1.1 “Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.

1.2. “Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.3. “GDPR” means EU General Data Protection Regulation.

1.4. “Precise Location Data” means location data that describes the precise geographic location of your device;

1.5. “Geo IP Data” means non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device.

1.6. “ID” means distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.

1.6. “ID” means distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.

1.7. “IP” means Internet Protocol address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.

1.8. “Internet connection” means: internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).

1.9. “Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR.

3.1. We may collect User Information about you from the following sources:

3.1.1. Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, create an account on our website ; receive promotional information by email; participate in surveys; contact us via email, telephone or by any other means; purchase our services or etc.).

3.1.2. Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).

3.1.3. Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) etc.

3.1.4. Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our website.

3.1.5. Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources; third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.).

3.1.6. If you use a third party connection or log-in to access the Services, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services. This Privacy Policy does not cover the practices of third parties, including those that may disclose information to us.

3.2. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.

The purposes, for which we may Process User Information, subject to applicable law, include:

4.1. Provision of the Services to You: providing the Services to you from ImRix including but not limited (a) management of your account, and (b) customer support and relationship management.

4.2. Offering and Improving the Services: operating and managing the Services for you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.

4.3. Surveys: engaging with you for the purposes of obtaining your views on our Services.

4.4. Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

4.5. IT Administration: administration of ImRix information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.

4.6. Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements.

4.7. Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

4.8. Legal Proceedings: establishing, exercising and defending legal rights.

4.9. Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of ImRix, any of our users or the public, or to respond to an emergency.

5.1. We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

5.2. You may unsubscribe from our email lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

6.1. ImRix may use cookies and other tracking technologies to analyze trends, administer Services, track users’ movements around the Services, and to gather demographic information about our user base.

6.2. The cookies used on our website can be divided into two basic types. Session cookies are deleted as soon as your visit to our website ends. Persistent cookies remain stored on your device far longer or until you remove them manually (the period for which a cookie is left on your device depends on the cookie’s own settings and your browser settings).

6.2. You can control the use of cookies at the individual browser level.

7.1. In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

7.1.1. Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);

7.1.2. Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;

7.1.3. Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;

7.1.4. Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or

7. 1.5. Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

8.1. We may disclose your User Information to other entities for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
- third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 8;
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);

8.2. If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

8.3. Our website may contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

9.1. Because of the international nature of our business, we may need to transfer your User Information within the third parties as noted in Section 8 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

9.1.2. Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses.

10.1. We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

10.2. Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

11.1. We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified.

12.1. We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

13.1. We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

14.1. If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact: