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IMPERATIVE GROUP, INC. PRIVACY POLICY
Last updated: October 7 th, 2021

This privacy policy (“Policy”) describes the information that Imperative Group, Inc. (“Imperative,” “we,” “us” or “our”) collect when you access or use our website www.imperative.com, our SaaS applications (app.imperative.com), and related services (collectively our “Services”) and how we use and disclose this information.   This policy does not, however, apply to the information that we process on behalf of our customers or subscribers (including your employer if your employer has executed our Imperative Group, Inc. SaaS Licensing Agreement with us and you are signing up for our Services through or at the request of your employer) (collectively “Subscribers”), such as user profiles, content, messages or other information or data.

Information We Collect
We collect information through the use of our Services as described below.

Information You Provide
To register you for the Services, we require you to provide us with certain information, including your name, e-mail address and your account password. If you communicate with us by, for example, e-mail, telephone, online form, any information voluntarily provided in such communication may be collected. Note, when you make a purchase of our Services, our payment processor directly collects and processes the payment information that you provide, as necessary to complete your purchase.

Invited Users
You may choose to invite colleagues or other individuals to use our Services on behalf of Subscribers. When an authorized user of a Subscriber invites a colleague or other individual, we will receive that individual’s name and email address, and we will send that person an email inviting to register for our Services, to the extent permitted under applicable law.

Account Administrators
In order to successfully utilize our Services, our Subscribers can assign several levels of administrative access to their authorized users that access our Services. You should be aware that certain user roles include heightened privileges with an account on our Services and may be able to access, view, and edit your information, as needed to perform their functions. For example, some authorized users of Subscribers can enter information on behalf of their fellow team members (who may also be authorized users), access, edit, or otherwise change information on an account (“Administrators”). These Administrators can enter information about members of their team, including, but not limited to: first and last name, email address. Note, some users may have the ability to view information about team members without the ability to edit or change the information.

Information We Receive from Third Parties
In order to support your experience using the Service, we may also collect information about you from third party partners and combine it with other information we collect from you.

Automatically Collected Information
We automatically collect information, such as your IP address, when you access our Services. We may also track user activity (e.g., pages visited and projects created) and use cookies and other tracking technologies on our Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. We use IP address to derive your approximate location. We work with analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities, trends, and demographics. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout. For information about how to opt-out of certain use of cookies and other technologies, please see the Your Choices section below.

How We Use Information
We may use the information we collect for various purposes, including:

Providing & Improving Our Services
We use the information we collect to provide, maintain, improve, enhance, personalize, and promote our Services.

Communications
We may communicate with you about products, services and events offered by Imperative and others and provide news and information that we think will interest you. If you do not want to receive promotional emails from us, please indicate your preference by opting-out via the links provided in the emails. Note, that if you opt-out of receiving our promotional emails, you may still receive transactional emails from us.

Legal
We reserve the right to access, use, preserve, transfer, or disclose, at any time without notice to you, any information as reasonably necessary to: (1) comply with any applicable law, regulation, subpoena, or legal process, or respond to any governmental requests or regulatory investigation and to cooperate with law enforcement, if we believe such action is required or permitted by law; (2) enforce our this Policy or our Terms of Service, including investigating any potential violations; (3) protect the safety, integrity, rights, or security of our users, our Services or equipment, or any third party; or (4) detect, prevent, or otherwise address fraud, security, or technical issues related to our Services or those of our business partners.

Data Analysis
We may perform data analysis (including anonymization of personal information).

Business Purposes
We may process personal information in connection with prospective service engagements, partnerships or vendor relationships.

How We Disclose Information
We may disclose the information we collect, including in the following ways:

Service providers
We employ service providers to perform tasks on our behalf when providing the Services. We do not authorize these service providers to use or disclose the data except as necessary to perform tasks on our behalf or comply with legal requirements. If you would like to review a list of the third-party services used to support Imperative, please see our sub processors list.

Analytics
In addition, our third-party analytics vendors may set and access their own cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different websites, to provide us with aggregate information.

Legal/Protection
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Imperative, our employees, our users, or others.

Aggregate Data
We may de-identify and aggregate your information and process and share it in an anonymous and aggregated form for purposes in addition to those described above. For example, we may share aggregate reports about business metrics. Account Administrators & Viewers Please see above section entitled “Information Provided by Account Administrators” for information about how individuals with different access levels may disclose, share, and access information.


Privacy Shield
Imperative complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Imperative has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Imperative commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Imperative at: dataprivacy@imperative.com

Imperative has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

In addition, Imperative would also like to inform individuals about:

  • your organization being subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)
  • the possibility, under certain conditions, for the individual to invoke binding arbitration
  • your organization’s liability in cases of onward transfers to third parties


Your Rights and Choices
You may update your preferences, ask us to remove your information from our mailing lists, delete your account, submit a request to exercise your rights available under applicable law, or express your concern about the use of your information at any time. To do so, please contact us via the email address or phone number provided below in the Contact Us section. Additionally, you may choose not to provide information to us. However, if you do not provide information when requested, you may not be able to benefit from the Services as the information may be necessary to provide you with the Services or we may be legally required to collect it in the context of the Services. Please note that if you cease using the Service or we terminate your access to the Service, you may no longer have the ability to access or update your information.

Tracking
Many web browsers allow you to manage your preferences relating to cookies. You may be able to adjust your browser to manage cookies using your browser’s preferences, however, if you choose to block cookies, doing so may impair the use of our Services.

Transborder Transfer
Imperative is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

Updates to this Policy
From time to time we may, in our discretion, make changes to this Policy. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make material changes, we may notify you through the Services or by sending you an email or other communication. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. Your continued use of our Services after we have updated this Policy constitutes your acceptance of the changes.

Contact Us
If you have questions about this Policy please contact us.

Imperative Group Inc
1201 Second Ave.
Suite 917
Seattle, WA 98101
United States
dataprivacy@imperative.com