OUR PRIVACY POLICY
Last updated: November 27, 2018

We at Imperative Group Inc. (Imperative) value your privacy. This privacy policy (Policy) describes the information we 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, disclose, and protect this information. It also tells you about rights and choices you may have with respect to your information, and how you can reach us to update your information or get answers to questions you may have about our privacy practices. Your access and use of our Services indicates your consent to the terms of this Policy and our Terms of Service.

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. If you do, we will receive that individual’s name, email address, and send that person an email invitation them to register for our Services, to the extent permitted under applicable law. Inviting a colleague will require them to also accept this Policy and our Terms of Service.

Account Administrators

In order to successfully utilize our Services, our subscribers can assign several levels of administrative access to their personnel that use 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 users can enter information on behalf of their fellow team members (who may also be users of our Services), access, edit, or otherwise change information on an account (Administrators). These Account 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 (Certified Purpose Leaders).

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 when you access our Services such as IP address. 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 text files that web servers place on your device; they are designed to store basic information and to help websites and applications recognize a browser. Cookies help us track and target the interests of our users to enhance their experience with our Services. 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

When you register for our Services, we use the information you provide to create and maintain your account. The information we collect also helps us improve, enhance, personalize, and promote our Services.

Communications

We will communicate with you if you’ve provided us the means to do so. For example, if you’ve provided your phone number, we may call you to discuss our Services, to the extent permitted under applicable law. If you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services, to the extent permitted under applicable law. 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 Analyses

We may also perform data analyses (including anonymization of personal information).

Business Purposes

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

Data Controller

We process personal information in such a way that it produces insights on how your Purpose Assessment can be used to derive meaning from your work.

How We Disclose Information

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

Affiliates & Partners

We may share your information with any members of our group, which includes our affiliates, subsidiaries, and branch offices, to which it is reasonably necessary or desirable for us to disclose your information in order to carry out the above-mentioned information processing purposes.

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.

Business Transfers

We may choose to buy or sell assets and may share and/or transfer your information in connection with the evaluation of and entry into such transactions. Also, if our company (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your information could be one of the assets transferred to or acquired by a third party.

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 this Policy or 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 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.

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 in accordance with your Customer Agreement, 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.

Non-US Residents Choices

Under certain jurisdictions outside the US, we may obtain your opt-in consent at the time of collection for the processing of certain information for direct marketing purposes or to use cookies and similar tracking technologies. If we rely on consent for the processing of your information, you may have the right to withdraw your consent at any time and, when you do so, this will not affect the lawfulness of the processing before your consent withdrawal. Under certain jurisdictions, you may have the right to request access to and receive information about the information we maintain about you, to update and correct inaccuracies in your information, to restrict or to object to the processing of your information, have the information deleted, or to exercise your right to data portability, as appropriate. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you have the right to lodge a complaint with a competent supervisory authority subject to applicable law. The rights of access, correction, amendment and deletion are, in particular, provided under the Privacy Shield Frameworks. For more information, please see our EU-U.S. Privacy Shield Policy.

Notice to California Residents

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of certain information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at dataprivacy@imperative.com. California residents are entitled to ask us for a notice identifying the categories of information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to dataprivacy@imperative.com.

Transborder Transfer

We may transfer or disclose personal information to recipients in countries outside of your country, including the United States, where we are headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your personal information to other countries, we will protect that information as described in this Privacy Notice. We have certified to the EU-U.S. and Swiss-U.S. Privacy Shield Framework to provide adequate safeguards for the transfer of personal information to the United States from the European Economic Area (“EEA”) and Switzerland. For more information, please see our EU-U.S. Privacy Shield Policy.

Security

We are committed to protecting your information. We seek to use reasonable organizational, technical, and administrative measures to protect information within our organization. We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it or when you request their deletion. In particular for EEA residents, we delete your data after 6 months of inactivity in your trial or upon closing your paid account. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having used our Services. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact Us section below.

Children

Our Services are not directed to children under the age of 16. We do not knowingly collect personal information from children under 16.

