to respect your rights and maintain transparency in this policy in how we handle your information. 

6. How is my information shared?

We will only ever share your Personal Information when there is a legitimate need to do so. 

‍Providing you with our Service. We may share your Personal Information and other information to any member of our group, including staff operating within our group, which is in the UK, the EEA and outside of the EEA. By submitting your Personal Information, you agree to this processing. We may disclose your Personal Information and other information to third parties such as insurance companies, brokers, banking and financial institutions, licensed agents, federal, state and local tax agencies, administrators, auditors, legal and financial advisors. We may disclose your information in other instances in order to provide you the Services that you have requested.

‍To Vendors, Service Providers, and Affiliates. We may disclose your Personal Information and other information to other companies that help us process or Service your applications, correspond with you, operate our business, or help us with the uses of your Personal Information and other information that are explained in this Privacy Policy. These companies may or may not be affiliated with us. When we use third-party business associates to help us operate our business, we have contracts with them that require them tokeep your Personal Information confidential. 

‍For Payment Processing. For example, we may use the analytics Services of Microsoft or Google, and the payment processing Services of NatPay. Google's analytics Services would allow us to learn how you use our site by giving us the ability to collect information based on your interaction with the site. 

‍Legal Obligations. We may disclose or report your Personal Information and other information as required or permitted under law. For example, we may disclose your Personal Information to cooperate with regulators or law enforcement authorities, to comply with subpoenas and court orders, to prevent harm to persons or property, or to resolve consumer disputes. 

‍Acquisition, Sale, or Reorganization. We may also use and disclose Personal Information and other information in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with atransaction. If the sale occurs, the purchaser will be entitled to use and disclose the Personal Information and other information collected by us, and the purchaser will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. 

‍Aggregate Information. We may collect statistical information about registered users that use our Services on the site ("Aggregate Information"). This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser. We may share Aggregate Information with prospective clients, partners, Service providers and other persons with whom we conduct business. 

7. What are my rights?

‍Marketing. You have the right to ask us not to process your Personal Information for marketing purposes. We will usually inform you if we intend touse your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your Personal Information for marketing purposes. You can exercise the right to not have your data used for marketing purposes at any time by contacting us contact@in2america.com. 

‍California Privacy Rights. If you are aCalifornia resident, you can make certain requests regarding your Personal Information by contacting us at contact@in2america.com. We will fulfill each of these requests to the extent required by law. 

·        You can ask us what Personal Information we have about you, including a list of categories of your Personal Information that we have sold and a list of categories of your Personal Information that we have shared with another company for a business purpose.
·        You can ask us to delete your Personal Information.
·        You can ask that we stop selling your Personal Information (although we do not sell Personal Information to third parties.)


‍Additional Information for European Residents. The UK General Data Protection Regulation (UK GDPR) (Regulation (EU)2016/679) is a regulation which replaces the Data Protection Regulation(Directive 95/46/EC). The Regulation aims to harmonise data protectionlegislation across EU member states, enhancing privacy rights for individualsand providing a strict framework within which commercial organisations canlegally operate. 

If you are a UK or European Economic Area resident, GDPR provides you with the right to:
·        Request correction of the Personal Information that we hold about you.This enables you to have any incomplete or inaccurate information we hold about you corrected.
·        Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason forus continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below).
·        Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
·        Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.
·        Request access to your information held about you. We encourage you to contact us to ensure your data is accurate and complete. A subject access request should be submitted to contact@in2america.com. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request.
·        Request the transfer of your Personal Information to another party in certain formats, if practicable.
·        Make a complaint to a supervisory body which in the United Kingdom isthe Information Commissioner’s Office. The ICO can be contacted through this link:  https://ico.org.uk/concerns/.
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‍Privacy of Minors. We do not knowingly collect any PersonalInformation from persons under the age of 18. If you are under the age of 18,please do not submit any Personal Information through our site. If you havereasons to believe that an individual under the age of 18 has provided PersonalInformation to us through our site, please contact us via contact@in2america.com. 

8. How do you protect my information?

‍Administrative, physical, and technical safeguards. We take reasonable technical and organizational precautions to prevent the loss, misuse, or alternation of your Personal Information. All electronic transactions you make to or receive from us containing sensitive information are encrypted using SSL technology. We take privacy and security very seriously, but it is impossible for us or others to guarantee the safety and security of information under all circumstances. We also depend on you to protect your information. If you become aware of any incident of security or privacy, or if you receive/share any information in error please notify us immediately. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. 

‍Training. Allour employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying apotential data breach. All employees who use our computer systems are trained to protect individuals’ private data, to ensure data security, and to understand the consequences of any potential lapses and breaches of thepolicies and procedures. 

‍Links to Other Websites. Our website may contain links that allow you to visit other websites. We have no control over those websites, and this policy does not apply to them. We encourage you to read the privacy policies of these linked websites to learn about their information privacy practices. 

‍International Data Transfers. We operate at a multi-national level and therefore Personal Information may need to be transferred to countries outside of where it was originally collected. When we transfer Personal Information outside the EEA or UK, we will ensure that this transfer complies with GDPR, UK GDPR and applicable laws.

9. How long do you retain my information?

We retain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected. We may retain your Personal Information for longer if necessary and relevant to our legitimate interests, in accordance with applicable legal obligations. This may include retention necessary to meet any regulatory or reporting requirement s as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings. 

We will appropriately and securely dispose of your Personal Information when it is no longer required. Where there is no retention period stated in law, to determine the appropriate retention period we consider factors such as the purposes for which we process your Personal Information, including any legal, regulatory, payroll, accounting and reporting obligations, the amount and nature of data and its sensitivity, potential risk of harm from unauthorised use or access and the purpose for which we handle it. 

10. How can I opt out of receiving communications?

If you want to opt out of any email communications or marketing, you may contact us at contact@in2america.com. Please note that if you use our Service you will still receive communicationsfrom us regarding payroll, benefits, or insurance applications, even if you opt out. 

11. Will this policy change?

We may update this policy from time to time. We will provide notice of changes in our information privacy practices by posting revised versions on the website. Any changes we make to this policy will apply to the Personal Information we already hold about you, as well as any additional information we may collect. By your continued visits to the site, you agree to the Privacy Policy as updated. 

12. What if I have questions?

We are available to answer any questions you may have about our Privacy Policy or our information privacy practices. You may contact us at contact@in2america.com. For the purposes of GDPR the data controller is twentyAI Ltd of Copthall House, 14-18 Copthall Avenue, London, EC2R 7DJ.