Privacy Policy for Integrated Marketing Solutions, Inc.
This Privacy Policy (“Policy”) describes how Integrated Marketing Solutions, Inc. (“IMS,” “we,” or “us”) collects, uses, and discloses your personal information in connection with your use of our website(s) (the “Site”) and the related services (together with the Site, the “Services”).
Please read this Policy carefully to understand our policies and practices regarding such personal information. This Policy may change from time to time, so please check the Policy periodically for updates. If you do not agree with the terms of this Policy, please do not use the Services.
This Policy contains the following sections:
BACKGROUND: OUR SERVICES
Background: Our Services
We provide strategic and consulting Services to a range of customers, particularly to help companies analyze their own consumer data and/or data they have licensed. We also assist our customers in their purchase of data from third parties, generally pursuant to the contract between organizations and the third party.
Under privacy and data protection laws, IMS usually acts as a “processor” and “service provider” to the customer with respect to that information. This means that IMS generally handles personal information pursuant to our contracts with and instructions from our customer. This personal information, i.e., the information provided by our customers, are subject to those customers’ privacy policies, rather than our own (and rather than this one). In turn, any inquiry or request you might have relating to such data should be directed to the relevant customer, not IMS.
While the information we collect or process on behalf of our customers is described in those customers’ own privacy policies, we describe the information the information we collect on our own behalf in this Policy.
INFORMATION WE COLLECT IN PROVIDING OUR SERVICES
Information we collect in providing our services
We may collect a variety of personal information. The information we collect about you depends on the Services you use, how you use them, and the information you provide to us. We collect personal information in three main ways: (1) information you provide to us; (2) information we collect automatically through technology when you use the Services; and (3) information we collect from other sources.
a. Information You Provide To Us
You may provide the following types of information to us:
- Identifiers (such as name, username, physical address, email address, phone number, and other contact information by which you may be contacted online or offline);
- Commercial information (such as information provided to us in your communications, customer service interactions, transaction data, information about interactions with IMS or our partners, information about your interests and preferences, information you provide related to a promotion, and your posts to our community forums);
- Financial data (such as payment information);
- Internet or other network or device activity (such as IP addresses, device identifiers, cookie data, device attributes, device usage information, browsing information, metadata, and other information; and utilization data and configuration settings related to your use of our products);
- Professional or employment-related data (such as company name and position);
- Other information that identifies or can be reasonably associated with you; and
- We may draw inferences from any of the above.
b. Information We Collect Automatically
We also may receive and store certain personal information about yourself and your device(s) automatically when you access or use the Site. This information may include:
- Log Information: When you use the Site, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser or device type and language, referring URLs, access times, pages viewed, links clicked and other information about your interactions with the Site.
- Mobile Device Information: We may collect information about the mobile device you use to access or use the Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Activity information: We may store information about your use of the Site, such as website pages visited, date and time of your visit, transactions you initiate, and emails you receive, open, and click.
- Cookies (and cookie identifiers): We and our third-party service providers, which may include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information – including the above information — about the computers or devices (including mobile devices) you use to access the Site, including the above information. Sometimes, we work with third parties who deploy these cookies on our behalf. When we use these cookies to target ads to you – for instance, to “retarget” you on other services with information about services, after you’ve visited our Site – we give you the opportunity to “opt-out” of these ads: see “Tailored Advertising” below for information about those “opt-out” methods. We also use cookies for analytics, and other purposes, as described further in “Analytics” below.
c. Information We Collect From Other Sources
We may also receive personal information from third parties, including our service providers, affiliates, and partners (such as organizations with whom we partner on events and contests, resellers, customers, technology vendors, business information vendors, and list brokers), as well as from publicly available sources (such as LinkedIn and company websites). We may combine some of that information with other information we have about you. We may sometimes receive personal information, such as contact information, from third parties that seek to help us identify potential customers, or to provide us with information about our own customers (such as information to help us contact them, or to help us validate the information that is already in our databases).
