Privacy policy
Last updated: Feb 11,
2025
Welcome to Incarno.ai operated by Grid Dynamics Holdings, Inc.
(“
Grid Dynamics”,
we,” “
our,” and/or “
us”), which
is committed to protecting the privacy of individuals who visit
and use the website located at
incarno.ai or
services that link to this privacy policy (collectively, our
“
Services)". This
privacy policy (the “
Privacy Policy”) explains how we collect, use, and share personal information
from users of our Services (“
Users”) or their devices. If you are located in the European
Economic Area (“
EEA”) or
the United Kingdom (“
UK”), “personal information” means any information relating to an
identified or identifiable individual. By using or accessing our
Services, you agree to the collection, use, disclosure, and
procedures this Privacy Policy describes. Beyond the Privacy
Policy, your use of our Services is also subject to our
Terms of Use.
Information We Collect
We collect a variety of personal information from or about you
or your devices from various sources, as described below.
If you do not provide your personal information when requested,
you may not be able to use our Services if that information is
necessary to provide our Services, or if we are legally required
to collect it.
A. Information You Provide to Us
Registration Information.If you sign up for one of our talks, meetups, competitions,
hackathons, workshops, or other events, including our events
hosted on third-party sites, we will receive your first and last
name, email address, the contents of a message or attachments
that you may send to us, and other information you choose to
provide.
Communications. If you
contact us directly, we may receive additional personal
information about you. For example, when you contact us through
our website, we may receive your first and last name, email
address, phone number, the contents of a message or attachments
that you may send to us, and other information you choose to
provide. When we send you emails, we may track whether you open
them to learn how to deliver a better customer experience and
improve our Services.
B. Information We Collect When You Use Our Services
Device Information.We
receive information about the device and software you use to
access our Services, including internet protocol (“IP”) address,
web browser type, operating system version, internet traffic
data, service usage data, and unique device identifiers.
Usage Information. To
help us understand how you use our Services and to help us
improve them, when you use our Services, we automatically
receive information about your interactions with our Services,
like log files, performance logs, diagnostic reports, the pages
or other content you view, the searches you conduct, pages you
request, the websites you visited before using our Services, and
the dates, times, and durations of your visits.
Location Information.
When you use our Services, we infer the general physical
location of your device and the geographic regions our Users
come from. For example, your IP address may indicate your
general geographic region.
Information from Cookies and Similar Technologies.
We and our third-party partners may collect personal information
using Cookies. Cookies are small files of letters and numbers
that we store on your browser or the hard drive of your
computer. They contain information that is transferred to your
computer’s hard drive. We use cookies, beacons, invisible tags,
and similar technologies (collectively “Cookies”) to collect
information about your browsing activities and to distinguish
you from other Users of our Services. This aids your experience
when you use our Services and also allows us to improve the
functionality of our Services. Cookies can be used for
performance management, collecting information on how our
Services are being used for analytics purposes. They can also be
used for functionality management, enabling us to make the
User’s visit more efficient by, for example, remembering
language preferences, passwords and log-in details. We may also
use pixel tags and web beacons on our Services. These are tiny
graphic images placed on web pages or in our emails that allow
us to determine whether you have performed a specific action.
Below is an overview of the types of Cookies we and third
parties may use to collect personal information. For a detailed
list of the Cookies that we use, along with their purpose and
retention period.
-
Strictly Necessary Cookies.
Some Cookies are strictly necessary to make our Services
available to you. We cannot provide you with our Services
without this type of Cookies.
-
Functional Cookies.
Functional Cookies are used to recognize you when you return
to our Services. This enables us to adapt our content for you
and remember your preferences. For example, we use functional
Cookies to remember your choice of language or region.
-
Targeting or Performance Cookies.
We also use Cookies for website analytics purposes in order to
operate, maintain and improve our Services. We may use our own
analytics Cookies or use third-party analytics providers such
as: Google Analytics. These providers may also collect
information about your use of other websites, apps, and online
resources.
Where required by applicable law, we will obtain your consent to
use Cookies. You can find more information about your rights and
choices, and how to block the use of certain Cookies in the
section Your Rights and Choices below.
C. Information We Receive from Third Parties
Third-Party Services.
You may also post photos, comments, or reviews on our pages
available through third-party platforms, including Facebook,
Twitter, LinkedIn or YouTube. If you do so, or if you otherwise
provide information to our ads hosted on third-party platforms,
we and other users may be able to view the personal information
you make available through these third-party platforms.
Partners. We may receive
additional personal information about you from third parties
such as data or marketing partners and combine it with other
personal information we have about you.
