PRIVACY POLICY
As of May 26, 2021
ImpactWayv, Inc. and its affiliates (“ImpactWayv”, “we,” “our” or “us”) are committed to protecting your privacy and the data you share with us. This Privacy Policy describes how ImpactWayv may collect, use, protect and share your information, particularly in association with the operation of our ImpactWayv™ application, its contents, our website (www.impactwayv.com), ImpactWayv-operated pages on social media sites, ImpactWayv’s business activities, like conferences and events, client services, and any other websites, applications, activities, services, HTML-formatted emails or communications that link to this Privacy Policy (collectively, the “ImpactWayv Digital Services”). Please see our Terms of Use for more information about our online terms and policies in general.
What information do we collect?
We do not collect any personal information about you unless you affirmatively provide it to us. For example, certain portions of our ImpactWayv Digital Services, such as the registration process and the “Contact Us” page, allow you to provide certain personal information on a voluntary basis, including your name, e-mail address, company information, and other contact information. If you correspond with ImpactWayv via email, we may retain the content of your email together with your email address and any response from us. Likewise, when you provide your contact information to one of our team members, your contact information may be added to our email lists for client alerts and other ImpactWayv resources or communications.
Consistent with industry practice, we protect our ImpactWayv Digital Services by automatically collecting specific information to our log files. This information includes IP addresses, type of browser, internet service provider, operating system and date and time of access. This information is not linked to any information we may collect about you.
We may conduct surveys regarding the functioning of the ImpactWayv Digital Services. Your responses are appreciated but such surveys are optional. We may share the results of our surveys with third parties, but only in a cumulative, statistical format without disclosing your personal information.
In addition, when you are visiting the ImpactWayv Digital Services, ImpactWayv and third parties with whom we work (e.g., service providers, business partners, etc.) may place, view, and/or use “cookies” or similar technologies to collect certain information about your use thereof. This may include information about the IP address of your computer and mobile device, browser type, language, operating system, geo-location data, the state or country from which you accessed any ImpactWayv Digital Services, the web pages visited, the date and the time of a visit, and the websites you visited immediately before visiting ImpactWayv Digital Services. You can control the use of cookies at the individual browser level, but your ability to access some features of the ImpactWayv Digital Services may be restricted.
How will the information you provide be used?
We may use the personal information you provide us for a number of different purposes. Specifically, we may use the information to respond to any requests you have submitted. Likewise, we may use your contact information to send you ImpactWayv memoranda, announcements, news, invitations, or other information about ImpactWayv events and services that we believe may be of interest to you.
Other potential uses of this data include:
· To comply with the law or in response to a subpoena, court order, law enforcement or government request, or other legal process;
· To produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government, or internal investigation, or other legal or administrative proceedings;
· To protect the interests, rights, safety, or property of ImpactWayv, our clients, users of the ImpactWayv Digital Services, or others;
· In connection with internal organizational matters;
· To combat fraud or other criminal activity;
· For any other purpose disclosed by us when you provide the information;
· As otherwise required or permitted by law.
Any information collected by cookies will be done on an anonymous basis; ImpactWayv does not link any personal information you provide with cookie data. From time to time, we may aid third parties in their promotion activities by sharing, renting, or trading your personal information. If you are a resident of California, you may have additional rights which are set out below.
How may we share the information we collect?
ImpactWayv is a global provider of media, technology, consulting and other services. Our team members share information with each other for business purposes such as internal administration, billing, informing you about our events and services, and providing you or your organization with services. In order to provide the information and services described in this Privacy Policy, we may share your personal information and other information with carefully selected vendors or other business partners or representatives that perform services on our behalf.
How do we provide a press release?
To request media relations information or a press release you may contact ImpactWayv, but we require that you provide your name, company, email address, telephone number and the reason for the request. We will not share your information with any third-party except our public relations firm. We may retain this information to send you future press releases.
What is our legal basis for processing your personal data?
We rely on the following legal grounds to process your personal information, namely:
· Performance of services – To the extent you are a client of ImpactWayv or wish to become one, we may need to collect and use your personal information to perform the services for which you have contracted with us. For example, we may use your personal information to respond to requests you make via the ImpactWayv Digital Services to provide you with such services.
· Consent – Some of the personal information collected by ImpactWayv is provided by you voluntarily, for example when you sign up to join a mailing list or register for an event and is therefore collected and used with your permission. By using the ImpactWayv Digital Services, you consent to the collection, use and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the ImpactWayv Digital Services. To withdraw your consent to such use, you can contact us at legal@impactwayv.com.
