1) Personal Information IMPACT gathers

“Personal Information” is information that can be used to identify, locate, or contact an individual. IMPACT collects the following types of Personal Information:

Contact Information. Contact Information allows IMPACT to communicate with you. Examples of Contact Information include, but are not limited to, your name, accurate postal addresses, valid email address, or other addresses at which you receive communications from or on behalf of IMPACT. IMPACT may also request demographic contact information including, but not limited to, your job title, job function, and corporate title. 

Transaction Information. IMPACT automatically receives and records some information from your browser when you visit the site, such as your IP address, cookies and data about which pages you visit on the site through the use of log files provided by our third-party tracking-utility partners. This information helps IMPACT analyze and understand how the site works for users. Information that is gathered includes, but is not limited to, information about how you interact with IMPACT, information about how you use IMPACT’s Sites, email, other communications, and applications, and how you interact with other users and IMPACT business partners.

Mobile Location Information. If you have permitted your mobile or other location-aware device to transmit location data, IMPACT collects Mobile Location.

Posted Information. If you chose to post a comment on IMPACT’s blog, IMPACT may collect information regarding your name and the content of your post. It is important to note that any content you post on the blog is publicly displayed and will be seen by other users of the Site. 

2) How IMPACT Collects Personal Information

IMPACT gathers Personal Information in the following ways:

If and when you are prompted and to provide Personal Information (including Contact Information) when you use IMPACT or otherwise interact with the Site or contact IMPACT.

When you use the Site. For example, IMPACT may track the pages you view, the methods of communication that may be offered on or through the Site from time to time. IMPACT uses cookies and related technologies to collect information about your computer and your interaction with the Site and our partner websites.

If and when you contact IMPACT via telephone, email, or other methods of communication.

Lawful basis for IMPACT’s processing of your Personal Information:

As applicable, the following is the lawful basis IMPACT relies on to process your Personal Information:

Legitimate Interest means the interest of Impact in conducting and managing its business to enable it to give you best service/product and the most optimized and secure interaction. IMPACT makes sure to weigh any potential impact on you (both positive and negative) and your rights before IMPACT processes your Personal Information for its legitimate interest. Unless IMPACT has your consent or is otherwise required or permitted to by law, it will not use your Personal Information for activities where the impact on your overrides IMPACT’s interests.

3) How IMPACT Uses Personal Information

IMPACT may use Personal Information to enhance to enhance your user experience, to help IMPACT better understand you, to help IMPACT customize offers, blog topics, or posts that may be of interest to you, and to help IMPACT otherwise enhance the Site.

IMPACT uses Personal Information to:

• Identify and authenticate users;
• Facilitate transactions;
• Operate and improve the Site;
• Connect with you on social media (such as Facebook, LinkedIn, or Twitter);
• Contact you by phone or email;
• Personalize and continually improve users’ IMPACT experience;
• Provide you with suggested information based on variables such as stated preferences, interests, business activities, and/or location;
• Send you technical notices, updates, alerts and support and administrative messages service bulletins, or marketing;
• Evaluate additional services, items, or offerings that may be of interest to users;
• Track transactions and perform other analytics;
• Communicate and provide additional information that may be of interest to you about IMPACT partners or third parties; and
• Manage IMPACT everyday business needs such as Site administration, communication management, analytics, fraud prevention, enforcement of our corporate reporting obligations, Terms of Use or to comply with the law.

4) When and Why IMPACT Discloses Personal Information

IMPACT will not disclose your Personal Information to third parties without your explicit consent, except as specified in this Privacy statement. IMPACT will disclose your Personal Information when:

• Working with companies and service providers (i.e. HubSpot, Salesforce.com, or other companies that process billing, website hosting, or analytics performance in furtherance of the purposes described in Section 3 (“How IMPACT Uses Personal Information”) above.
• IMPACT employs other companies to perform tasks on IMPACT’s behalf and therefore IMPACT must share your Personal Information with these companies to provide services to you. Examples include but are not limited to processing payments, handling billing disputes and collections, analyzing data, providing marketing assistance and providing customer service. IMPACT may partner with third-party services for fraud prevention and/or identity verification.
• Enforcing IMPACT’s rights or protect IMPACT property and intellectual property;
• Protecting the rights, property or safety of others, investigate fraud, respond to a government request.
• IMPACT believes in good faith that it must disclose such information to prevent imminent physical harm or financial loss.
• IMPACT believes in good faith that it must disclose such information to commence an investigation or take action regarding illegal activities or suspected fraud.
• IMPACT believes in good faith that it must disclose such information per auditing, compliance, and corporate governance functions.
• IMPACT believes in good faith that it must disclose such information to defend IMPACT in litigation or a regulatory action.
• IMPACT believes in good faith that it must disclose such information, or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate.

IMPACT will not sell your Personal Information to third parties unless IMPACT is in the process of entering into a merger with another business, acquisition of another business, or the sale of all or a portion of IMPACT’s assets and the information is needed to support the sale or transfer of business assets.

This Privacy Statement only governs when and why IMPACT discloses Personal Information. This Privacy Statement does not apply to the practices of third parties that IMPACT does not own or control, or individuals that IMPACT does not employ or manage. The use of your Personal Information by third parties that you access through the Site is governed by the privacy policies of such parties and is not subject to IMPACT’s control. IMPACT is not responsible for the privacy or security practices of other websites on the Internet, even those linked to or from the IMPACT Site. IMPACT encourages you to ask questions before you disclose your personal information to others.

