Effective Date: 29 July 2020
Collecting and Using Your Personal Data
Personal Data. While using IEM Services, we may ask you to provide us with certain Personal Data that can be used to contact or identify you. Personal Data may include without limitation your first name, last name, e-mail address, telephone number, and address, including city, state, province, and postal code.
Use of Your Personal Data. IEM may use your Personal Data to:
- Provide and maintain IEM Services, including monitoring the usage of IEM Services.
- Manage your account or registration as a user of IEM Services.
- Comply with and perform under any contract with us.
- Contact you regarding updates or informative communications related to IEM Services, including security updates when necessary or reasonable for their implementation.
- Provide you with news, special offers, and general information about other products, software, or services that we offer unless you have opted not to receive such information.
- Attend and manage your requests to us.
We may share your Personal Data:
- With Service Providers to monitor and analyze the use of IEM Services or to contact you.
- In connection with, or during negotiations of, any merger, acquisition, financing, or asset sale of all or a portion of our business.
- With other users when you share personal information or otherwise interact in public areas or with other users.
Security of Your Personal Data. The security of your Personal Data is important to us, but no method of transmission over the Internet or method of electronic storage is absolutely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Processing Your Personal Data
Service Providers have access to your Personal Data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may use Service Providers to monitor and analyze the use of IEM Services. We may use your Personal Data to contact you with information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any communications we send. We may use Service Providers to manage and send communications to you.
General Data Protection Regulation Privacy
For the purposes of the General Data Protection Regulation (“GDPR”), IEM is the Data Controller; you are the Data Subject or the User; Service Providers are Data Processors; and Personal Data means any information relating to you, 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.
Legal Basis for Processing Personal Data under GDPR. We may process Personal Data under the following conditions:
- Consent. You have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a Contract. Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal Obligations. Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
- Vital Interests. Processing Personal Data is necessary in order to protect your vital interests or those of another natural person.
- Public Interests. Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
- Legitimate Interests. Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing and, in particular, whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.
- Request Access to Your Personal Data. You have the right to access, update, or delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
- Request Correction of the Personal Data that We Hold About You. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to the Processing of Your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation that makes you want to object to our processing of your Personal Data on these grounds. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request Erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
- Request the Transfer of Your Personal Data. We will provide to you, or to a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Your Consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of IEM Services.
Exercising Your GDPR Data Protection Rights. You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If you are in the European Economic Area, please contact your local data protection authority for more information.
California Consumer Privacy Act Privacy
- Right to Notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
- Right to Access/Right to Request. You may request and obtain from us information regarding the disclosure of your Personal Data that has been collected in the past 12 months by us to a third party for the third party’s direct marketing purposes.
- Right to Say No to the Sale of Personal Data. You have the right to ask us not to sell your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” web page. Sale, for the purposes of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means a Consumer’s Personal Data to another business or a third party for monetary or other valuable consideration.
- Right to Know About Your Personal Data. You have the right to request and obtain from us information regarding the disclosure of the following: the categories of Personal Data collected; the sources from which the Personal Data was collected; the business or commercial purpose for collecting or selling the Personal Data; categories of third parties with whom we share Personal Data; and the specific pieces of Personal Data we collected about you.
- Right to Delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
- Right Not to Be Discriminated Against. You have the right not to be discriminated against for exercising any of your Consumer’s rights, including denying goods or services to you; charging different prices or rates for goods or services, using discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; and suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. For the purposes of the CCPA, Consumer means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the United States for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the United States who is outside the United States for a temporary or transitory purpose.
Exercising Your CCPA Data Protection Rights. In order to exercise any of your rights under the CCPA, and if you are a California resident, you can e-mail us or visit our “Do Not Sell My Personal Information” web page. We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Do Not Sell My Personal Information. We do not sell personal information. However, the Service Providers we partner with may use technology on IEM Services that “sells” personal information as defined by the CCPA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under the CCPA, you can e-mail us or visit our “Do Not Sell My Personal Information” web page.
“Do Not Track” Policy as Required by California Online Privacy Protection Act
IEM Services do not respond to Do Not Track signals. However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your browser.
IEM Services do not address anyone under the age of 13. We do not knowingly collect Personal Data from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.
California Privacy Rights (California’s Shine the Light Law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light Law, you can e-mail us.
California Privacy Rights for Minor Users
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
All information on IEM Services—including without limitation all design, text, images, news releases, and other documents—is subject to copyright protection under United States and other copyright laws and is owned by IEM or used under license from the copyright owner. Permission is granted to view and print materials for the non-commercial purpose of viewing, reading, and retaining for reference. Any other copying, distribution, retransmission, or modification of information or materials on IEM Services, whether in electronic or hard copy form, without express prior written permission of IEM is prohibited.
IEM’s registered marks, trademarks, logos, taglines, and images used in IEM Services are the property of IEM and may not be used without expressed written permission from IEM. Other product or company names may be the trademarks or service marks of their respective owners.
Linking to IEM Services
All links to IEM Services must be approved in writing by IEM. All approved links must point to the location specified by IEM and, when activated by a user, display that page full-screen in a fully operable and navigable browser window and not within a frame on the linked website. IEM reserves the right to revoke this consent to link at any time at our sole discretion.
All IEM Services are presented “as is,” without any representation or warranty, express or implied, including the implied warranties of merchantability, fitness for a particular purpose, and non-infringement of intellectual property. IEM does not warrant the accuracy or completeness of the materials or the reliability of any advice, opinion, statement, or other information displayed or distributed through IEM Services.
Neither IEM nor any party involved in creating, producing, or delivering IEM Services will be liable for any damages, including without limitation direct, incidental, consequential, indirect, or punitive damages arising out of access to, use of, or inability to use IEM Services, or any errors or omissions in content. This limitation applies to damages to, including viruses that infect, your Device.
In no event shall IEM be liable to any party for any direct, indirect, special, consequential, or other damages (including without limitation damages for lost profits, lost data, or business interruption) that are related to the use of or the inability to use IEM Services or the content, materials, and functions of IEM Services, even if IEM has been expressly advised of the possibility of such damages.