This Policy provides information about our collection, use and sharing of the personally identifiable information or personal data (“Personal Information“) that we obtain through your use of the Impello website (“Websites”); the software applications made available by us for use on or through computers and mobile devices (“Apps”); through social media properties (“Social Media”); through email messages that we send to you (“Emails”); through filling out forms on one of our Websites (“Submitted Forms”); through interactions with our advertising or applications that we serve on third-party websites and services (“Served Ads”) and through services we provide to our users and clients (“Client Services.”) Collectively, we refer to the Websites, the Apps, our Social Media, Emails, Submitted Forms and Client Services as the “Services.”
Personal Information means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identifier has been removed.
Impello may collect, process, store and transfer different types of information about users. Certain types of data that we collect constitute Personal Information only when combined with personal identifiers.
Identity & Demographic Data
This includes information that we use to identify or communicate with you as a user of the Services. This may include first & last name, gender, date of birth, user credentials and passwords and other similar data. Under certain circumstances, we may request and collect sensitive Personal Information like social security number and demographic information like gender, ethnicity and sexual orientation where required for certain aspects of the Services.
This includes mailing or billing addresses, email address, telephone number and mobile phone number and social media handles or screennames.
Technical Usage Data
Includes information specifying the internet protocol (IP) address used to access the Services, data about your computer, web-browser, operating system, physical location, and other technical data about the devices you use to access the Services.
We use third-party payment processors for most financial transactions, however we may collect payment information for processing of payments under specific circumstances.
Academic performance and progress-tracking data collected to assess your performance in Impello’s educational programs.
Marketing and Communications Data
Includes information about your interests, preferences, website browsing history, demographic information such as age, gender, education level, feedback and survey responses and your marketing and communications preferences.
We directly collect Personal Information from you when you:
In many instances, our legal and regulatory obligations require us to collect certain Personal Information from you. Any failure or refusal to provide that information may preclude us from providing access to the Services, or otherwise prevent us from entering into contractual arrangements with you.
We have listed below the different ways that we may use your Personal Information, along with the lawful basis for processing and the legitimate business interests that require processing. We will only use your Personal Information for the purposes for which we collected it. In some instances, we may have several lawful purposes for processing your Personal Information. Feel free to contact us if you would like additional information about our processing of your Personal Information.
In order for Impello to do the following;
We may process the following types of Data;
This is the lawful basis for our processing of that Data;
Provide you with access to the Websites; creating and maintain an online account for you to register and use the Services.
Demographic Data Identity Data
Data processing is necessary for us to enter into a contract with you; for us to comply with our legal and regulatory obligations, and in support of our legitimate interest in providing you with the Services.
To deliver the Services to you.
Demographic Data Identity Data Performance Data
Data processing is necessary for us to perform under the terms of a contract with you, for us to comply with our legal and regulatory obligations, and our legitimate interest in delivering the Services.
To facilitate, collect and process your payments, fees and charges for the Services.
Identity & Demographic Data Contact Information Payment Data
Data processing is necessary for us to enter into or perform under the terms of a contract with you; for us to comply with our legal and regulatory obligations, and for our legitimate interest in providing you with the Services.
To improve the Services and to provide high-levels of customer service.
Contact Information Technical & Usage Data Anonymized Data
Data processing is necessary for the performance of our contract with you and for our legitimate business interests in; assuring proper technical functionality, high-levels of customer service and usability to meet the needs and demands of our customers.
Contact Information Identity & Demographic Data Marketing & Communications Data
Data processing is necessary for us to comply with our legal and regulatory obligations under the relevant privacy laws and regulations, and for our legitimate interest in delivering the best levels of service to you.
To recommend additional Services to you and provide updates to existing Services.
Contact Information Identity & Demographic Data Marketing & Communications Data Technical & Usage Data Anonymized Data Performance Data
Data processing is necessary for us to perform under the terms of our contract with you and for our legitimate interest in delivering high levels of customer service.
Properly administer and protect the Services through data integrity testing, system analysis and troubleshooting.
Contact Information Identity & Demographic Data Marketing & Communications Data Technical Usage Data
Data processing is necessary for the performance of our contract with you; for us to comply with our legal and regulatory obligations, and in support of our legitimate interests in providing network security in connection with the Services, improved functionality and customer service.
