Privacy Policy – Impetus Technologies Inc. & Impetus Technologies India Pvt. Ltd.

Effective January 01, 2020.

Impetus Technologies Inc. & Impetus Technologies India Pvt. Ltd. (“We”) care about your privacy. This Privacy Policy describes the types of personal information we may collect, how we may use and share that information, and how we protect it. By using, accessing, or purchasing our applications, products/services, and/or websites (the “Product/Service”), you agree to the terms of this Privacy Policy. We are not in the business of selling your personal information to advertisers or spammers.

“Personal Information” is any information, whether correct or not, and whether recorded in a material form or not, that relates to you, and which, alone or in combination with other information, could reasonably be used to identify you. However, it does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

We may make changes to this Privacy Policy from time to time. We will indicate the recent update date at the top of the policy, and highlight any significant changes to the policy.

This Privacy Policy will apply to the use of all Products & Services that may be hosted by us, or a third-party service provider on our behalf (a “Cloud Implementation”).

If you are using our Product/Service as part of a service other than a Cloud Implementation (e.g., one that is hosted on-premises by your employer), then: (i) we are not collecting, using, or sharing any of your personal information; and (ii) the organization that makes the service available to you (or, if applicable, the third party that hosts the services on behalf of such organization) (the “Implementing Organization”) may collect, use, or share your personal information., Details of the personal information they collect may be found in their privacy policy. If you are using our Products/Service as part of an implementation of our “Product/Service” other than a Cloud Implementation, please contact the Implementing Organization to obtain information regarding what personal information they collect and how they use or share that information. In such cases, we shall not be responsible for the protection of personal information. However, we strictly advise you to please read those third-party policies and agreements.

Information we collect

We may collect/ receive your personal information in multiple ways, depending on which product/service, applications, or websites you use and how you interact with us.

Information you provide and we collect from other sources

You may choose to submit personal information and additional information to us by purchasing or interacting with our “Product/Service.” Examples include:

• When you create and manage a user account
• Join or connect with a network
• Request technical support,
• Request any information
• Communicate via email, telephone, or online chat
• Upload information through our “Product/Service”
• Subscribe to newsletters or other subscription services
• Register for training or conferences
• Purchase Product/Services
• Submit job applications
• Participate in surveys

For some “Product/Service,” we may ask you to provide information including:

• Basic personal details (e.g., your name, title, and gender)
• Contact details (e.g., your email address, postal address, and phone number)
• Professional details (e.g., your company or organization name and any professional organization memberships)
• Usernames or URLs
• Payment details (e.g., credit card information, bank account, etc.)
• Your photo
• Any other personal information you choose to provide us (e.g., in communications with technical support services, marketing teams, or during the provision of products/services)

Some of the information is necessary for us to provide you a particular “Product/Service,” and our ability to deliver the “Product/Service” may be affected if you do not provide certain information.

We may also collect this information indirectly, like from publicly available sources (such as your employer's website or professional social networks such as LinkedIn), or from third-party data providers that maintain lists of individuals' contact information. Other users of our “Product/Service” may also provide information about you when they submit content through the use of our “Product/Service.” For example, you may be mentioned in a technical support case opened by someone else. Similarly, an administrator may provide your data, such as when they designate you as the billing or technical contact on your company's account.

Please note that we may also have access to your personal information that our customers may have uploaded to our cloud services.

Biometric information

The biometric information is subject to those third-party-owned privacy policies, terms and conditions, and other policies. In such cases, we shall not be responsible for the protection of personal information. However, we encourage you to read those third-party policies and agreements before participating in such credentialing activities.

Information we collect

When you access or use our “Product/Service,” we may collect certain information about your device and your use of our “Product/Service.” Such information may include:

• Information, including version information, about the web browser or application you are using
• Products/services you purchased, with related pricing
• If you are using a mobile device, the model of the device and its operating system
• Crash data
• A unique identifier we assign to you
• Your IP address
• Information about your usage of our “Product/Service,” including what functions or pages you use, the frequency of your use, links that you click, and how often you log in.

