Effective September 16, 2022
“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 lawfully made available to the public from federal, state, or local government records.
We collect/ receive your Personal Information in multiple ways, depending on which product/service, applications, or websites you use and how you interact with us.
You may choose to share personal and additional information with us by purchasing or interacting with our “Product/Service,” through various means including, but not limited to:
For some “Product/Service,” we may ask you to provide following information, including:
If you are an internal stakeholder (employee, contractor, freelancer etc), we may also seek your consent to process:
We may also collect this information indirectly from publicly available sources (such as your employer’s Website or professional social networks such as LinkedIn) or third-party data providers that maintain individuals’ contact information lists.
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:
Some of our websites may also feature cookies associated with certain unaffiliated companies. 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.
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. In addition, 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 to deactivate 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.
Some web browsers and mobile devices incorporate a “do not track” feature that signals to websites and online services that you do not wish to be tracked when enabled. However, because there is no accepted standard for responding to the do-not-track signal, we do not recognize or respond to these signals.
We may use the information we collect from you to:
We also use the information we obtain about you in other ways to 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. Therefore, we may ask for your consent in certain circumstances as indicated above, but if we do not ask for your specific permission:
We 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.
Internally, Personal Information is shared for legitimate business purposes, such as managing our relationship with you and other external parties, compliance programs, or systems and network security. We do this to improve efficiency, save cost and collaborate internally between our subsidiaries. Our internal access to Personal Information is restricted and granted only on a need-to-know basis. Sharing this information is subject to the appropriate intracompany arrangements, policies, and security standards.
In certain circumstances, Personal Information may be subject to disclosure to government agencies in accordance with judicial proceedings, court orders, or legal processes. We may also share Personal Information to protect the rights of Impetus or others when Impetus believes that such rights may be affected, for example, to prevent fraud.
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 we do not retain Personal Information longer than necessary in compliance with applicable law. When Personal Information is no longer needed, we have processes to securely delete it, for example, by erasing electronic files and shredding physical records.
Our Website 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.
The Services are not directed to, and we do not knowingly contact or collect Personal Information from individuals under the age of 16 years. Therefore, if you are under the age of sixteen, these Services are not intended for you, and you should not provide us with any Personal Information.
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 PrivacyOffice@impetus.com with a detailed request, including your full name, physical address, and email address. You also have, in particular circumstances, the right to object to or restrict our usage 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”).
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. However, if 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, the laws of the State of California /India, and by the law of the court of Indore, subject to the jurisdiction of the Courts at Indore.
Below is an overview of your various rights granted by EU-GDPR
You may also ask us:
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
In cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels or selected channels. We must always comply with your request.
This right does not include communications and information functions, such as alerts and notices, which are displayed in any application or product interface of ours that is part of the operation of or relates to a normal function of our product. By logging into our products or services, you expressly consent for such purposes. If you disagree, do not log in or use our products or services.
You can contact us and request to exercise these rights anytime by emailing privacyoffice@Impetus.com.
If we choose not to honor your request to exercise data privacy rights, we will explain the reasons for our refusal.
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 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 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:
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 PrivacyOffice@impetus.com.
Only you, or a person registered with the California Secretary of State 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. 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. Therefore, 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 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. Our response will also explain why 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 without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine that the proposal warrants a fee, we will tell you why we decided and provide you with a cost estimate before completing your request.
Non-discrimination: We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you Products 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 specific 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.
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 an effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.