This privacy policy (this "Privacy Policy") governs how NetImpact Strategies, Inc.
("NetImpact" "we", "our", or
"us") collects, uses, and treats Personal Information (as defined
below) that you provide to us: (i) through our website at https://netimpactstrategies.com (our
"Website"); or (ii) while using the services and information available via our
Website or in other
instances in which we notify you that this Privacy Policy apply (collectively, the
"Services") (the
Services, together with our Website, our "Platform"). This Privacy Policy
establishes our rights and
obligations with respect to your personal information, and lets you know your associated rights.
- Scope of this Privacy Policy.
- Application of this Privacy Policy. Our Privacy Policy applies to
anyone that uses or
visits our Platform (collectively, "you"), subject to Section 1.2
(Exclusions from this
Privacy Policy), including the following:
- Our existing clients, prospective clients, and their agents or other authorized
representatives (collectively, "Clients");
- Our contractors, vendors, and other service providers (collectively,
"Service
Providers"); and
- Our visitors of our Website (collectively, "Site Visitors").
-
Exclusions from this Privacy Policy. This Privacy Policy does not apply
to: (i) our
application(s) and other offerings, the use of which is governed under separate terms
and conditions, including, for example, end user license agreements (EULAs); or (ii) our
current employees providing us information with respect to their employment with us.
Moreover, if we provide you with links to other websites, then they are solely for your
convenience and reference and we are not responsible for the privacy practices or
content on, or accessed through, such links or websites.
- Your Consent to this Privacy Policy. You indicate your consent to this Privacy
Policy in
different ways, depending on your relationship with us, as set forth below.
- Your Consent If You are a Site Visitor. By accessing and using our
Website as a Site
Visitor, you are acknowledging that you have read and understood this Privacy Policy,
and agree to be legally bound by it. If you do not agree with the terms of this Privacy
Policy, please refrain from accessing or using our Website. In addition, for certain
Services or components of our Website, we may further confirm your consent by asking you
to click an "I accept" or a similar button.
- Your Consent If You are Not a Site Visitor. Except as provided in
Section 2.3 (Consent
by User Acting in a Representative Capacity), your consent to, and your affirmative
agreement that you have read and agree to, this Privacy Policy shall be by providing us
information in connection with our business. By providing us information, including
Personal Information, in connection with the Platform you are affirmatively agreeing
that you have read and agree to this Privacy Policy, and to be legally bound by it.
- Consent by User Acting in a Representative Capacity. If you are
agreeing to our Privacy
Policy on behalf of a company or other legal entity ("Your Organization"), then (i) you
represent and warrant that you have authority to act on behalf of, and to bind Your
Organization, and (ii) for all purposes in this Privacy Policy, the term "you" means
Your Organization on whose behalf you are acting.
- Right to Withdraw Consent. You have the right to withdraw your consent
at any time, in
accordance with Section 11 (Your Choices Regarding Your Personal Information; Opting
Out).
- The Information We Collect. The information that we collect about you falls
into certain
categories as further described in this Section 3 (The Information We Collect). This information
consists of the following:
- Personal Information. We may collect certain information that
identifies you as an
individual (collectively, "Personal Information"). The Personal
Information we collect
may include the following:
- Your name and email address;
- Your other contact information, including a mailing address and phone number;
- Information you may submit to us in connection with your job application; and
- Geolocation information.
- Online Activity Information. We may also collect technical and
device-related
information through our Platform (collectively, "Online Activity
Information"). Online
Activity Information is typically collected automatically by technical means and,
subject to Section 3.4 (Treatment of Combined Information), for purposes of our
Platform, may consist of the following:
- Device identifiers, such as cookies;
- Device information, such as hardware and software settings;
- IP addresses and log information, such as your device's name, the type and
version of your web browser, and referrer addresses that can function to
identify a user device; and
- Tracking information that we, or a third party, may collect.