Location information

To provide certain features of our “Product/Service,” we may request your permission to access location information from your device. Some functions of our “Product/Service” may not work if you choose not to allow access to this location information. If you have provided  your consent  to share your location information through one of our applications or websites, you can restrict the access later by changing the settings on your device or by uninstalling the applications. In addition, even if you have not enabled location services for the applications or websites, we may derive your general location information from your use of the applications or websites, including your Bluetooth signal while using our Product/Service.

Cookies and similar technologies

When you use our websites, we may collect certain information by automated means, such as cookies. A "cookie" is a file that websites send to a visitor's computer or other Internet-connected devices to uniquely identify the visitor's browser, store information, or settings on the device. The information we collect in this manner enables us to serve the returning visitors better. For example, it can "remember" and auto-populate your email address in the future. We also use cookies to track responses to our marketing materials, such as emails and online advertisements. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. For more information about our cookies, please email inquiry@impetus.com.

Some of our websites also use marketing automation technology (Pardot) to collect data on visitor’s behavior. These Pardot cookies help us track your visits to our websites and enable us to create an engaging marketing experience for you. We also use Pardot cookies to understand your interaction with the emails we send you and to ensure we’re sending you relevant information. Specifically, Pardot cookies let us know whether our emails have been opened and which links are clicked. For more information on Pardot privacy and cookie policy, please click here.

Some of our websites may also feature cookies associated with certain unaffiliated companies. For example, we partner with other companies to connect you to certain social networks, such as Facebook, Twitter, and YouTube. By engaging with such other companies’ sites, for instance, by clicking the Facebook "Like" button found on our website, such companies may place session or persistent cookies on your device. This may allow these third parties to collect information about your online activities over time and across websites. The use of these cookies is subject to such third-parties’ cookie policies, which we strongly recommend you review.

Web analytics and interest-based advertising

We may use web analytics services on our websites, such as those of Google Analytics. The service providers that administer these services use cookies to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed or collected directly by these service providers, who use the information to evaluate the use of the website or for advertising purposes, as described below.

Some of our online advertising takes place through Google Display Advertising. As a part of this program, we use Google Analytics features such as Retargeting. We and the operators of these ad networks, including Google, may use third-party cookies (such as the DoubleClick cookie) – and in some cases first-party cookies (such as the Google Analytics cookie) – to inform, optimize, and serve ads across the internet based on a user’s past visits to our website.

You can opt-out of Google Analytics for Display Advertising or customize Google Display Network ads using the Google Ads Preferences Manager. To disable Google Analytics in general, please download the browser add-on for the deactivation of Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout. To learn more about other ad networks, including how to opt-out, click here.

Do not track

Some web browsers and mobile devices incorporate a “do not track” feature which, when enabled, signals to websites and online services that you do not wish to be tracked. Because there is not yet an accepted standard for how to respond to such a do-not-track signal, we do not recognize or respond to these signals.

How we use the information we collect

We may use the information we collect from you to:

• Provide products/services to you
• Bill/invoice you
• Manage any accounts that you may have with us
• Validate your identity
• Send personalized marketing messages via email, post, and telephone. Where required by applicable law, we will only send these messages with your consent, and you have the right to opt-out of receiving marketing by contacting us
• Serve relevant advertising on our site and third-party sites related to our products and services  personalized to your interests
• Provide you with notice of product releases, special events, training, promotions, or other matters relevant to you
• Respond to your inquiries
• Improve the services you receive from us
• Solicit your feedback
• Prevent you from having to re-enter personal information about you on future visits to our websites or subsequent use of our applications
• Facilitate your access to third-party services and resources
• Keep track of your activities
• Process your payments and purchases
• Operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing, and other internal functions)
• Detect and prevent fraud and other unauthorized activity and enforce our terms of use
• Comply with applicable legal requirements, relevant industry standards, and our policies

We also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

If you are an individual in the E.U., we may be required to have a legal basis to process your personal information for these purposes under applicable E.U. law. We may ask for your consent in certain circumstances as indicated above, but if we do not ask for your specific Consent :

