Your Privacy Rights
Effective: March 14, 2023
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.
Users From Outside the United States
Our websites and services are provided and operated from within the United States and are subject to the applicable state and federal laws of the United States. If you are located outside the United States, please be aware that your Information is being transferred to and stored in the United States. Your use of the websites is your consent to such processing.
Cross-Border Transfer of Your Data
IMN may transfer your personal data outside of the US. Such transfer shall be conducted in accordance with all laws and regulations, including, when and where applicable, Chapter V of the European Union General Data Protection Regulation.
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.
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 when offered, 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 will be required to process and protect your information in compliance with this Policy
- 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 necessary to protect the legal rights and personal safety of IMN and its employees and agents. IMN also may transfer your data to an affiliate or to a successor in interest (or a potential successor in interest) to its stock, assets or business. and as appropriate to protect our rights, property, or safety, or the rights, property or safety of our customers or other third parties, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
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 physical 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. End-customer behavior data can also be shared for usage by IMN email campaigns and affiliate services if the IMN customer has enrolled in those services.
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 upholds the terms, conditions, and principles of this policy. 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, LinkedIn, and Pinterest) (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.
Your California rights
If you are an individual residing in California, you may have additional rights with regard to the information we gather about you. Upon verifiable written request, we will provide to you information regarding the types of personal information we gather about you, the types of sources from which we obtain the information, the purposes for which the information is gathered, and the types of third parties with which we share or to whom we sell the information. In addition, upon verifiable request or when required or otherwise appropriate, and within periods (if any) set by applicable law, we will endeavor to grant you reasonable access to the personally identifiable information that we hold about you provided that you establish to our reasonable satisfaction that you are the person whose personal information is requested. We may deny such access where the denial is permitted by applicable law and every request from an individual will be assessed on a case by case basis. In the event a request is denied, we will notify you regarding the reasons for the denial in writing. Consistent with how your personally identifiable information is maintained in the ordinary course of our business, we will provide the information in an understandable form, and to the extent feasible in a format that permits you to use the information on other systems. We may impose a reasonable charge when a request is made (e.g., for photocopying or postage) to the extent permitted under applicable law. In addition, we will endeavor to take reasonable steps to permit you to correct, amend, or delete personally identifiable information that is demonstrated to be inaccurate or incomplete. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm the identity of the individual making the request before granting access. We will not discriminate against consumers who exercise their rights under California law. However, we may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided by your personal information and may offer financial incentives to an individual for the collection, sale, or deletion of personal information if the individual provides its prior consent to the terms of those incentives. For questions regarding this policy or to make a request please contact us at (800)769-2272. You can also make a request by clicking here.
California Civil Code Section § 1798.83 permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@imninc.com or write us at: 7400 Wilshire Place Dr., Houston, TX 77040.
Children Under the Age of 13.
The websites are not intended for use by children under 13 years of age. No one under age 13 may provide any personal information through the websites. We do not knowingly collect personal information from children under 13. If you are under 13, please do not use or provide information through the websites or otherwise send any information about yourself to us, including your name, address, telephone number or e-mail address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at support@imninc.com
GENERAL PROVISIONS
Enforcement of this Policy
IMN conducts an annual self-assessment in order to verify that this policy is published and implemented within IMN and that it conforms with appropriate privacy principles and applicable law. IMN has procedures for training employees, disciplining misconduct and conducting periodic reviews to verify compliance with this policy.
Dispute Resolution - External Recourse
Any questions or concerns regarding the processing of personal data should be first directed to the IMN at the address provided under Contact Information in this policy. Data subjects, when subject to applicable EU laws and regulations, may have the option of contacting EU Data Protection Authorities or lodging a complaint with a supervisory authority. IMN will investigate and attempt to resolve complaints and disputes regarding the processing of personal data in accordance with the principles contained in this policy. For complaints that cannot be resolved between IMN and the complainant, IMN agrees to cooperate with EU authorities and to implement any advice or ruling received from EU authorities.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by IMN to the above stated 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
Email us at privacy@imninc.com or contact:
Will Farley, Privacy Officer
Reynolds and Reynolds
One Reynolds Way
Dayton, OH 45430
Your privacy rights
As a consumer, subject to applicable laws ruling your jurisdiction, you have certain rights. These may include:
Right to Know: Upon receipt of a verifiable written request (where we will verify your ID) , and within periods set by applicable law, we will provide you with information regarding the personally identifiable information we gathered about you over the past 12 months from the date of receipt of such request, the types of sources from which we obtain the information, the purposes for which the information is gathered, and the types of third parties with which we share or to whom (if any) we sell the information, unless a request is impossible or involves disproportionate effort. In the event that the latter applies we will provide you with the reasons why such request cannot be processed. We may also deny your request in accordance with “Denying your request” section below.