To service you as a customer, including responding to inquiries, providing relevant information about the Services, promotions or other opportunities that you request or agree to receive, through electronic means or other marketing channels.
Data processing is necessary for us to enter into a contract with you and for the continued provision of the Services, and our legitimate business interests in offering better Services to you and in continuing to cultivate our customer relationships.
Impello does not share user information, including Personal Information, with third-parties except in the following situations.
Government, Regulatory and Law Enforcement: Impello may share your Personal Information to comply with any court order, law or legal process, including to respond to any law enforcement or requests from regulators. Additionally, we may share your Personal Information as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Impello, our customers or others.
Sharing on Social Media & Messaging: By using the Services, you may choose to share Personal Information on message boards, chat-applications, profile pages, blogs and other similar services including, without limitation, our Social Media. Please note that any information you post or disclose through these services may become public and may be available to other users and/or the general public. The use or processing of the Personal Information by such services will be governed by their privacy policies.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information, including Personal Information, may transfer as part of such a transaction as one of the transferred assets as permitted by law and/or contract.
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing- related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
We have implemented appropriate physical, technical and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Payment transactions are conducted through our PCI compliant secure payment solutions providers. We cannot and do not guarantee the security of any information transmitted over the Internet. Once we receive your Personal Information, we take steps that we believe are commercially reasonable to limit access to your Personal Information to only those employees and service providers whom we determine need access to the Personal Information to provide the requested products, services, offers or opportunities that may be of interest to you. However, even after we receive your Personal Information, we cannot guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed as a result of a breach of our commercially reasonable efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your Personal Information is completely secure and safe from such risks. Where you’ve created a password to access the Services, you are responsible for keeping this password confidential. Please do not share your password with anyone. Any transmission of Personal Information is at your own risk. If you have reason to believe that any interaction you have with us is no longer secure, please immediately inform us.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
Impello and the Services are operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including Personal Information, will be transferred to and processed and stored in the United States.
Impello sometimes contracts with Enterprise organizations to provide Services to employees or other organizations or individuals. If your access or use of the Services is related to a contractual engagement between us and your employer, or any other third-party, that third party shall be considered the “data controller” under EU privacy law and any processing of Personal Information shall be governed by the terms of the third-party engagement.
Users located in the EU have certain rights under the GDPR. These rights include the right under certain circumstances to receive, correct, restrict or object to the processing of your Personal Information, including the right to object to marketing. Where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent at any time. You may also request that we delete your Personal Information; however, we may only do so if permitted by applicable law.
Additionally, we may need to request specific information from you to confirm your identity before processing your request. If we are unable to satisfactorily resolve your request and you are located in the EU, you may contact your local data protection authority for further information about your rights and our obligations in relation to your Personal Information, as well as assistance with any complaints about our processing of your Personal Information.
We do not rent, sell or share Personal Information about you with third parties who are not our partners or affiliates for their own direct marketing purposes unless you have opted-in to such a disclosure or were offered the opportunity to opt-out of such a disclosure at the time you provided your Personal Information and elected not to opt-out. California residents may, at any time, request disclosure or erasure of the categories and specific pieces of their personal information we have collected, as well as opt out of the selling of their information to third parties, by contacting us. We will do our best to process your request expeditiously, but we may require up to forty-five (45) days. Additionally, we may need to request specific information from you to confirm your identity before processing your request.
If you independently enroll in an educational program offered by Impello or any of its affiliates; you may have limited rights in addition to this Policy, under the U.S. Federal Family Educational Rights and Privacy Act (“FERPA”). You will have the right to limit access to certain directory information about you, as defined in FERPA. You may request to access or limit access to your directory information by contacting us
Our Services are not intended for children under sixteen (16) years of age. If you are under the age of sixteen, please do not use the Services or provide any Personal Information via a Website or App, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under sixteen without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under sixteen, please contact us
We want to ensure that the Personal Information we hold about you is accurate and up to date. We ask that you keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information that you have provided to us through your use of the Services. If you require assistance or have questions about unsubscribing from email or other communications.
If you have any questions about this Policy, please contact us. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Privacy — Terms of Service