IMPACT may disclose information about you that is not personally identifiable. For example, IMPACT may provide our partners, (such as HubSpot or Salesforce.com), or other third parties with reports that contain aggregated and statistical data about IMPACT users.

5) Personal Information Retention

To determine the appropriate retention period, IMPACT considers the type and volume of the information, the negatives that can result from un-permitted access to such information, why IMPACT gathers such information and the availability of achieving the goals of such gathering through alternative means.

6) Tracking Technologies - Indirect Data Collection

IMPACT implements cookies to store user information and track user activities. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information. Cookies enable IMPACT to monitor your activity across sessions of interaction between your device and the Site. Please see #7, Choice and Control, for information on how to refuse cookies.

7) Choice and Control

While IMPACT does need to gather certain information to make your IMPACT experience personalized and to conduct transactions for you, IMPACT wants to give you the ability to control how your information is provided and shared.

• Email Preferences. For various reasons, IMPACT may contact you about our services or your activity.
• Cookies and Tracking Devices. Upon visiting IMPACT’s site for the first time (or after a clearing a browser’s cache) you will be shown a notification. You may click “accept” to clear the notification. However, we will, by default, use cookies when you visit our site.

  The notification states: “This website uses cookies to remember you and improve your experience. To find out more see our Privacy Policy.”

  If you would like to decline cooking tracking, you can manage how your browser handles cookies and other tracking devices by adjusting the privacy and security settings on your browser. If accessing IMPACT by a mobile device, you may manage the information your mobile device shares, such as cookies, tracking technologies, and location information, by adjusting your mobile device privacy and security settings.

8) Security of Personal Information

IMPACT strives to use commercially acceptable means to protect your Personal Information, however, no method of transmission over the Internet, or method of electronic storage, is 100% secure and therefore IMPACT cannot guarantee absolute security of your personal information. IMPACT strives to maintain a system that reasonably safeguards Personal Information and has put in place appropriate security measures to accomplish the foregoing. 

9) EU Data Subject Rights

In certain circumstances, you have the following rights under data protection laws in relation to your Personal Information:

• Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information IMPACT holds about you and to check that IMPACT is lawfully processing it.
• Request correction of the Personal Information. This enables IMPACT to have any incomplete or inaccurate data held about you corrected, though IMPACT may need to verify the accuracy of the new data provided.
• Request erasure of Personal Information. This enables you to ask IMPACT to delete or remove Personal Information where there is no good reason for IMPACT continuing to process it. You also have the right to ask IMPACT to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where IMPACT may have processed your information unlawfully or where IMPACT is required to erase your personal data to comply with local law. Note, however, that IMPACT may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to gathering of your Personal Information where IMPACT is 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 gathering on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where IMPACT is gathering your Personal Information for direct marketing purposes. In some cases, IMPACT may demonstrate that it has compelling legitimate grounds to gather your information which override your rights and freedoms.
• Request restriction of gathering of your Personal Information. This enables you to ask IMPACT to suspend the gathering of your personal data in the following scenarios: (a) if you want IMPACT to establish the data's accuracy; (b) where IMPACT’s use of the data is unlawful but you do not want IMPACT to erase it; (c) where you need IMPACT to hold the data even if IMPACT no longer requires it as you need it to establish, exercise or defend legal claims; or (d) you have objected to IMPACT’s use of your data but IMPACT needs to verify whether it has overriding legitimate grounds to use it.
• Request the transfer of your Personal Information to you or to a third party. IMPACT will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for IMPACT to use or where IMPACT used the information to perform a contract with you.
• Withdraw consent at any time where IMPACT is relying on consent to gather your Personal Information. However, this will not affect the lawfulness of any gathering carried out before you withdraw your consent. If you withdraw your consent, IMPACT may not be able to provide certain products or services to you. IMPACT will advise you if this is the case at the time you withdraw your consent.

10) Withdrawing Consent

If IMPACT is relying on your consent for certain activities, you have the right to withdraw you sent at any time by contacting IMPACT at contact@impactplus.com 

11) Privacy Practices of Third Parties.

This Privacy Statement describes the collection, use, and disclosure of information by IMPACT through the Site. IMPACT utilizes third parties to provide services to users and also provides links from the Site to other websites. These third parties may have their own privacy policies and may collect, use, and distribute information differently than IMPACT. IMPACT encourages all users to read the privacy policies of all third parties.

12) IMPACT Blog

IMPACT contains a blog and other areas where users may publicly post information, communicate with other users, and submit content they deem relevant for discussion. IMPACT strongly encourages you to read the IMPACT Terms of Use carefully prior to posting or engaging in the blog. All the information you post will be accessible to anyone, at any time, with Internet access. Furthermore, IMPACT strongly advises you to NOT post any personal or identifiable information about yourself or contact information, including address, email, phone numbers, or other means of communicating outside of the blog. Any information you post may be read, collected, and used by others.

13) Changes to this Privacy Statement

IMPACT may, from time to time, in IMPACT’s sole, absolute, and unfettered discretion, update this Privacy Statement to clarify its practices or to reflect new or different privacy practices. IMPACT encourages all users to periodically review the Privacy Statement. You are bound by any changes to the Privacy Statement when you use the Site after such changes have been first posted.

If you have questions or suggestions, you may contact IMPACT by sending an email to contact (at) impactplus.com.