Last Updated: October 27, 2021
Table of Contents:
Changes to this Policy
Information We Collect
How We Use Your Data
How We Share Your Data
How We Safeguard Your Data
Your Choices Regarding Your Data
About This Policy
For purposes of this Policy, “Rhonda”, “we”, “us” and “our” means IMI People, IMI Software Labs and the software Service called Rhonda. Except as otherwise provided, this applies to our interactions with our customers, visitors, and the users of our products and services in connection with activities, including, but not limited to:
- Use of our websites, including mobile websites, applications (collectively, the “Site”)
- Visits to location where our products are located or attendance at one of our events
- Phone and email communications
- Social media interactions on our websites and other third-party websites like Facebook, YouTube, Pinterest, Google+, Instagram and Twitter
- Viewing our online advertisements or emails
- Through our authorized service providers
The nature of our business requires that we gather and maintain information that is of a personal nature that you may wish to keep protected. This Policy does not apply to any third-party websites, services or applications, even if they are linked to or accessible through our Services.
Changes to our Policy apply to your use of the Website after the “effective date” listed above.
Changes to this Policy
We reserve the right to change this Policy at any time. In the event we make material change(s) to the Policy, they will be effective immediately upon posting to the Site and will apply after the “effective date” listed above. You understand and agree that your continued use of the Site and/or Services after the effective date, means that the collection, use, and sharing of your information is subject to the updated Policy.
Except to the extent we obtain your consent or as permitted or required by applicable law, we will handle your personal information collected through the Site or as part of the Services, or as otherwise described in this Policy in accordance with the terms of the Policy in effect at the time of such collection.
You provide data when you request information from us.
We collect data through your use of the Website.
Information We Collect
We may collect or have collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of personal information we collect personal information. In that case, we will inform you.
- Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
- Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
- Commercial information. This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. It also may include your credit card number or account information when you upgrade to a paid account.
- Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity. Examples include browser type, browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement, as well as operating system and version, Internet Protocol (IP) address, domain name, information about your application, operating environment and hardware profiles and/or a date/time stamp for your visit.
- Geolocation data. This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone.
- Professional or employment-related information.
- Consumer profile. This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
- Sensitive personal information. This includes personal information that would reveal identifiers such as social security, driver's license, state identification card, or passport numbers, as well as log-in, financial account, required security or access code and other information that would permit access to an account. It also would include precise geolocation and racial or ethnic origin, religious or philosophical beliefs, union membership or a consumer's genetic or medical information.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We also may collect "Anonymous Data" which is data about you that is not associated with or linked to your personal information. Anonymous Data does not permit the identification of individual persons.
We may use your data to communicate with you and improve the Website and our services/products.
Purposes We Collect Your Information
Set forth below are the business or commercial purposes we have collected your PI. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.
- To provide access to the Site, to enable use of our App, and to provide and improve our Services
- To provide you with information, products or Services that you request from us.
- To fulfill or meet the reason for which the information is provided.
- To contact you and/or provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To provide you with marketing and sales communications both on and off of the Rhonda Website Services. We may also receive reports regarding the effectiveness of our campaigns on an individual and aggregated basis. If you wish to opt-out of targeted marketing, please use the options available in the cookie banner or button at the bottom of the page or the controls available through your browser.
- To communicate with you in social media concerning our products and services.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our website, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.
- To provide customer service and engage in quality control activities concerning our products and services.
- For testing, research, analysis and product and service development.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To process applications for employment, as well as to evaluate and improve our recruiting efforts.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We may disclose your data to third parties to help us manage the Website, to provide you with information and services, and to protect legal rights and interests.
Sources of Personal Information
The categories of sources of PI are described below. The examples provided are for illustration purposes and are not exhaustive.
- You. Examples of when we collect that information include:
- During a Site visit, register for the Service, or when you visit us at one of our office, locations, or events.
- If you upload or share information, submit a request, submit information, participate in a promotion, or post other digital content through one of our websites, applications or via social media interactions on third party websites like Facebook or Twitter.
- If you apply or inquire about employment.
- We may use tracking tools like browser cookies, flash cookies, and web beacons.
- Your business connections, friends, and family, such as when they refer you to us with respect to the products and services we provide.
- Social media and related services
We may disclose your data in connection with legal process, to protect the security or integrity of the Website, to defend ourselves, and to protect others.
We may disclose your data in connection with a sale, acquisition, merger, or change in control.
We collect data through cookies and similar technology.
Of the categories of PI noted above, during the past 12 months, we disclosed the following:
Categories of Personal Information Disclosed
Categories of Third Parties to Whom Disclosed
Characteristics of protected classifications under California or federal law.
Internet or other electronic network activity.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information
· Third parties as directed by you. We will disclose your PI with those third parties to whom you direct. For example, if you decide to send one of our products as a gift, we may include your name.
· Our business partners. For example, we might disclose your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner's privacy statement before signing on with them.
· Third parties who perform services on our behalf. For example, we disclose information with certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect PI on our behalf. These service providers have access to your personal information only for the purpose of performing services on our behalf and are contractually restricted in how they may use your personal information.
· Governmental entities, legal service providers. We may disclose your PI in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request.
· Successors to all or portions of our business. We may share your personal information as part of a sale, merger or change in control, or in preparation for any of these events.
We may disclose your data to operators of social media site you are logged into while browsing the Website.
Selling Personal Information.
We do not sell your PI and have not sold any PI in the preceding 12 months, including any information concerning minors under age 16.
We take steps to protect your personal information and to try to guard against data breaches.
Use of Your Personal Information On Our Website.