To the extent that statutes, regulations, and any other laws that apply to the
Services
(collectively, "Applicable Law") establish that Online Activity
Information
constitutes Personal
Information, and such Applicable Law applies to information we collect from you,
then we will
treat the relevant Online Activity Information as Personal Information. In addition,
sometimes Online Activity Information can be associated with your Personal
Information, in
which case we will treat it as Personal Information (as described in Section 3.4
(Treatment of
Combined Information)). Otherwise we consider, and treat, Online Activity
Information as
Anonymous Information.
- Anonymous Information. Our Website also collects, processes, and/or
uses information
that does not identify you or your devices, including Personal Information that has been
made
anonymous by: (i) removing identifying fields and aggregating the information with other
information so that individual subjects of the information cannot be re-identified, or
(ii) anonymizing
the information with techniques that remove or modify the identifying data so as to
prevent
re-identification of the anonymized information (collectively, "Anonymous
Information").
Information that meets these criteria might include, for example, demographic
information, statistical information (e.g., page views and hit counts), and general
tracking
information. We use Anonymous Information for our business operations. Because Anonymous
Information
does not include Personal Information, Anonymous Information is outside the scope of
this Privacy
Policy.
- Treatment of Combined Information. To enable us to better understand
the characteristics
of our users and/or to conduct the business, we may link your Personal Information with
Online Activity Information associated with you or other Anonymous Information. If we
combine or associate Online Activity Information or other Anonymous Information with
your Personal Information, then we will treat the resulting combination as Personal
Information.
- How We Collect this Information. We collect the above information through the
following means
and technologies:
- Contacting Us. You can contact us with questions or comments. In order
to communicate
with us, you must provide certain Personal Information. By communicating with us for
these purposes, you may provide us with your name, email address, and other Personal
Information. In these instances, we use any information you provide to us for the
purposes for which you submit the information.
- Questionnaires and Surveys. We may allow you to participate in surveys
and
questionnaires, which we may post on the Website or otherwise provide to you from time
to time. You are free to choose whether to participate in a survey or questionnaire. We
may ask that, in addition to providing your responses, you also provide Personal
Information. In these instances, we use any information that you provide to us for the
purposes for which you submit the information. Survey and questionnaire information may
be used for the purposes of monitoring or improving our business. As further set out in
Section 11 (Your Choices Regarding Your Personal Information; Opting Out), please
understand that you will not be allowed to "opt out" of formal notices related to our
business, such as those concerning the operation of the Website, legal notices, and
other related notices concerning your relationship with us.
- Job Applications and Inquiries. You may submit to us Personal
Information in connection
with job applications and if you have questions for us. In each case, we collect the
information you submit to us for various purposes, including to respond to your
inquiries or to consider your candidacy for our employment opportunities.
- Newsletters. We may offer newsletters and other content that we believe
may be of
interest to you. We will use your Personal Information to provide you with this content.
You can opt-out of receiving this content by following the instructions set out in
Section 11 (Your Choices Regarding Your Personal Information; Opting Out).
- Submitted Content. As further set out below, we may provide you with
the ability to
submit content to us for our internal use or to submit content to us for public
consumption (collectively, "Submitted Content"). If you include any
Personal Information
relating to others in your Submitted Content, then you represent that you have full
permission and authority to do so.
- Submitted Content Provided to Us for Internal Use. We may
provide you with the
ability to submit Submitted Content to us (either directly or through a third
party service), and we may also provide content to you, in order
for us to better provide Services. For example, we may allow you to provide us
with feedback related to the business. If you provide us with such Submitted
Content, we will protect it in accordance with this Privacy Policy.
- Submitted Content Provided to Us for Public Consumption. We may
give you the
ability through our Website or a third party social media platform, to engage
with us and others in public exchanges by providing Submitted Content. For
example, we believe that your experiences with us can often act as the strongest
promotion for our Services. To promote and illustrate our Services, we may wish
to incorporate in our success stories or otherwise post on our Website or
elsewhere, your endorsements or your other descriptions of experiences with us,
as well as comments, feedback, and other information that you wish to share.