HOW WE USE THE INFORMATION WE COLLECT
How we use the information we collect
We may use your personal information for any of the following reasons:
- Providing and operating the Services, including the Site;
- Developing new products and Services, including conducting analysis (for instance, analyzing public opinion);
- Communicating with you, including through advertisements, promotions and email, which may be through social media platforms;
- Analyzing how people use our Services including the Site, or respond to our marketing and communications;
- Protecting our users, Site, and properties, and complying with the law;
- For internal auditing and recordkeeping purposes,
- Detecting, investigating, and preventing improper or fraudulent use of our Services or the Site;
- Protecting our rights, and complying with the law;
- Evaluating job applications (as applicable);
- Communicating with you on behalf of a client of ours and/or in response to a survey (as applicable);
- Bug detection and error reporting; and
- Other uses about which we notify you.
We may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify information collected through the Site. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties.
DISCLOSING INFORMATION TO THIRD PARTIES
Disclosing Information to Third Parties
We may disclose your personal information as follows:
- To provide Services you have requested
- Within IMS for a variety of purposes, including providing you with the latest information about our Services and offering you our latest promotions.
- To IMS affiliates.
- To service providers who perform services on our behalf. These parties provide a variety of services to us, including without limitation billing and collections, marketing and advertising, market research, data storage, web hosting, customer and tech support, security, data enhancement, analysis and processing, auditing, accounting and legal services.
- If required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the law or comply with legal process served on IMS; (b) protect and defend the rights or property of IMS; and/or (c) protect the personal safety of IMS, customers of IMS, or the public.
- In connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing between any future parent, subsidiary, and/or affiliated company.
- In other situations, with your consent or at your direction.
Your Opt-Out Choices For Analytics and Marketing
a. Analytics
We may use third-party web analytics Services on the Site, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the service, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
b. Tailored Advertising
We may allow certain third parties (e.g., ad networks and ad servers such as Google Analytics) to serve targeted marketing to you on our behalf (for instance, when you are on our website) and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Site. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Site by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. However, the parties that use these technologies may offer you a way to opt out of targeted advertising as described below.
Targeted advertising often employs cookies and other device identifiers to identify you, your browser or your device. In turn, sometimes these cookies may be associated with de-identified data linked to or derived from data you have submitted to us (e.g., your email address) that we may disclose with a service provider in a hashed format.
For more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Site, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. We do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites, accessible by the above links.
c. Email Marketing
You may opt out of any email marketing communications from us at any time by following the instructions in those communications, such as an “unsubscribe” link in emails we may send to you.
LINKS
Links
The Site may provide hypertext links to other websites over which we have no control and which may contain privacy provisions that are different from those provided herein. We are not responsible for and expressly disclaim any and all liability for the privacy policies or practices of other websites to which you choose to link from our websites. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.
SECURITY AND RETENTION OF PERSONAL INFORMATION
Security and Retention of Personal Information
We have implemented administrative, technical, and physical security measures intended to protect against the loss, misuse and/or alteration of your information. However (like any organization), we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since, despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
We generally retain personal data for so long as it may be relevant to the purposes above. In determining how long to retain information, we may consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests.
CHILDREN’S PRIVACY
Children’s Privacy
We do not knowingly collect personal information (as defined by the U.S. Children’s Online Privacy Protection Act) from children under 13. If you are under 13, please do not attempt to register for the service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information or take other appropriate action. If you believe that a child under 13 may have provided us with any personal information, please contact us at info@imsdm.com.
PRIVACY RIGHTS YOU MAY HAVE IN SPECIFIC STATES
Privacy Rights You May Have in Specific States
Certain states have passed state-specific privacy laws that grant residents of their states particular privacy rights. These states include California (as to which a separate “Addendum” is provided below), as well as Colorado, Connecticut, Utah, Virginia, and others. If you live in one of these states, you may have certain rights with respect to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Namely, you may have the right to ask that we:
- confirm that we are processing your personal information
- provide access to certain personal information we hold about you, in some cases in a portable format, if technically feasible
- update or correct your personal information
- delete your personal information
- restrict the use of your personal information
- suppress the “sale” or “share” of your personal information, or (similarly) suppress the use of your information for targeted advertising
- provide general information about our processing activities
- withdraw your consent to our use of your personal information for certain processing purposes, where the processing purpose was based on your consent
We do not use your personal information to make decisions that produce legal or similar effects based solely on the automated processing of your information.
We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.
