Effective: September 12, 2023
If you are a California resident, as defined in the California Code of Regulations, you have rights under the California Consumer Privacy Act of 2018, effective as of January 1, 2020, as amended by the California Privacy Rights Act of 2020, effective January 1, 2023 (collectively “CPRA”) and applies solely to residents of the State of California. A description of your rights about your personal information is provided below.
Right to know about the personal information we collect, share, and restrict its sale
The CPRA gives you the right to request that we disclose the specific pieces of personal information we have collected about you, share, and restrict the sale of your personal information. Imply does not sell your personal information as defined by the CPRA and its implementing regulations. However, we may disclose certain personal information for a business purpose.
Right to opt out of “sharing” certain Personal Information
You have a right to opt out from future “sales” or “sharing” of personal information. CPRA requires us to describe the categories of personal information we share with third parties and how to opt out of future sales or sharing. The CPRA defines personal information to include internet or other electronic network activity information which includes identifiers, such as IP addresses, cookies IDs, pixels, and mobile IDs. The law also defines a “sale” or “share” broadly to include simply making data available to third parties in some cases.
Disclosures Of Your Personal Information
Categories of information we collect and disclose for a business purpose
We collect the following categories of personal information from you in connection with the Services, as defined in the CPRA. In addition, during the past twelve months, we have disclosed these categories of personal information for a business purpose:
| Categories of Personal Information We Collect | Categories of Third Parties with Whom we Share Information |
| Identifiers and Contact Information (e.g., name, address, email address, etc.) | Affiliates, vendors, services providers, and third-party business partners |
| Any categories of personal information described in subdivision (e) of Section 1798.80 (e.g., address, telephone number, financial information, etc.) | Vendors, service providers, and third party business partners |
| Legally Protected Classifications (e.g., gender, marital status, etc.) | Vendors and service providers |
| Commercial Information and Transactional Information (e.g., transaction data, etc.) | Vendors, service providers, and third-party business partners |
| Internet or Other Network or Device Activity (e.g., browsing history, app usage, etc.) | Vendors and service providers |
| Approximate Location Information (e.g., location inferred from your IP address, city, country, etc.) | Vendors and service providers |
| Professional or Employment-Related Data or Other Demographic Data (e.g., the name of your employer) | Vendors, service providers, and third-party business partners |
| Educational Information (e.g., degrees and certifications) | Vendors and service providers |
| Inferences drawn from any of the information identified above | N/A |
| Biometric Information | N/A |
| Sensitive Personal Information (e.g., Personal identification numbers, including social security, exact geolocation, racial origin, religious beliefs, or union membership) | N/A |
For a description of all of our data collection, use and disclosure practices, please read our Privacy Policy at https://imply.io/privacy/ in its entirety.
According to California law, personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
Other disclosures about your personal information
Our privacy policy covers additional disclosures about your personal information that the CPRA requires we provide to you. Our privacy policy includes more information about the sources from which we collect your personal information, the business or commercial purposes for which we collect your personal information, and the categories of third parties with whom we share your personal information. For a description of all of our data collection, use and disclosure practices, please read this privacy policy in its entirety.
Categories of Personal Information Disclosed for a Business Purpose in the Preceding 12 Months:
- Identifiers and Contact Information
- Any categories of personal information described in subdivision (e) of Section 1798.80
- Legally Protected Classifications
- Commercial Information and Transactional Information
- Internet or Other Network or Device Activity
- Approximate Location Information
- Professional or Employment-Related Data or Other Demographic Data
- Educational Information
For a description of all of our data collection, use and disclosure practices, please read our Privacy Policy at https://imply.io/privacy/ in its entirety.
Sensitive Personal Information.
Imply does not collect, use, or disclose sensitive personal information.
California Privacy Rights
California consumers have certain rights with respect to their personal information. These rights include the following:
1. Right to opt out of “sharing” certain Personal Information
You have a right to opt out from future “sharing” of personal information. CPRA requires us to describe the categories of personal information we share with third parties and how to opt out of future sales or sharing. The CPRA defines personal information to include internet or other electronic network activity information which includes identifiers, such as IP addresses, cookies IDs, pixels, and mobile IDs. The law also defines a “share” broadly to include simply making data available to third parties in some cases.
Use the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.
2. Right to Know or Request Categories of Personal Information
You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information such as a list of the categories of personal information collected about you, and other related information such as the source of the information, categories of information shared or sold to third parties, and the purpose for such sharing.
3. Right to Correct.
You have a right to request correction of inaccurate personal information.
4. Right to Request Deletion.
You also have a right to request that we delete personal information under certain circumstances, subject to certain exceptions. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information, unless an exception applies.
5. Right to Designate an Authorized Agent.
You may designate an authorized agent to exercise some of your rights; however, in order to help protect the security of your personal information, the authorized agent must follow the same authentication procedures that are required if you exercise your rights without using an agent. Imply will verify requests made through authorized agents to help ensure the safety of your account and to comply with our policies and procedures.
6. Right against Discrimination.
You have a right to not be discriminated against for exercising your rights set out in the CPRA.
7. Right to Notice.
You have a right to receive notice of our practices at or before collection of personal information.
How to make a request
You have the right to exercise the rights listed above and in our Privacy Policy free of charge or penalty, but we may limit the number of requests you make or charge reasonable fees as legally permitted. Do note you will be asked to verify your identity which may include providing us with additional personal information. Upon verifying your identity, we will make the disclosure within 45 days of receiving your request, unless we request an extension. In the event that we reasonably need a 45-day extension, we will notify you of the extension within the initial 45-day period. You may request these disclosures by emailing us at privacy@imply.io. In some cases, your requests may not be fulfilled if they are not consistent with our obligation to comply with applicable legal or operational requirements, for example, if your personal information is necessary for the performance of a contract between you and Imply. Imply will not discriminate nor retaliate against a party who makes a request under the CPRA.
How to contact us
If you have questions about your rights or our disclosures under the CPRA, you may reach us at privacy@imply.io.
Changes to This Information
We reserve the right to modify this information at any time. Please review it occasionally. If we make changes to this information, the updated page will be posted on the privacy policy webpage in a timely manner.
OTHER IMPORTANT PRIVACY INFORMATION
Notice to End Users
Our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different from this policy.
Administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations
In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g., your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.
If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.
Please contact your organization or refer to your administrator’s organizational policies for more information.
OUR POLICY TOWARDS CHILDREN
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at privacy@imply.io.
CHANGES TO OUR PRIVACY POLICY
We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this privacy policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.
If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.
CONTACT US
For information controlled by Imply, if you have questions or concerns about how your information is handled, please direct your inquiry to:
Imply Data, Inc.
Attn: Privacy
1633 Old Bayshore Highway, Suite 232
Burlingame, CA 94010
privacy@imply.io