Privacy Policy
This Privacy Policy (“Policy”) describes the manner in which IMakeNews, Inc. (“IMN”) handles personal information collected from individuals (“you” or “users”) by IMN through IMN websites or in connection with IMN’s delivery of services to its customers. In this Policy, the term “personal information” refers to information relating to an identified or identifiable natural person.
This Policy applies to IMN websites that directly link to this Policy when you click “Privacy Policy” in the website footer. Please refer to the privacy policies of any linked third party website to learn how the operators of those websites collect and use information that is gathered through those websites.
Safe Harbor Compliance
IMN has certified its compliance with the standards of the Safe Harbor Principles developed by the U.S. Department of Commerce for the regulation of data transfers between the European Union and the United States. This Policy and IMN’s information handling practices described in this Policy comply with the Safe Harbor privacy Principles.
Information Categories
IMN collects and uses personal information both on its own behalf and in connection with its delivery of services to its customers. This Policy is divided into separate sections to distinguish these different categories of information.
INFORMATION COLLECTED OR USED BY IMN ON ITS OWN BEHALF
Notice
IMN will notify you about the purposes for which it collects and uses information about you, how to contact IMN with inquiries or complaints, the types of third parties to whom it discloses personal information, and the choices and means the organization offers individuals for limiting its disclosure. This notice will be provided by this Policy, which is available from IMN’s home page so that you may review it before you disclose personal information to IMN.
Choice
IMN provides you with the right to opt out whether your personal information is disclosed to a third party, or used for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by you. This Policy clearly describes the ways that IMN uses and discloses your personal information. If you wish to opt out at any time, you may do so by contacting us at legal@imninc.com. In addition, there is an opt-out feature located in the footer of all unsolicited IMN email communications.
Personal information gathered
The IMN website has various features which allow those interested in IMN and its services to obtain more information about IMN, such as by subscribing to an IMN Newsletter, viewing a webinar, obtaining a free trial of an IMN service, purchasing a subscription to an IMN service, participating in a promotional event, or requesting a white paper. IMN asks those requesting such information to provide IMN with certain personal contact information that IMN may use to follow up with those interested in its services. The information IMN may collect includes first and last name, company or organization, title or position within the company or organization, postal address, phone number, email address, and credit card information. IMN stores this information and uses this information internally to invoice and provide support to its customers and in addition for IMN’s own marketing purposes.
Technical information gathered online
IMN may employ web tracking technologies, such as log files and web beacons, in order to collect certain technical information about the operation of its websites and the behavior of visitors to the websites. The information collected may include: The URL of the site that you came from before visiting IMN's website; your computer’s IP address; the browser you are using; the pages that you visit on the IMN website; search terms that were used to reach the IMN website. IMN websites also use cookies that track anonymous traffic data and to authenticate users and keep track of users’ sessions. Some cookies are used to allow users to enter the portions of the IMN website reserved for registered IMN customers or to govern survey voting. All cookies, except those used for survey validation, expire within several hours after a period of idle use. IMN may use cookies and web tracking technologies to associate your online behavior with your personal information
and use that information internally for IMN’s marketing purposes.
Onward Transfer
IMN does not disclose personal information submitted to IMN to any third party, except as follows:
- IMN may disclose personal information to subcontractors engaged by IMN to perform services on its behalf, such as fulfillment houses that send marketing information on IMN’s behalf. Any subcontractors to whom personal information is disclosed are subject to written agreements of confidentiality. Any subcontractor that receives any personal information of individuals resident in the European Union is either itself subject to EU data privacy law, subscribes to the Safe Harbor Principles or another adequacy finding, or has entered into a written agreement with IMN requiring that such third party provide at least the same level of privacy protection as the Safe Harbor standards.
- IMN reserves the right to disclose personal information if required by law enforcement authorities, subpoena or other court order, or other governmental authority, and (to the extent permitted by law and the Safe Harbor principles) to the extent necessary to protect the legal rights and personal safety of IMN and its employees and agents.
Security
IMN maintains reasonable precautions designed to ensure the security of personal information covered by this Policy, and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction or disclosure. IMN has a written data security policy that describes the policies and procedures by which data security is to be maintained. Although IMN makes every effort to ensure security of its customer information, no data transmission over the Internet can be guaranteed to be 100% secure.
Data Integrity
IMN takes reasonable steps to ensure that personal information it collects is reliable for its intended use, accurate, complete and current. IMN does not use personal information in ways that are incompatible with the purposes for which the information was disclosed.
User Access to Personal Information
IMN allows you access to personal information held about you and allows you to correct, amend or delete that information if inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to your privacy. If you have submitted personal information to IMN, and you wish to obtain access to such information in order to review, amend, or delete that information, you should contact IMN by emailing us at legal@imninc.com. IMN reserves the right to confirm your identity before providing access.