Please understand that, if you include Personal Information in such Submitted
Content, others will be able to read, collect, re-publish, and otherwise freely
use such Personal Information. We are not responsible for Personal Information
that you decide to include in such Submitted Content, and we will not take down,
remove, or edit Submitted Content, except as required by applicable law.
- Cookies. A cookie is a small amount of data that is sent to your
browser from a
website's computers and stored on your computer's hard drive. Cookies can be used to
provide you with a tailored user experience and to make it easier for you to use a
website upon a future visit. We may include cookies on our Website and use them to
recognize you when you return to our Website. You may choose not to accept cookies;
however, you may need to enable cookies if you wish to access certain personalized
features of our Website.
- IP Addresses; Logs. We may automatically receive and record information
in our server
logs from your browser or mobile device, including your IP address (the Internet address
of your computer), your computer's name, the type and version of your web browser or
mobile device operating system, referrer addresses, and other generally-accepted log
information. We may also record page views and other general statistical and tracking
information, which will be aggregated with that of other users in order to understand
how our Website is being used, and for security and monitoring purposes.
- Tags. We may use so-called "pixel tags" - small graphic images (also
known as "web
beacons" or "single-pixel gifs") - to tell us what parts of our Website have been
visited or to measure the effectiveness of searches you perform on our Website. Pixel
tags also enable us to send email messages in a format that you can read and they inform
us whether emails have been opened. Pixel tags also help us ensure that our messages are
of interest to you.
- Click-Throughs. We may send email messages, which use a "click-through
URL" linked to
content related to our business. When you click one of these URLs, you pass through our
web server before arriving at the destination web page. We may track this click-through
data to help determine interest in particular topics and to measure the effectiveness of
our customer communications.
- Configuration. In order to determine whether your computer or other
device is supported
by our system, we may collect certain Anonymous Information. This information includes,
but may not be limited to, your operating system and browser, the presence of any
software that our Website may require to operate with your computer or other device, or
other third party software on your computer or mobile device.
- Other Uses. In addition to the uses specifically identified in this
Section 4 (How We
Collect this Information), there may be instances where you request information or other
Services from us that are not described in this Privacy Policy. In that instance, we
will use Personal Information that you submit in order to provide such information or
Services to you.
- Information Provided to Third Parties. As explained further in Section
7.1 (Our Service
Providers), we may engage third parties to perform certain services for us or on our
behalf. The forms on our Website may be managed by such third parties, and we may obtain
from the applicable service provider the information that you provide using such forms.
- Provision of Personal Information Offline. We may ask you to provide us
with Personal
Information via offline interactions. Personal Information we collect in this manner may
include, for example, your name, username, email address, and other identifying
information. If you provide information to us at our request, then we will strive to
provide you with either verbal and/or written notice of this Privacy Policy upon your
request for a copy of the Privacy Policy. We treat any information that you provide to
us as Personal Information under this Privacy Policy.
- How We Use The Information We Collect. We use the information that we collect
or process,
including Personal Information, Online Activity Information, and Anonymous Information, as
permitted under applicable law and consistent with the terms of this Privacy Policy. More
specifically, we use the information we collect for the following purposes:
- To provide you with the Services you request and to communicate with you regarding our
Services;
- To use, and to allow you to provide us with, Submitted Content for purposes set out in
Section 4.5 (Submitted Content);
- To respond to your inquiries;
- To customize and enhance your use of our Platform, such as by personalizing your
experience with us;
- To provide communications that might interest you, including marketing messages and to
inform you of services that we think would be appealing to you, whether the services are
provided by us or by others, and whether the services are available via NetImpact or a
third party;
- To perform analytics, quality control, market research, and to determine the
effectiveness of our Services and promotional campaigns, to improve our Platform, and to
develop new services;
- To perform internal administration, auditing, operation, and troubleshooting; and
- To share the information to third parties as permitted in this Privacy Policy
In addition to the uses specifically identified above, there may be instances where you
request information and Services from us that are not described in this Privacy Policy. In
our discretion, we can use information that you submit in order to provide such information
and Services.
