CCPA Privacy Notice
Updated: December 2020
Imperative is complying with the CCPA and considering its underlying principles in how we think about customer trust and data privacy as a core pillar of our business. We are providing this CCPA-specific privacy notice to supplement the information and disclosures already contained in our Privacy Policy. This notice applies to individuals residing in California from whom we collect Personal Information.
The TLDR for California residents is:
We do not sell your Personal Information.
The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in our Privacy Policy.
| Category | We Collect | We Disclose | We Sell |
| A. Identifiers Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | Yes | No | No |
| B. Categories of Personal Information in Cal. Civ. Code1798.80(e) Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Yes | No | No |
| C. Characteristics of Protected Classifications under California or Federal Law Examples: Race or color, ancestry or national origin, religion or creed, age (over40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status. | No | No | No |
| D. Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No | No | No |
| E. Biometric Information Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | No | No | No |
| F. Internet or Other Electronic Network Activity Information Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement. | Yes | No | No |
| G. Geolocation Data Examples: Precise physical location. | No | No | No |
| H. Sensory Information Examples: Precise physical location. | No | No | No |
| I. Professional or employment-related information Examples: Job application or resume information, past and current job history, and job performance information | No | No | No |
| J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution. | No | No | No |
| K. Inferences Drawn from Personal Information Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes | No | No |
Use of Personal Information
The CCPA defines various business and commercial purposes for collecting, using, and disclosing Personal Information. While we collect, use, and disclose Personal Information pursuant to our Privacy Policy as a whole, we wanted to clarify out that this includes Personal Information in accordance with the specific CCPA business and commercial purposes below:
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services
- Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
- For other purposes for which we provide specific notice at the time the information is collected.
Collection and Disclosure of Personal Information
In the preceding twelve months since this notice was last updated, we have collected Personal Information from general sources including you, your use of our services, your devices, our affiliates, our vendors, and our service providers. More specific information about Personal Information we collect is laid out in this notice and in our Privacy Policy, which we update from time to time.
Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. We do not rent, sell, or share your Personal Information with non affiliated companies for their direct marketing purposes, unless we have your permission.
Submit Requests. To exercise your rights under the CCPA, you can deactivate and purge your account in your Imperative settings. For other requests or to authorize an agent to make a request on your behalf, you can also reach out to us at dataprivacy@imperative.com.
Contact Information
If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights, please email us at dataprivacy@imperative.com or write to us at:
Imperative Group Inc
1201 Second Ave.
Suite 917
Seattle, WA 98101, United States