How We Use the Information We Collect
We use the personal information we collect:
-
To provide, maintain, improve, and enhance our Services;
-
To communicate with you, provide you with updates and other
information relating to our Services, provide information that
you request, and otherwise provide customer support;
-
For marketing purposes, such as developing and providing
promotional and advertising materials that may be useful,
relevant, valuable or otherwise of interest to you;
-
To personalize your experience on our Services such as
presenting tailored content;
-
To conduct research to understand and analyze how you use our
Services and develop new products, services, and features;
-
To de-identify and aggregate information collected through our
Services and use it for our business purposes;
-
To find and prevent fraud, and respond to trust and safety
issues that may arise;
-
For compliance purposes, including enforcing our legal rights,
or as may be required by applicable laws and regulations or
requested by any judicial process or governmental agency; and
-
For other purposes for which we provide specific notice at the
time the personal information is collected.
Legal Bases for Processing European Information
If you are located in the European Economic Area or the United
Kingdom, we only process your personal information when we have
a valid “legal basis”, including as set forth below.
-
Consent. You have
consented to the use of your personal information. For
example, we may process your personal information to send you
marketing communications, to use your personal information in
future recruitment efforts or to use Cookies where you have
consented to such use.
-
Contractual Necessity.
We need your personal information to provide you with our
Services. For example, we may need to process your personal
information to respond to your inquiries.
-
Compliance with a Legal Obligation.
We have a legal obligation to use your personal information.
For example, we may process your personal information to
comply with tax, labor and accounting obligations.
-
Legitimate Interests.
We or a third party have a legitimate interest in using your
personal information. Specifically, we have a legitimate
interest in using your personal information for product
development and internal analytics purposes, to exercise and
defend potential legal claims, to transfer information within
our group of undertakings, to verify the adequacy of your
qualifications and otherwise to improve the safety, security,
and performance of our Services. We only rely on our or a
third party’s legitimate interests to process your personal
information when these interests are not overridden by your
rights and interests.
How We Share the Information We Collect
We may disclose personal information we collect from or about
you as described below or otherwise disclosed to you at the time
of collection.
Partners and Affiliates.
We may share any personal information we receive with our
partners, subsidiaries, and affiliates, including to the Grid
Dynamics Group entities, for any of the purposes described in
this Privacy Policy.
Vendors and Service Providers.
We may share any personal information we receive with
contractors, vendors, service providers, and other third parties
retained in connection with the provision of our Services.
Analytics Partners. We
use analytics services such as Google Analytics to collect and
process certain analytics data. These services may also collect
information about your use of other websites, apps, and online
resources. You can learn about Google’s practices by going to
Google partnership
and opt-out of them by downloading the Google Analytics
opt-out browser add-on.
Advertising Partners. We
work with third-party advertising partners to show you ads that
we think may interest you. These advertising partners may set
and access their own Cookies, pixel tags and similar
technologies on our Services and they may otherwise collect or
have access to information about you which they may collect over
time and across different online services. Some of our
advertising partners are members of the
Network Advertising Initiative
or
Digital Advertising Alliance. If you do not wish to receive personalized ads, please visit
their opt-out pages to learn about how you may opt out of
receiving web-based personalized ads from member companies.
As Required by Law and Similar Disclosures.
We may access, preserve, and disclose personal information about
you if we believe doing so is required or appropriate to: (a)
comply with law enforcement requests and legal process, such as
a court order or subpoena; (b) respond to your requests; or (c)
protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers.
We may disclose and transfer your personal information to
service providers, advisors, potential transactional partners,
or other third parties in connection with the consideration,
negotiation, or completion of a corporate transaction in which
we are acquired by or merged with another company, or we sell,
liquidate, or transfer all or a portion of our business or
assets.
Consent. We may also
disclose personal information from or about you or your devices
with your permission.
Your Rights and Choices
Your California Privacy Rights.
If you are a California resident, you may exercise certain
rights by submitting requests to know and access the personal
information we have collected about you, to delete personal
information, to opt-out of the sale of personal information, and
to not be discriminated against for exercising these rights.
Please visit our
California Resident Privacy Notice
for supplemental information and disclosures regarding rights of
California residents.
Your European Privacy Rights.
If you are located in the EEA or the UK, you have the additional
rights described below:
-
You may request access to the personal information we maintain
about you, update and correct inaccuracies in your personal
information, restrict or object to the processing of your
personal information, have your personal information
anonymized or deleted, as appropriate, or exercise your right
to data portability to easily transfer your personal
information to another company. In addition, you also have the
right to lodge a complaint with a supervisory authority,
including in your country of residence, place of work or where
an incident took place.
-
You may withdraw any consent you previously provided to us
regarding the processing of your personal information at any
time and free of charge. We will apply your preferences going
forward and this will not affect the lawfulness of the
processing before you withdrew your consent.
You may exercise these rights by contacting us using the contact
details at the end of this Privacy Policy. Before fulfilling
your request, we may ask you to provide reasonable information
to verify your identity. Please note that there are exceptions
and limitations to each of these rights, and that while any
changes you make will be reflected in active user databases
instantly or within a reasonable period of time, we may retain
personal information for backups, archiving, prevention of fraud
and abuse, analytics, satisfaction of legal obligations, or
where we otherwise reasonably believe that we have a legitimate
reason to do so.