• We use your personal information for certain purposes as it is necessary to comply with contractual obligations we have to you, including when we provide our “Product/Service” to you following the applicable terms and conditions, or when we process payments and purchases you make
• We may also use personal information to comply with our legal obligations, such as financial reporting obligations and compliance with subpoenas or similar court orders or order of government/statutory/federal agencies
• Where not strictly required by contract or by law, we use personal information to meet our legitimate business interests (when your data protection interests do not override the use) in running our business efficiently, in advertising our products and services to existing and prospective customers, understanding how our business is performing, defending our interests and legal rights, and keeping our records accurate and up to date. We take steps to ensure that your personal information is not used in ways other than those you would expect, and subject to laws in the country where you live, you have the right to object to our uses of personal information on this basis.

How we may share information

We disclose your information: (i) to our third-party service providers; (ii) to our other group companies; (iii) if we are required to do so by law, regulation, or legal process (such as a court order or subpoena), (iv) in response to requests by government agencies, such as law enforcement authorities, (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity (vi) to protect our legitimate business interests, or (vii) with your consent, in any other case. We also reserve the right to transfer any information we have about you in connection with any sale or transfer of all or a portion of our business or assets, including in the event of a reorganization, dissolution, or liquidation.

In addition, if you are using our Product/Service, we may share certain information with the administrator of our Product/Service Network that you are a member of, with other users of our Mobile application, or with third-party services with which our application is integrated.

How we protect personal information

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

We also ensure that, in compliance with applicable law, we do not retain personal information longer than necessary. We will keep your data as long as we have a relationship with you, for example, as long as you wish to continue receiving marketing messages from us, or as long as you are a customer (and for a reasonable period after that). When determining how long to retain personal information after we no longer have a relationship with you, we take into account how long our customers usually want to continue hearing from us, our legal obligations, and the expectations of regulators, as well as the length of time the information is needed for internal audit purposes and to exercise or defend our legal rights.

Links to other websites

Our “Product/Service” may contain links to websites maintained by third parties, whose information and privacy practices differ from ours, including, for example, websites that process online payments. We are not responsible or liable for the content of any such websites, any use of such websites, or the information or privacy practices employed by the providers of such websites. We encourage you to read the privacy statements of all third-party websites before using such websites or submitting any personal information or any other information on or through such websites.

Not for use by children

The Services are not directed to, and we do not knowingly contact or collect personal information from individuals under the age of thirteen. If you are under the age of thirteen, these Services are not intended for you and you should not provide us with any personal information.

Access and correction

To request a copy of the personal information , update or correct inaccuracies in that information, or request to remove your information from our systems and stop contacting you; please email to inquiry@impetus.com with detailed request, including your full name, physical address, and email address. You also have, in particular circumstances, the right to object to our uses of your personal information, the right to restrict our uses of your personal information, and the right to have personal data transmitted in the electronic form to you or a third-party (the right of “data portability”).

How to contact us

If you have any comments or inquiries about this Privacy Policy, if you would like to update your information, or to exercise your rights, send an email to inquiry@impetus.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country in which you live via their website.

This Policy will be governed by and construed according to the laws of the United States of America and by the laws of the State of California /India and by the law of court of Indore, subject to the jurisdiction of the Courts at Indore.

PRIVACY NOTICE AND DISCLOSURES FOR CALIFORNIA RESIDENTS

This section applies solely to the personal data of users  (i.e., a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017, however identified, including by any unique identifier) ("You") and supplements the information contained in our Privacy Policy. We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA), and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices: The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

• Access to specific information and Data portability rights: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable  request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

• Deletion request rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Exercising Access, Data portability, and Deletion rights. To exercise the access, data portability, and deletion rights described above, please email a valid consumer request to inquiry@impetus.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable  consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within 12 months. The verifiable A valid consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

• Response timing and format: We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover 12 months preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• Non-discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you Product or services; (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggests that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Contact Information: If you have any questions or comments about this notice, how we collect and use your information described in this section, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at inquiry@impetus.com

Changes to Our Privacy Notice: We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website with effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.