- Other Essential or Internal Uses of Information. We may also use the
information that we collect
as we believe to be necessary or appropriate for certain essential purposes, including:
- To comply with applicable law and legal process;
- To respond to requests from public and government authorities;
- To detect, prevent, or investigate potential security incidents or fraud;
- To facilitate the functionality of our Platform;
- To enforce our terms and conditions;
- To protect our operations or those of our affiliates;
- To protect our rights, privacy, safety or property, security and/or that of our
affiliates, you or others; and
- To allow us to pursue available remedies or limit the damages that we may sustain.
- How We Disclose this Information. We value your privacy, and we share the
information we collect
only in the manner set out below.
- Our Service Providers. We engage third parties to perform functions on
our behalf, and
these may include maintaining the Platform, collecting information, responding to and
sending email or other messages, and other functions useful to our business. In this
capacity, we may provide service providers with Personal Information, Online Activity
Information, and Anonymous Information (as applicable). The following are examples:
- Our Platform may include links to third party websites, such as those offering
services that augment those Services offered on our Platform, and plug-ins that
integrate with third party resources, such as CMS applications and associated
tools.
- We may use service providers to: (i) provide customer service (where
applicable); (ii) process and distribute email and newsletters; (iii) manage
marketing and similar activities; (iv) provide you with access to various forms
and platforms on which to perform activities, including registering for webinars
and other events that we may provide or make available; and (v) assist in
organizing and hosting events and programs. These service providers generally
require access to your Personal Information in order to perform these services.
- We may use analytics service providers to assist us in understanding and using
Online Activity Information and other information that we collect via the
Platform.
- We may use service providers to anonymize and aggregate Personal Information in
order to generate Anonymous Information.
We require our service providers to contractually commit to protect the privacy and
security of the Personal Information they process on our behalf.
- Questions of Harm; Legal Process. We may disclose your Personal
Information and Online
Activity Information to third parties, including law enforcement agencies, attorneys,
and private investigators, where it is necessary, or where we have a good faith belief
that it is necessary to: (i) comply with legal process; (ii) protect and defend our
rights and property, including the Platform and associated content; (iii) protect
against misuse or unauthorized use of our Platform and associated content; (iv) protect
the personal safety or property of Platform users or the public, including your personal
safety or property (it being understood that we assume no duty to provide, or monitor
the need for, such protections); and (v) cooperate with public and government
authorities including, where required, authorities outside
your jurisdiction.
While you are not able to opt out of this use of information, we will take reasonable
steps to limit such use, and disclose only the information we reasonably believe is
necessary for the above purposes. If we receive legal process calling for the disclosure
of your Personal Information, then we will attempt to notify you within a reasonable
amount of time, unless such notification is not permitted.
- Corporate Transactions. We shall be entitled to transfer information
that we collect
(including Personal Information) to a third party in connection with or in contemplation
of a reorganization, merger, sale, joint venture, assignment, transfer, or other
disposition (including a disposition in connection with a bankruptcy or similar
proceedings) of all or substantially all assets or stock of the business unit or
division responsible for the information under this Privacy Policy; provided the
acquiring third party has agreed to safeguard your Personal Information with protections
that are compatible with those set out in this Privacy Policy.
- Our Affiliates. We may choose to rely on and share the information we
collect with our
affiliates. By "affiliate" we mean an entity that is closely related to us, such as an
entity that controls, is controlled by, or is under common control with, NetImpact. Our
affiliates will be bound by the terms of this Privacy Policy
- How We Safeguard the Information We Collect. We recognize the sensitivity of
our users' Personal
Information and we have put in place security systems designed to prevent unauthorized access to
or disclosure of this information. Our security systems include physical, technical, and
administrative information security controls, and we take commercially reasonable steps to
secure and safeguard such Personal Information in accordance with applicable law.
- Our Retention of Data. We retain Personal Information for the period of time
necessary to
fulfill the purposes for which we obtained the Personal Information and consistent with
applicable law. We use the following criteria to set our retention periods: (i) the duration of
our relationship with you; (ii) the existence of a legal obligation as to the retention period;
and (iii) the advisability of retaining the information in light of our legal position (for
example, in light of applicable statutes of limitations, litigation, or regulatory
investigations).
- Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the
accuracy of the
Personal Information we process, and (ii) to limit the Personal Information that we process to
that which is reasonably necessary for the purposes for which we obtained the information.
- Your Choices Regarding Your Personal Information; Opting Out.
- Discretionary Account Information. To allow appropriate control over
Personal
Information, you can view, change, or update discretionary information that you have
previously submitted either by contacting us as provided in Section 16 (Contact Us)
below.
- Opt-Out of Marketing Communications. If we choose to send to you, or
you have elected to
receive, bulletins, updates, or other marketing-related materials, we will provide you
with the ability to decline - or "opt out" - of receiving such communications.
Instructions for opting-out will be provided if and when we determine to send you such a
communication. For example, if you no longer wish to receive email messages from us, you
can opt out of this Service by either: (i) following the "unsubscribe" instructions
located near the bottom of each email message, or (ii) contacting us as provided in
Section 16 (Contact Us) below. Please understand that we may still communicate with you
in connection with administrative notices concerning any transactions, operation of the
Platform and legal notices.
- State-Specific Notices Regarding Your Privacy Rights.
- California Shine the Light Disclosure. California law requires
certain
businesses to respond to requests from California users who ask about business
practices related to disclosing Personal Information to third parties for their
own direct marketing purposes. The California "Shine the Light" law further
requires us to allow California residents to opt out of certain disclosures of
Personal Information to third parties for their own direct marketing purposes.
- California Do No Track Notice. Our Website does not change its
behavior when
receiving "Do Not Track" signals from browser software, and handles all Personal
Information consistent with this Privacy Policy.
- Nevada Disclosure. For Nevada residents, please note that we do
not sell
personal information as defined by Nevada law. You can submit a request to us as
set out in Section 16 (Contact Us) below.
- Advisory Regarding Participation by Children and Teens. Under U.S. Federal Law
(as reflected in
the Children's Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONAL
INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further
information concerning privacy policies in general, and concerning online social networking and
safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.
- Third Party Sites. Our Platform may link to (or be linked from) third party
websites or third
party features ("Linked Sites"). We have no control over third parties that operate such Linked
Site, and we are not responsible for the content, availability, or security of such Linked
Sites. Third parties may use your information for their own purposes, including for behavioral
or advertising purposes. The inclusion of a link on our Platform to a Linked Site is provided
for your convenience only and does not imply endorsement of the Linked Site, the third party, or
its products or services. If you decide to access any of the Linked Sites, you do so subject to
the terms and conditions of use for such Linked Sites. Any Personal Information that you provide
through a Linked Site will be subject to the privacy policy of its operator and not this Privacy
Policy.
- Complaints. If you have a suggestions on how we can improve our Services or
complaints you would
like us to address, please contact us at the address set out in Section 16 (Contact Us). If you
are a California resident, you may report complaints to the Complaint Assistance Unit of the
Division of Consumer Services of the California Department of Consumer Affairs. Other states may
provide similar avenues for lodging complaints. Please check with your state's consumer
protection authority.
- Changes to this Privacy Policy. From time to time, we may change this Privacy
Policy for our
business purposes and to comply with changes in applicable law. In the event of any substantive
or material changes, we will communicate these changes to you by posting the updated Privacy
Policy on the Website and/or notifying you of the change via the Website, email, or other
methods. Your continued use following such notice constitutes your agreement to follow and be
bound by the updated Privacy Policy. If you do not agree with any changes to our Privacy Policy,
please contact us using the information set forth in Section 16 (Contact Us).
- Contact Us. If you would like to contact us, please email us at pr@netimpactstrategies.com.
- Effective Date. The effective date of this Privacy Policy is May 3rd, 2022.
- Copyright and Legal Notice. © 2022 NetImpact Strategies, Inc. All rights
reserved. No part of
this content may be reproduced, stored in any form without written permission from NetImpact
Strategies, Inc.
