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 BEHALFNotice
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 does not disclose personal information submitted to IMN to any third party, except as follows:
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 CUSTOMERSNotice 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
GENERAL PROVISIONSEnforcement 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.
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 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: June 2018