Effective as of September 1, 2020
Imperion, Inc. understands that your privacy is important to you and that you care about how your personal information is used and shared online. We respect and value the privacy of everyone who visits this Website, and will only collect and use personal information in ways that are described here (whether or not you have an account with us), and in a manner that is consistent with our obligations and your rights under the law.
A. Registration on our Website
If we become aware that you are under the age of Majority and are attempting to or have submitted personal information via the Website, we will not accept such information and we will take steps to remove such information from our records. This may involve us having to access and verify your age and other relevant details.
- What information we collect about you and why;
- How we use information about you;
- How your information may be shared;
- How we store and process information about you;
- When and how we communicate with you;
- How long we may keep personal information about you;
- How you can opt-out from receiving communications from us;
- Information over the Internet and other websites;
- Offensive or inappropriate content;
- Legal disclaimer;
- How to contact us;
1. What information we collect about you and why:
We may collect two types of information: personally identifiable information (“PII”) and information that is not personally identifiable (“Non PII”).
A. What PII Do We Collect?
- When you register with us, we ask for information such as your name, postal address, zip code, email address, and telephone number. We also acquire your Internet protocol address and/or mobile device identification, which certain jurisdictions consider to be PII because it could be used to identify an individual or device if it were combined with other identifying information.
- We may capture user information when users send us questions or comments via e-mail. Information collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. Sending us an e-mail will not enroll you on our e-mail list unless you specifically request it.
- For purchases made on the Website, including subscription services, a third-party payment processor, such as PayPal, may collect your name, email address, postal address, contact details and credit or debit card information. This record will be stored and processed in the United States and other countries (see further below under “How we use information about you” and “How we store and process information about you”).
- For users who choose to participate in our referral program, information may be collected directly by or shared with third parties solely in connection with the operation of the program, such as your name, email address, postal address, contact details. This record will be stored and processed in the United States.
- We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards such as site monitoring, secured networks and servers, firewalls and/or encryption. When we ask for sensitive information, we protect it through the use of encryption during transmission, such as SSL (Secure Socket Layer). Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security.
- We may also obtain your personal information through your use of social media such as Facebook or LinkedIn, depending on your settings or the privacy policies of these social media services. To change your settings on these services, please refer to their respective privacy notices.
B. What Non PII Do We Collect?
- We may capture Non PII such as your user agent, referring URL, browser operating system, device type, location, and/or the language option you chose in your device. Some of the information that we acquire cannot identify, distinguish or trace you or your device. Alternatively, some information could be considered PII when combined with other identifying information. However, the information is not used by us in a way that identifies, distinguishes or traces you or your device, but is instead used in an anonymous way, often aggregated with other anonymous information about other users.
2. How we use information about you:
A. We may use the PII we collect in the following ways:
- to contact users with updates and relevant information about our products and services because they have signed up to do so through our Website. If you would no longer like to receive promotional e-mails or other communications from us, please refer to the “How you can opt-out from receiving communications from us” Section below;
- to provide users with personalized offers, promotions, news, events and other information relevant to them because they have signed up to do so through our Website;
- to quickly process user requests for information and to allow us to respond efficiently to user questions;
- to monitor Website statistics;
- to respond to or satisfy legal requirements, such as a court order, a subpoena, or a law enforcement agency’s or other public agency’s request;
- to help prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Website, to help protect the security or integrity of our Website, or to enable us to take precautions against liability;
- to provide information to service providers or such companies who provide support for the operations of our Website and who do not use or disclose the information for any other purpose;
- to administer a contest, promotion, survey, or other features; and
- to allow us to disclose your information to the extent permitted by law.
3. How your information may be shared:
Except as set forth below, we do not sell, trade, or otherwise transfer to third parties our users’ PII unless we receive their consent. In the following situations, we may share PII with outside parties:
- Subsidiaries and Affiliates. We may transfer personally identifiable information to our subsidiaries and corporate affiliates;
- Website Consultants and Service Providers. We may disclose personal information to third party consultants and service providers (such as providers of hosting, support, maintenance; third party payment processing agencies; reward fulfillment agencies, and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service us and the Website. We use Outbrain as a native advertising and content discovery platform; PubGalaxy to display advertising solutions; Admiral as a consent management tool; Connatix and AnyClip as a video advertising solution; StackCommerce as a native commerce platform; JW Player as a video player software; Facebook Social Share and LinkedIn as social media plug-ins; Hotjar for user engagement and web analytics and Google Analytics and Yandex Metrica for web analytics software. For more information on how your PII is used by these companies, please refer to their respective privacy policies;
- Reorganization or Sale. In the event that we merge with or become a part of another organization, or in the event that we are sold, we sell all or substantially all of our assets, or we are otherwise reorganized, the information you provide will be one of the transferred assets to the acquiring or reorganized entity;
- To Help Protect Minor Users of Our Website. In the event that the safety of our users is threatened, and we are able to do something about that by sharing PII with third parties, we reserve the right to do so. This may be done to prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Website, to help protect the security or integrity of our Website, or to enable us to take precautions against liability;
- As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized by applicable law to do so;
- Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer that aggregated information to third parties;
- We may make available services such as blogs, message boards and chat functionality to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on the Website becomes public information, and may be available to visitors to the Website and to the general public. In addition, when you choose to make a posting on such services certain personal information will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose personal information about you, or any other information, on the Website. WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD PARTY OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY SUCH SERVICES OR OTHERWISE ON THE WEBSITE; and
- With your express consent.