As is true of most websites, we gather some personal information automatically and store it in log files. This information may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, date/time stamp, etc. We use this personal information to understand and analyze trends, to administer the Website, to learn about user behavior on the Website, and to gather demographic information about our user base as a whole. To monitor use of the Website and improve its quality, we may compile statistical information concerning the use of the Website through analytics services, such as those provided by Google Analytics. Examples of this information may include: the number of visitors to the Website or to sections or pages within the Website, patterns of traffic flowing through the Website, length of time spent on the Website, or in sections or pages of the Website, the other sites that refer visitors to the Website, the pages of the Website that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Website. We also may use this personal information in our marketing and advertising services.
We may use various kinds of software devices to collect personal information about use of our Site and Services. Small files called "cookies" may be attached to your Web browser. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them, or for an extended period of time) to provide you with a more personal and interactive experience while using the Service. Persistent cookies can be removed by following Internet browser help file directions. If you choose to disable cookies, some areas of the Site, the application and/or the Services may not function correctly.
We do not detect Do Not Track signals.
We are not responsible for any website which may be linked to ours.
This site is not directed at children.
This Website may use social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Site, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Website, the social plugins allow that social media website to share data about your activities on our Website with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content form the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.
We are not responsible for any website which may be linked to ours.
IMPORTANT: By using the Website, you consent to the processing of any personal information provided or collected for the analytics purposes and functions described above.
Safeguarding of Information
No system for safeguarding personal or other information is 100% secure and even though we have taken steps to protect your personally identifiable information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information. However, we take a number of steps to safeguard the security of personally identifiable information obtained through the Site. For example, we maintain administrative, technical and physical controls to reasonably safeguard data from unlawful use, unauthorized access or disclosure. Additionally, we use Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our Website. Individuals who have access to confidential and otherwise nonpublic data are required to maintain the confidentiality of such information.
Do Not Track.
“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Links to Third Parties’ Websites.
We may provide links to websites or resources outside of our Site for your informational purposes only. You acknowledge and agree we are not responsible for the availability of such sites or resources, and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through or provided by such sites or resources. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any of your personal information that you provide or may be collected by such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.
This site is not directed at children.
Information of Children.
We do not knowingly collect or solicit personal information from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request personal information from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any personal data, the parent or guardian of that child should contact us and ask to have this personal information deleted from our files. If we otherwise obtain knowledge that we have personal information about a child under 13 in our files, we will delete that personal information from our existing files so that it is not in retrievable form.
Notice to Website Users Located Outside the U.S.
We operate in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the personal information that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
Our main servers are in the U.S., and it is likely that your data will be held on servers there. When you provide us with your personal data, you acknowledge that this information may be stored and processed on servers located outside the European Economic Area (‘EEA’). If you are in the EEA, you consent to your personal data being exported outside the EEA and being stored and processed at our discretion on any of our servers wherever they may be located.
Your Choices Regarding Your Personal Information.
You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access some of the services and content on the Website. You can also limit the communications that we may send you by following a simple opt-out or unsubscribe process. Simply follow the instructions in our newsletter or other communications to opt-out of receiving, or unsubscribe from, future communications.
Please note that even if you opt-out of certain communications from us, we may still need to contact you with important information about your use of the Website or for other lawful purposes.
You may contact us.
How to Contact Us.
Send us an e-mail:
877-464-4484 (Toll-free in U.S.) 9:00 AM - 4:30 PM PST Monday – Friday
Write to us:
IMI Software Labs, 240 Great Circle, Nachville, TN 37228.
Information for California residents.
If you are having trouble accessing this CA Addendum, click here for more information including to obtain the CA Addendum in PDF/printable format.
Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.
Request to Delete
You have the right to request that we delete your PI from Our records and direct any service providers or contractors to delete your PI from their records, subject to certain exceptions. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, We will delete and direct any service providers or contractors to delete your PI from our records.
We are not required to comply with your request to delete your PI if it is reasonably necessary for us (or our service providers or contractors) to maintain your PI in order to:
- you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the us and you.
- Help to ensure security and integrity to the extent the use of the consumer’s PI is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.
- Comply with a legal obligation.
Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, We will provide a response.
Request to Know.
You have the right to request that We disclose the following to you as it relates to the 12-month period preceding Our receipt of your verifiable consumer request:
- The categories of PI we have collected about you.
- The business or commercial purpose for collecting PI.
- The categories of sources from which the PI is collected.
- The categories of PI We disclose about you for a business purpose
- The categories of third parties to whom we disclose PI.
- The specific pieces of PI We have about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to your request for information.
Request to Correct Inaccurate Information.
You have the right to request that we correct inaccurate PI that we maintain. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Direct the Company to Limit the Use of Sensitive Personal Information.
You have the right to direct that we limit the use of sensitive personal information we collect about you to (i) uses that an average consumer would expect are reasonably necessary to provide the goods and or services you have requested, (ii) perform certain other activities permitted under the CCPA, and (iii) what is permitted by applicable law. Your right to direct the Company under this paragraph applies only to sensitive personal information that we collect or processed for the purpose of inferring characteristics about you.
We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.
In addition to the CCPA, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Company to third parties for the third parties’ direct marketing purposes. Consumers who have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such request must be submitted to us by calling [insert toll-free number] or reach us by email at email@example.com. Please mention in your call or email that you are making a "California Shine the Light" inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of such personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
Submitting Consumer Rights Requests
To submit any of the Consumer Rights requests as outlined above, please contact us at 877-464-4484 and firstname.lastname@example.org. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer’s minor child, or
- by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive personal information to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used for any other purpose. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by the Company. The response we provide will also explain the reasons We cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Policy. When you submit a request under this Addendum, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
Questions. If you have questions about this CA Addendum, please contact us as described in the Policy.
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