· Legitimate interests – We may use your personal information for our legitimate interests, such as to improve our products and services and the content on the ImpactWayv Digital Services. We may also use your contact information to keep you and others who have provided us with their contact information up-to-date on recent developments of interest. It you wish us to stop using your contact information in this manner, you can contact us at legal@impactwayv.com.
How do we secure your information?
We use reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access and use. This may include, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by ImpactWayv.
However, no system of transmission or storage of data can be 100% secure. As such, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet.
How long do we hold your information?
We retain the information we collect no longer than as reasonably necessary to fulfill the purposes for which we collect the information and to comply with our legal obligations.
What occurs in business transactions and change of ownership?
In the course of building our business, we may buy or sell assets or services. Email information or ImpactWayv Digital Services visitor information may be one of the assets transferred in such a transaction. During a corporate merger, divestiture, or dissolution we may transfer such information. In the event of a change of ownership or other uses of this personal information you will be sent a notice via email or by a prominent notice on our website or other ImpactWayv Digital Services.
What other details about this Policy should you know?
The examples contained in this Privacy Policy are illustrations only and are not intended to be all-inclusive. This policy will be reviewed based on changing business conditions or changes in our information sharing practices. ImpactWayv Digital Services reserves the right to change this policy at any time, and we will inform you of changes as required by law.
What are your rights?
If you no longer wish to receive communications from us – such as about events being promoted or hosted by ImpactWayv or insight from ImpactWayv team members on recent developments – you can let us know by contacting us at info@impactwayv.com with the subject line “unsubscribe” on your email. It may take up to 30 days to remove your personal information from our records. You may also use this email address to correct, update, delete or deactivate your account.
Who is the data controller?
The data controller for the ImpactWayv Digital Services is: ImpactWayv, Inc., 270 Madison Avenue, 16th Floor, New York, New York 10016.
California Residents – Additional Privacy Provisions
In compliance with the California Consumer Privacy Act of 2018 (the “CCPA”), this additional notice is mandated for, and applies only to, California residents from whom ImpactWayv Digital Services collects personal information (“California Consumers”). Any terms defined in the CCPA will have the same meaning in this notice. If there is any conflict between the terms of our Privacy Policy above and this CCPA policy, the California version shall control.
What information is collected from California Consumers?
We collect certain types of personal information when you access the ImpactWayv Digital Services or request our services, including: contact information, demographic information, commercial information as applicable, Internet network activity, geolocation information and similar information, including any inferences that can be derived from this information.
The sources of personal information from whom we collect data include: directly from each California Consumer who registers on the ImpactWayv Digital Services, Internet network monitoring and network tools, analytics tools, and third-party services that supplement our information about a California Consumer.
What are the purposes for disclosure of information from California Consumers?
See the information above in our Privacy Policy which lists the uses we may make of any personal information from a California Consumer.
During the past 12 months, we have not sold any personal information to any third-party. However, we anticipate that some personal information may be provided and/or sold (as defined in the CCPA) in the future to third-party business partners, service providers or entities which place advertising on our site.
What are California Consumers’ rights of access?
As a California Consumer you have the right to request access to the specific personal information that is collected about you and that we may disclose or sell. This includes the categories of personal information listed above.
What are California Consumers’ rights of deletion and opting out?
As a California Consumer you have the right to ask that we delete any personal information that we may have collected about you, subject to certain legal exceptions. As a California Consumer you have the right to “opt out” of the sale of your personal information to third parties (as defined in the CCPA), although we currently have no plans to sell such information.
How may California Consumers exercise their rights?
If you want to exercise your rights of access or deletion, as set forth above, you may submit your request via email at legal@impactwayv.com, or by telephone at (212) 933-9150 or by US mail to our address listed below.
The above rights are limited to California Consumers, or an authorized individual acting on their behalf. In the event you seek either access or deletion of information, we may request verification before we act on such a request. Verification may require you to provide us with information to reasonably confirm that the California Consumer is the person from whom we have collected personal information. If we determine, in our sole discretion, that such a request is excessive, repetitive, or manifestly unfounded we may charge a reasonable fee or may deny the request. We will not discriminate against California Consumers who exercise their rights pursuant to the CCPA.
How does the California Shine the Light Act apply to a California Consumer?
As a California Consumer, California Civil Code Section 1798.83 provides that you may request information regarding our disclosure of your personal information to our affiliated companies and to third-parties for direct marketing purposes by the third-parties. We do not share your information with third-parties for their direct marketing purposes unless we have received your prior consent.
How may California Consumers get further information about their rights?
Questions about our privacy practices and your rights as a California Consumer will be answered if you contact us at legal@impactwayv.com with the subject line “California CCPA Policy”. You may also write to us at: ImpactWayv, Inc., 270 Madison Avenue, 16th Floor, New York, NY 10016