Right of Access and Portability: Upon receipt of a verifiable request, and within the periods set by applicable law, we will grant you with reasonable access to the personally identifiable information that we hold about you, provided that you establish, to our reasonable satisfaction, that you are the person, or you represent the person, who the personal information relates to. You also may have the right to receive your personal information in a form and format for the purpose of transmitting that information to another entity.
Right of Correction: We will take reasonable steps to permit you to correct, update or amend personally identifiable information that is demonstrated to be inaccurate or incomplete. In addition to any other terms set out in this policy, a request to correct may be denied if your request to correct the same alleged inaccuracy has been denied by us within the past 6 months from the receipt date.
Right of Deletion: Upon receipt of a verifiable request or when required or otherwise appropriate, we will delete personally identifiable information we have gathered about you, except to the extent applicable law permits or requires us to maintain that information for a longer period. We will inform you once the request has been completed or if we cannot comply with your request for a specific reason.
Right to Opt Out of Sale/Sharing: We do not sell your personally identifiable information to third parties for monetary consideration. We may, however, share personally identifiable information in the course of our business when we instruct a service provider to act on behalf of us for the purpose of providing the goods and the services or gathered by cookies and similar tools with third parties for marketing purposes, including analytics.
Right to Opt Out of Certain Processing: Upon receipt of a verifiable request or when required or otherwise appropriate, you may have the right to opt out of the processing of your personal information for the purpose of targeted advertising or for profiling in furtherance of decisions that produce legal or similar effects.
Right to Limit the Use and Disclosure of Sensitive Personal Information: If you would like to exercise the right to limit our use or disclosure of Sensitive Personal Information, please access the link “Limit the Use and Disclosure of My Sensitive Personal Information." As used in this policy, Sensitive Personal Information means and includes information that reveals:
- A person’s social security, driver’s license, state identification card, or passport number.
- A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
- A person’s precise geolocation.
- A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
- A person’s mental or physical health or diagnosis.
- A person’s citizenship or citizenship status.
- The contents of a person’s mail, email, and text messages unless we are the intended recipient of the communication.
- Information about a person’s sex life or sexual orientation
- A consumer’s genetic data and biometric data, where the processing of biometric data is intended for the purpose of uniquely identifying a consumer.
Denying a request and non-disclosable information
Upon request or when required or otherwise appropriate, and within periods (if any) set by applicable law, we will endeavor to grant individuals reasonable access to the personal information that we hold about them. To guard against fraudulent requests to know, to delete to correct and to access, we will require sufficient information to allow us to confirm the identity of the individual making the request before granting access, giving details about the personal information in scope, correcting or deleting the information. Such access may be denied in whole or in part by us where the denial is permitted by applicable law. Every request from an individual will be assessed on a case-by-case basis. In the event a request is denied, we will notify the individual regarding the reasons for denial in writing. Consistent with how your personal information is maintained in the ordinary course of our business, we will provide the information in an understandable form. We may impose a reasonable charge when a request is made (e.g., for photocopying or postage) to the extent permitted under applicable law. We will not be able to disclose to you or any other individual authorized to act on your behalf, the information listed below, however, we would be able to inform you with sufficient detail that we collect certain types of information about you.
Non-Disclosable PERSONAL INFORMATION:
- Social security number
- driver’s license number or other governmental ID number
- financial account number
- any health or medical identification number
- account passwords
- security questions and answers
- unique biometric data generated from measurements or technical analysis of human characteristics.
NON-DISCRIMINATION
We will not discriminate against consumers who exercise their rights under applicable data protection laws. Unless permitted by the applicable law depending on the jurisdiction or other applicable laws, we will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
However, we may offer financial incentives to you for the collection, sale, or deletion of personally identifiable information. Any such offer will reasonably relate to the value of your personally identifiable information and contain written terms that describe the program’s material aspects. Participation in such a financial incentive program requires your prior opt-in consent, which you may revoke at any time. For questions regarding this policy or to make a request please contact us at (800)769-2272.
Changes to Privacy Policy
We will post any change to this policy on this page.