4. How we store and process information about you:
In order to communicate with you about products, local events, offers and opportunities, the information that we collect from you may be transferred to, stored, used and processed by Imperion in the United States or one of our service providers based in the United States or outside of the United States. Such entities may be engaged in, among other things: (i) preparing and sending newsletters to which you subscribe; (ii) the processing of payment details; and (iii) the provision of support services.
YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR INFORMATION WITH US, OR MAKE USE OF THIS WEBSITE.
TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISIDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.
5. When and how we communicate with you:
We may use the information we collect to contact you by mail, email and telephone (including automated calls, and by SMS text messages and other multimedia electronic messages such as picture messaging).
We will not send you unsolicited premium rate SMS messages (which are SMS messages you pay to receive), although your service provider may impose a charge on any messages that you receive. Please check with your service provider for details.
You can unsubscribe from promotional emails and other commercial communications by following the instructions contained within the communication. Please note that due to marketing production schedules you may receive any messages already in production.
6. How long we will hold personal information about you
We will hold personal information about you on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with Imperion, subject to any applicable laws and/or regulations. In the case that you wish to cancel your registration as a member of the Website once an account is deleted, we cannot use the personal information about you other than for administrative purposes.
Where you contribute to the Website, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.
7. How you can opt-out from receiving communications from us:
At any time you can add or remove your name from an Imperion Info list by contacting us at email@example.com.
We will endeavor to comply with your request as soon as reasonably practicable. Please keep in mind that if you opt-out of receiving promotional messages from this Website, we will continue to send you transactional messages and important account-related information regarding this Website or products or services offered through this Website.
9. Information over the Internet and other Websites
The Internet is a global network and, therefore, there are times when information about you travels globally and may not always be completely secure. If you provide us with information over the Internet, this will be at your own risk. By using the Website, you agree and authorize us to process information in this way. However, please be assured that we use commercially reasonable procedures and security features to prevent unauthorized access to information about you.
10. Offensive or inappropriate content
If you find any link on our Website that is offensive for any reason, you are free to contact and inform us any moment. We will consider requests to remove links but we are not obligated to or so or to respond to you directly. You acknowledge that we have not reviewed and do not necessarily endorse the content of these websites, applications, destinations or services linked to or accessible from this Website and are not responsible for the content or actions of any other sites, applications, destinations or services. Your linking to or accessing any other website, application, destination or service is at your sole risk.
11. Legal disclaimer
We are not responsible nor will be liable to you in any way for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee nor do we represent that our performance will be error free, and to the maximum extent permitted by law we will not be liable for any direct, indirect, incidental, consequential or punitive damages or other loss suffered by you and relating to the use or release of your personal information.
YOUR CALIFORNIA PRIVACY RIGHTS
Disclosures about the use of your Personal Information
If you have registered an account with us or purchased a subscription offering, in the past twelve months, we have disclosed the following categories of Personal Information as defined by the CCPA for our business purposes to our technology vendors: (i) Identifiers such as a name or email address; and (ii) Other personal information described in Cal. Civ. Code Section 1798.80(e), such as credit card information.
We do not sell users’ Personal Information, but we do disclose Personal Information for a business purpose to third parties such as our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Information on how you can opt out of selling your information with these vendors for purposes beyond the advertising services they provide us is provided below (“Opt out of sale of your Personal Information”). You also can opt out of sharing your information for personalized advertising through the available web- and app-related opt-outs listed above.
Data Rights: Under the CCPA, you have the right to: Know your Personal Information. You can request information about the Personal Information collected from your use of the Website. You will need to provide your email address so we can return the requested data to you. To request specific pieces of information, you may email firstname.lastname@example.org for further instructions. Please note that we may take steps to verify your identity before you can make a request to know your Personal Information.
Delete your Personal Information. You can request that we delete the Personal Information that we have collected from your use of the Website. You will need to provide your email address so we can confirm to you that we have fulfilled your request. We will delete your information unless it is necessary for purposes permitted by CCPA.
Non-discrimination. If you choose to exercise any of these rights, we will not deny goods or services to you or provide different quality of services, unless that difference is reasonably related to the value provided by your data.
Authorized Agent. You can designate an authorized agent to make a request under the CCPA on your behalf provided that (1) it is a natural person or a business entity registered with the Secretary of State of California; and (2) you have authorized the authorized agent to act on your behalf. Authorized agents may email email@example.com for further instructions. To protect your information, please note that we may take steps to verify your identity and we will also ask for a signed permission from you authorizing the authorized agent to submit a request on your behalf.
Whenever a user agrees to allow us to collect personal information, we provide the user with an option to prevent information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by sending an email to firstname.lastname@example.org
12. How to contact us
We welcome your questions, comments and concerns about privacy. Please contact us at email@example.com with any questions or comments you may have regarding the privacy of your information.
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