We likewise may grant certain of these rights to any consumers: for instance, any consumer may opt out of our email marketing, or access the interest-based advertising opt-out methods provided by us or provided through industry websites. How to Exercise Your Privacy Rights. To exercise any of these rights, you can call us at 877-745-2661 or email us at info@imsdm.com with your name and type of request you are making. As noted above, certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our Services to you. In addition, for some types of requests, such as your request for a copy of your personal information (or ask to have that information deleted), we will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. If we cannot verify you, we may be unable to respond to your requests.
Authorized Agents. You may designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
Right to Appeal. In certain states, residents have the right to appeal our decision to deny your request, if applicable. If you wish to do this, please send an email at info@imsdm.com with the word “Privacy Appeal” in the subject line.
Opt-Out of Targeted Advertising. You may also opt out of targeted advertising, which we may occasionally engage in, such as to “retarget” with information about our Services when you visit other websites (which in some states may be considered “selling” or “sharing” personal information). Please see the instructions in “Tailored Advertising”, above, to learn about those “opt-out” methods. You can also opt out of these activities by clicking Do Not Sell My Personal Information. We do not knowingly sell the personal information of minors under 16 years of age, or deliberately target minors with advertising.
INTERNATIONAL USERS
International Users
If you live in the European Union, United Kingdom, or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. Your personal information may be transferred for processing and storage by IMS and our affiliates and third parties. By providing your personal data you consent to any transfer and processing in accordance with this Policy.
CONTACT US
Contact Us
If you have questions or comments regarding our privacy practices or this Policy, please contact us immediately at 877-745-2661 or email us at info@imsdm.com.
CALIFORNIA PRIVACY ADDENDUM
California Privacy Addendum: Privacy Notice to California Residents
This section applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements (and, in some cases, repeats) the information in the rest of our Policy above. Data about individuals who are not residents of California is handled differently and is not subject to the same rights described in this Section. This Section also does not apply to data that IMS handles in its capacity as a “service provider” (as defined in the CCPA) for its customers, even when such data is about a resident of California, or to other data or activities that are not subject to the relevant provisions of the CCPA. Personal information that IMS handles as its customer’s “service provider,” if any, is subject to IMS’s contract with the customer, not this Policy.
1. The Personal Information We Collect
Similar to the description in our fuller Policy, the below chart provides a concise summary of the categories of information we collect, our sources of information, and the purposes for use.
| Categories of information | Purpose of use | Categories of other parties to whom we disclose the information for business and operational purposes |
|---|---|---|
| Identifiers such as name, address, and email address, and telephone number; and information about your browser or device such as IP address and device IDs | Provide and operate the Services Personalize your experience Provide seamless experience across platforms and devices Protect our users, Services and properties Send you marketing and advertising Market and advertise for third parties Build and manage business-to-business relationships Compliance and risk management | Affiliates and subsidiaries Vendors and service providers Ad networks and advertising partners Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent |
Commercial information such as information about your transactions with us, for example, products or Services you have purchased | Provide and operate the Services Personalize your experience Provide seamless experience across platforms and devices Protect our users, Services and properties Send you marketing and advertising Market and advertise for third parties Build and manage business-to-business relationships Compliance and risk management | Affiliates and subsidiaries Vendors and service providers Ad networks and advertising partners Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent |
| Financial information such as credit card information stored by our payment processors on our behalf | Provide and operate the Services Personalize your experience Provide seamless experience across platforms and devices Protect our users, Services and properties Compliance and risk management | Service providers for payment processing purposes Entities for legal and security purposes |
| Internet network and device activity data such as information about your device hardware (e.g., device type) and software (e.g., operating system and browser type) and browsing and usage information (e.g., how often you visit our Services, the pages you visit, referring pages, and the version of the Services you’re using) | Provide and operate the Services Personalize your experience Provide seamless experience across platforms and devices Protect our users, Services and properties Send you marketing and advertising Market and advertise for third parties Build and manage business-to-business relationships Compliance and risk management | Affiliates and subsidiaries Vendors and service providers Ad networks and advertising partners Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent |
| Professional or employment-related information such as your employer and job title | Provide and operate the Services Personalize your experience Provide seamless experience across platforms and devices Protect our users, Services and properties Send you marketing and advertising Market and advertise for third parties Build and manage business-to-business relationships Compliance and risk management | Affiliates and subsidiaries Vendors and service providers Ad networks and advertising partners Entities for legal and security purposes Entities for sales or transfer of business or assets Others with your consent |