Marketing Communications.
If you provide Grid Dynamics with your email address, you may be
contacted by Grid Dynamics for marketing and campaign update
purposes. When you become a Grid Dynamics customer, you will be
subscribed to our automated campaign update emails. If at any
time you do not wish to receive email from Grid Dynamics in the
future, you can unsubscribe. In order to unsubscribe from a
mailing list, you may choose any of the following options:
-
Follow the unsubscribe link found at the bottom of the email
you’ve received.
-
Contact your client success team or our customer service and
ask to be unsubscribed from automated marketing and/or
campaign update emails.
-
Remove yourself from Grid Dynamics’s automated campaign update
emails by visiting our unsubscribe page. We will update your
preferences for this email address.
Please be aware that if you are a Grid Dynamics customer, a
member of our client success team may continue to manually
contact you via email for administrative or informational
purposes, including follow-up messages regarding business
transactions between Grid Dynamics and yourself. By law, such
messages are not considered to be commercial email.
How to Block Cookies.
You can block Cookies by setting your internet browser to block
some or all Cookies. However, if you use your browser settings
to block all Cookies (including essential Cookies) you may not
be able to access all or parts of our Services. By using our
Services, you consent to our use of Cookies and our processing
of personal information collected through such Cookies, in
accordance with this Privacy Policy. You can withdraw your
consent at any time by deleting placed Cookies and disabling
Cookies in your browser, or as explained below. You can change
your browser settings to block or notify you when you receive a
Cookie, delete Cookies or browse our Services using your
browser’s anonymous usage setting. Please refer to your browser
instructions or help screen to learn more about how to adjust or
modify your browser settings. If you do not agree to our use of
Cookies or similar technologies which store information on your
device, you should change your browser settings accordingly. You
should understand that some features of our Services may not
function properly if you do not accept Cookies or these
technologies. Where required by applicable law, you will be
asked to consent to certain Cookies and similar technologies
before we use or install them on your computer or other device.
Third Parties
Our Services may contain links to other websites, products, or
services that we do not own or operate. We are not responsible
for the privacy practices of these third parties. Please be
aware that this Privacy Policy does not apply to your activities
on these third-party services or any personal information you
disclose to these third parties. We are not responsible for the
privacy practices or the content of such sites. If you have any
questions about how these other sites use your personal
information, you should contact them directly. We encourage you
to read their privacy policies before providing any personal
information to them.
Retention
We take measures to delete your personal information or keep it
in a form that does not permit identifying you when your
personal information is no longer necessary for the purposes for
which we process it unless we are required by law to keep your
personal information for a longer period. When determining the
specific retention period, we consider various factors, such as
the type of service provided to you, the nature and length of
our relationship with you, and mandatory retention periods
provided by law and the statute of limitations.
Information Security
We make reasonable efforts to protect your personal information
by using technical and organizational safeguards designed to
improve the security of the personal information we maintain.
For example, we have a robust information security program in
place designed to protect personal information from unauthorized
access, alteration, disclosure or destruction in line with the
ISO 27001:2022 standard. Our security measures include policies
and procedures related to data classification, data encryption,
passwords, access restrictions, network segmentation,
vulnerability scanning, alerts, logging and monitoring,
anti-malware, secure development, threat intelligence and
security analytics, and employee security training and testing.
However, no electronic transmission or storage of personal
information can be entirely secure, we can make no guarantees as
to the security or privacy of your personal information.
Children’s Privacy
We do not knowingly collect, maintain, or use personal
information from children under 16 years of age, and no part of
our Services are directed to children. If you learn that a child
has provided us with personal information in violation of this
Privacy Policy, then you may alert us at
dpo@griddynamics.com.
International Visitors
Our Services are hosted in the United States and intended for
visitors located within the United States. If you choose to use
our Services from the EEA, the UK, or other regions of the world
with laws governing data collection and use that may differ from
U.S. law, then please note that you are transferring your
personal information outside of those regions to the United
States for storage and processing. We may transfer personal
information from the EEA or the UK to the United States and
other third countries based on European Commission-approved
Standard Contractual Clauses, as needed to perform our Services
that you have requested from us, or with your consent. Also, we
may transfer your data from the U.S. to other countries or
regions in connection with storage and processing of data,
fulfilling your requests, and operating our Services. By
providing any information, including personal information, on or
to our Services, you consent to such transfer, storage, and
processing. To obtain additional information on the transfers,
please contact us using the contact information below.
Changes to This Privacy Policy
This Privacy Policy may be revised from time to time. We will
post any adjustments to the Privacy Policy on this page, and the
revised version will be effective as of the last updated date.
If we materially change the ways in which we use or share
personal information previously collected from you through our
Services, we will attempt to notify you of the changes through
our Services, by email, or other means.
Contact Information
If you have any questions, comments, or concerns about our
processing activities, please contact:
If you are based in the EEA or the UK, the entity responsible
for the processing of your information is:
