IMN - About Our Company

IMN - About Our Company

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 all 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 complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Reynolds has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view IMN's certification, please visit http://www.export.gov/safeharbor/.


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 will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Information, IMN will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

IMN will provide individuals with reasonable mechanisms to exercise their choices.

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. 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 Information Security Policy and Data Protection 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

Upon request, IMN will grant individuals reasonable access to Personal Information that it holds about them. In addition, IMN will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.



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 of 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 Information Security Policy and Data Protection 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.


SOCIAL MEDIA SERVICES

In order to utilize certain IMN services, you will need to permit IMN applications to access your accounts with social media websites and services that are owned and/or controlled by third parties (including, without limitation, Facebook and Twitter) (such Websites and services, collectively, the "Social Media Services"). IMN applications require access to your accounts with Social Media Services in order to post content and provide reporting data. When you elect to permit the IMN services to have access to your accounts with the Social Media Services, you will be authorizing the sharing of your information (which will include personal information if you elect to share such information) with those Social Media Services. It is important to note that the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by IMN policies and agreements. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including IMN. When you authorize the IMN service to exchange information with the Social Media Services we will collect relevant information necessary to enable our website and service to access that Social Media Service, however you will provide your login information, like your password, directly to such Social Media Service (and not to IMN). As part of such integration, the Social Media Service will provide IMN with access to certain information that you have provided to such Social Media Service, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of the applicable Social Media Services provider, and, as a result, IMN shall not have liability nor any responsibility for the privacy practices or other actions of Social Media Services that may be enabled within and/or otherwise accessible through the IMN website(s) and/or services. In addition, from time to time, our customers may offer certain contests, promotions and other offerings that will be integrated with various Social Media Services. In order to participate in these contests, promotions and other offerings, you will need to opt-in to share your Social Media Services contact information with our customers and their service providers.


GENERAL PROVISIONS


Enforcement of this Policy

IMN will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that IMN determines is in violation of this policy will be subject to disciplinary action, up to and including termination of employment.


Dispute Resolution - External Recourse

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the address given below. IMN will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Policy. For complaints that cannot be resolved between IMN and the complainant, IMN has agreed to participate in the following dispute resolution procedure in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

For disputes involving all other Personal Information received by IMN from the EEA, IMN has agreed to dispute resolution through arbitration in accordance with the commercial rules of the American Arbitration Association ("AAA"). Individuals who submit a question or concern to IMN and who do not receive acknowledgment from IMN of the inquiry or who think their question or concern has not been satisfactorily addressed should then submit a demand for arbitration with the AAA.

For information about AAA or the operation of the AAA arbitration dispute resolution process, visit AAA on the Internet at www.adr.org. The AAA arbitration dispute resolution process shall be conducted in English.

LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by IMN to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to IMN Office by mail to:

Information Security Department
Reynolds and Reynolds
One Reynolds Way
Dayton, OH 45430


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.

EFFECTIVE DATE: May, 2014

To learn more about the Safe Harbor program, and to view the Company's certification, please visit http://www.export.gov/safeharbor/.