INFORMATION RECEIVED OR USED BY IMN ON BEHALF OF ITS CUSTOMERS
Notice of Information Received and Stored by IMN on behalf of IMN’s Customers
IMN’s services allow IMN’s customers to send email communications to their customers (“end-customers”). In order for these services to be delivered, IMN’s customers upload certain personal information about their end-customers to IMN’s servers. Such information includes email addresses, and may also include other information such as names and addresses of the end-customers to whom the email communications will be sent. IMN does not control the categories of information that an IMN customer may choose to upload to IMN’s servers. IMN stores this information on its servers on behalf of its customers, and acts merely as a data processor with respect to this data. This information is controlled by the IMN customer on whose behalf the information is stored.
IMN uses personal information about end-customers stored by IMN customers solely for the purposes of delivering services to IMN customers. This includes sending email communications to the end-customers and providing analytical reports to IMN customers relating to IMN services. IMN uses web tracking technologies to track the online behavior of end-customers as they interact with the electronic marketing materials sent on IMN customers’ behalf. IMN associates such online behavior with personal information and provides this data to the applicable IMN customer; for example, if an end-customer clicks on a particular product featured in an email communication sent by IMN, the IMN customer may receive a report from IMN identifying the product interest of its end-customer.
Choice
Because information held on behalf of IMN customers is controlled by IMN customers, IMN cannot delete or modify that information. If you wish to opt-out with respect to information stored or used by IMN customers, you should contact the applicable IMN customer directly.
Disclosure of Information stored by IMN on behalf of IMN’s customers
IMN does not disclose any end-customer personal information stored on behalf of its customers to any third party except to a) the IMN customer on whose behalf the information is stored, b) to third parties that the IMN customer has agreed, in writing, may receive such information, and c) to IMN subcontractors performing services on behalf on IMN. Any subcontractor to whom personal information is disclosed is subject to written agreements of confidentiality. Any subcontractor that receives any personal information of individuals resident in the European Union is either itself subject to EU data privacy law, subscribes to the Safe Harbor Principles or another adequacy finding, or has entered into a written agreement with IMN requiring that such third party provide at least the same level of privacy protection as the Safe Harbor standards. Information stored on behalf of any IMN customer is under the control of the applicable IMN customer.
Security
IMN maintains reasonable precautions designed to ensure the security of end-customer personal information covered by this Policy, and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction or disclosure. IMN has a written data security policy that describes the policies and procedures by which data security is to be maintained. Although we make every effort to ensure security of end-customer information, no data transmission over the Internet can be guaranteed to be 100% secure. IMN Customer accounts are password-protected so that only IMN or the applicable IMN customer has access to personal information of end-customers. It is incumbent on the IMN customer not to divulge their password to anyone. IMN will never ask for a customer's password in an unsolicited phone call or in an unsolicited email.
Data Integrity
IMN is not responsible for the data integrity of data held by IMN on behalf of IMN customers, because IMN acts solely as a data processor for such customers.
Access
IMN cannot offer end-customers access to information stored by IMN on behalf of its customers. Such information is under the control of the relevant IMN customer, and you should contact that IMN customer if you wish to obtain access to any personal information about you which is held by them.
GENERAL PROVISIONS
Enforcement of this Policy
If you have a question, comment or complaint about this Policy or enforcement of this Policy, please address your concern to IMN at legal@imninc.com, or send correspondence to the following address:
iMakeNews, Inc.
200 Fifth Avenue
Waltham, MA 02451 USA
Attention: Chief Technology Officer
IMN will investigate your concerns promptly, and will respond to your correspondence within thirty (30) days after we receive it. IMN will provide you with a clear explanation of any decisions made with respect to your request. If you are not satisfied with the manner in which IMN dealt with your privacy concern, you may use the external recourse mechanism described below.
Dispute Resolution - External Recourse
IMN participates in the Direct Marketing Association (DMA) Safe Harbor dispute resolution process. If you feel that IMN is not abiding by its posted privacy policy or is not in compliance with the Safe Harbor principals, you should first contact IMN’s Chief Technology Officer by email at legal@imninc.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact the Direct Marketing Association (DMA) Safe Harbor Dispute Resolution Program. The Direct Marketing Association (DMA) will act as a liaison to IMN to resolve your concerns. You can contact the Direct Marketing Association (DMA) Safe Harbor Dispute Resolution Program at:
Safe Harbor Line
Direct Marketing Association
1615 L Street, NW Suite 1100
Washington, DC 20036
Safeharbor@the-dma.org
Verification
IMN conducts an annual self-assessment to verify that this Policy is accurate, comprehensive, prominently displayed, completely implemented, accessible and conforms to the Safe Harbor Principles, and to confirm that employee training and appropriate compliance procedures are in place.
Changes to Privacy Policy
Changes to this Policy will be posted in this section. This way you will always have a clear understanding of what information is collected online and offline, how it is used, and the choices you have. Your personal information will only be used in accordance with the version of the Policy that is in place at the time that you provided your information, unless you provide your consent to do otherwise.
Effective Date of Policy: April 28, 2010
|
|