| Audio or visual information such as when you call customer service | Provide and operate the Services Personalize your experience Provide seamless experience across platforms and devices Protect our users, Services and properties Build and manage business-to-business relationships Compliance and risk management | Affiliates and subsidiaries Vendors and service providers Entities for legal and security purposes Others with your consent |
| Other information any other information you provide to us that directly or indirectly identifies you, such as information you include in emails or other communications to us | Purposes of use will depend on the additional information you provide | Disclosure will depend on the additional information you provide |
1. The Personal Information We Collect
We may use your personal information for any of the following reasons:
- Providing and operating the Services, including the Site;
- Developing new products and Services, including conducting analysis (for instance, analyzing public opinion);
- Communicating with you, including through advertising, promotions and email, which may be through social media platforms;
- Analyzing how people use our Services including the Site, or respond to our marketing and communications;
- Protecting our users, Site, and Properties, and complying with the law;
- For internal auditing and recordkeeping purposes,
- Detecting, investigating, and preventing improper or fraudulent use or our Services or the Site,
- Protecting our rights, and complying with the law;
- Evaluating job applications (as applicable);
- Communicating with you on behalf of a client of ours and/or in response to a survey (as applicable);
- Bug detection and error reporting; and
- Other uses about which we notify you.
We may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify information collected through the Site. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties.
3. Selling and Sharing Personal Information
The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes. We “sell” or “share” the following categories of information to third-party advertising partners and vendors that support our advertising efforts (such as advertising analytics services):
Identifiers (such as name, address, email address); internet or other network or device activity (such as browsing history and usage information).
Identifiers (such as name, address, email address); internet or other network or device activity (such as browsing history and usage information).
If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law, please see “Tailored Advertising”, above. Alternatively, if you have a legally-recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law. Please note that we do not knowingly sell the personal information of minors under 16 years of age.
4. California Residents’ Privacy Rights
f you are a California resident, you have the right to ask that we:
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you.
- Delete certain personal information we have about you.
- Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
You also have a right not to receive “discriminatory treatment” (within the meaning of the CCPA) for the exercise of the privacy rights conferred by the CCPA. How to Exercise Your Privacy Rights. To exercise any of these rights, you can call us at 877-745-2661 or email us at info@imsdm.com with your name and the type of request you are making. Alternatively you can submit a form to Delete your personal Information by clicking Delete Your Information. To Access or Correct your data please click Access or Correct Your Information. Certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our Services to you. In addition, if you ask for a copy of your personal information
(or ask to have that information deleted), we will take reasonable steps to verify your identity before responding to a request, which may include at a minimum verifying your name and email address. If we cannot verify you, we may be unable to respond to your requests. We will not discriminate against you with respect to the use of our Services should you make such a request.
Authorized Agents. You may designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
Opt-Out of Targeted Advertising. You may also opt out of targeted advertising, which we may occasionally engage in, such as to “retarget” with information about our Services when you visit other websites (which in some states may be considered “selling” or “sharing” personal information). To “opt-out” of this type of advertising, you may:
- If you have a legally recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law, or
- Visit the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs.
- Opt out of these activities by clicking Do Not Sell My Personal Information.
Opting out of “sales” and “sharing” limits only some types of disclosures of personal information, and there are exceptions to all of the rights described in this Section.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. However, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.
5. California Shine the Light
We do not share personal information with third parties for their direct marketing purposes, for purposes of California’s “Shine the Light” law, Cal. Civ. Code section 1798.83.
6. Security And Retention of Your Information
We have implemented administrative, technical, and physical security measures intended to protect against the loss, misuse and/or alteration of your information. However (like any organization), we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since, despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
We generally retain personal data for so long as it may be relevant to the purposes above. In determining how long to retain information, we may consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests.
7. Updates to this Policy
We reserve the right to change this Policy from time to time and will notify you of changes as required by law. Your continued use of the Site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by that Policy.
Contact Us
If you have questions or comments regarding our privacy practices or this Policy, please contact us immediately at 877.745-2661 or email us at info@imsdm.com.