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
600 First Ave
Suite 635
Seattle, WA 98104
dataprivacy@imperative.com

Imperative Privacy Shield Policy

Last Updated: November 27, 2018

Imperative Group Inc has subscribed to and will comply with the EU-U.S. and Swiss-U.S. Privacy Shield (the “Frameworks”) as set forth by the U.S. Department of Commerce regarding the processing of Personal Information (as defined below) that is transferred from the European Economic Area (“EEA”) and Switzerland to the United States, respectively. Imperative has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (the “Principles”). Imperative created this Privacy Shield Policy to help you learn about how we handle Personal Information that is collected in the EEA and transferred to Imperative. in the U.S.

If there is any conflict between this Policy and the Principles, the Principles will govern. To learn more about the Frameworks please visit www.privacyshield.gov. You can view our certification at www.privacyshield.gov/list

This Privacy Shield Policy supplements our Privacy Policy above. Capitalized terms used in this Privacy Shield Policy have the meaning given to them by our Privacy Policy, unless specifically defined in this Policy. This Privacy Shield Policy applies to Imperative, which is subject to the investigatory and enforcement powers of the Federal Trade Commission.

How we Obtain Personal Information

We obtain and process Personal Information in different capacities.
As a data controller, we collect and process EEA Personal Information directly from individuals, either via our publicly available websites, including www.imperative.com, app.imperative.com or in connection with our customer, partner, and vendor relationships.

As a data processor, we process and host EEA Personal Information obtained from our customers when providing our services to our enterprise customers. In that context, we only process Personal Information on behalf and on the instructions of our customers, which are data controllers.

We commit to subject to the Principles all Personal Information received from the EEA in reliance on the Frameworks (which includes both types of activities).

Personal Information Received from the European Economic Area and Switzerland

We may receive from the EEA and Switzerland some or all of the information listed in our Privacy Policy. Some of that information may qualify as “personal information” or “personal data” (collectively, “Personal Information”) as defined in the Frameworks. When we process Personal Information on behalf of our enterprise customers, they determine the categories of data they upload in our systems and the purposes of the processing. Accordingly, customers are responsible for providing notice to individuals.

Data Integrity and Purpose Limitation

We may use the Personal Information we receive from the EEA and Switzerland for the purposes set forth in our Privacy Policy or as you may otherwise be notified. We take reasonable steps to ensure that the Personal Information we process is relevant and reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. We will adhere to the Principles for as long as we retain the Personal Information collected under the Frameworks. When we process Personal Information on behalf of our enterprise customers, we process and retain Personal Information as necessary to provide our services to our customers, or as required or permitted under applicable law.

Onward Transfers

Our Privacy Policy describes the types of third parties that we may disclose your Personal information to, and the purposes of such disclosures. If we disclose your Personal Information to a third party acting as a data controller or as an agent, we will comply with, and protect the Personal Information as provided in, the Accountability for Onward Transfer Principle. We remain responsible for the processing of Personal Information received under the Frameworks and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage. We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Choice

You may choose to change your Personal Information or cancel an account by contacting us using the contact details below. You can also unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the e-mail message. If we intend to use your Personal Information for a purpose that is materially different from the purposes listed in this policy or our Privacy Policy, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.

Recourse and Enforcement

We commit to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland.
If you have any questions or concerns, please write to us at the address listed below. If you are an EEA resident, we will investigate and attempt to resolve reasonable complaints and disputes regarding our use and disclosure of Personal Information in accordance with the Principles. If an issue cannot be resolved via our internal dispute resolution mechanism, EEA individuals may contact or submit a complaint, at no cost, to the EU Data Protection Authorities (DPAs). For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration before the Privacy Shield Panel as detailed in the Principles.

Contact Us
If you have questions, concerns, or complaints about this Privacy Shield Policy or our privacy practices, please contact us.

Imperative Group Inc
600 First Ave
Suite 635
Seattle, WA 98104
United States
dataprivacy@imperative.com