Privacy and Cookie Policy

Effective September 16, 2022.

Impetus Technologies Inc. & Impetus Technologies India Pvt. Ltd. (“We” or “Impetus”) understands that data privacy is paramount to our business. This Privacy Policy describes the types of Personal Information we may collect, how we may use and share that information, and how we protect it. By using, accessing, or purchasing our applications, products/services, and/or websites (the “Product/Service”), you agree to the terms and conditions of this Privacy Policy.

“Personal Information” is any information, whether correct or not, and whether recorded in a material form or not, that relates to you and which, alone or in combination with other information, could reasonably be used to identify you. However, it does not include publicly available information lawfully made available to the public from federal, state, or local government records.

We may make changes to this Privacy Policy from time to time. Therefore, we will indicate the most recent updated date at the top of the Policy and highlight any significant changes to the Policy.

Information we collect

We collect/ receive your Personal Information in multiple ways, depending on which product/service, applications, or websites you use and how you interact with us.

Information you provide, and we collect from other sources

You may choose to share personal and additional information with us by purchasing or interacting with our “Product/Service,” through various means including, but not limited to:

When you create and manage a user account regarding any of our products/services
Request technical support from us
Request any information as a prospect
Communicate via email, telephone, or online chat
Upload information through our “Product/Service”
Subscribe to our newsletter
Submit job applications
Participate in surveys
Participate in tradeshows

For some “Product/Service,” we may ask you to provide information, including:

Basic personal details (e.g., your name, title, and gender)
Contact details (e.g., your email address, postal address, and phone number)
Professional details (e.g., the name of your organization and any professional organization memberships)
Any other personal information you choose to provide us (e.g., in communications with technical support services, marketing teams, or while provisioning our products/services)

If you are an internal stakeholder (employee, contractor, freelancer etc), we may also seek your consent to process:

Bank account information (for payroll processing)
Criminal records (from background verification process)
Academic qualifications, Professional details (for interviews)
Identity data (National Unique identifier (Aadhar), PAN data, Passport information)

We may also collect this information indirectly from publicly available sources (such as your employer’s website or professional social networks such as LinkedIn) or third-party data providers that maintain individuals’ contact information lists.

Information we collect

When you access or use our “Product/Service,” we may collect certain information about your device and your use of our “Product/Service.” Such information may include:

Name and Version information about the web browser
Date/time stamp of your visit to our website(s)
Products/services you purchased, with related pricing
If you are using a mobile device, the model of the device and its operating system
Crash data
Your I.P. address
Information about your usage of our website including what pages you use, the frequency of your use, links that you click, and how often you log in

Cookies and similar technologies

We may collect certain information by automated means when you use our websites, such as cookies. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser and store information or settings on the device. The information we collect enables us to serve the returning visitors better. For example, it can “remember” and auto-populate your email address in the future. We also use cookies to track responses to our marketing materials, such as emails and online advertisements. In addition, your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies.

Some of our websites also use marketing automation technology (Pardot) to collect data on visitors’ behaviour. These Pardot cookies help us track your visits to our websites and enable us to create an engaging marketing experience for you. We also use Pardot cookies to understand your interactions with our emails and ensure we send you relevant information. Specifically, Pardot cookies let us know whether you have opened our emails or which links are clicked. Please click here for more information on Pardot’s privacy and cookie policy.

Some of our websites may also feature cookies associated with certain unaffiliated companies. By engaging with such other companies’ sites, for instance, by clicking the Facebook “Like” button found on our website, such companies may place session or persistent cookies on your device. This may allow these third parties to collect information about your online activities over time and across websites. The use of these cookies is subject to such third-parties cookie policies, which we strongly recommend you review.

Web analytics and interest-based advertising

We may use web analytics services on our websites. The service providers that administer such services use cookies to help us analyze how visitors use the site. The information collected through these means (including I.P. address) is disclosed or collected directly by these service providers, who use the information to evaluate the use of the website or for advertising purposes, as described below.

Some of our online advertising takes place through Google Display Advertising. As a part of this program, we use Google Analytics features such as Retargeting. We and the operators of these ad networks, including Google, may use third-party cookies (such as the DoubleClick cookie) – and in some cases first-party cookies (such as the Google Analytics cookie) – to inform, optimize, and serve ads across the internet based on a user’s past visits to our website.

You can opt-out of Google Analytics for Display Advertising or customize Google Display Network ads using the Google Ads Preferences Manager. To disable Google Analytics in general, please download the browser add-on to deactivate Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout. To learn more about other ad networks, including how to opt-out, click here.

Do not track

Some web browsers and mobile devices incorporate a “do not track” feature that signals to websites and online services that you do not wish to be tracked when enabled. However, because there is no accepted standard for responding to the do-not-track signal, we do not recognize or respond to these signals.

How we use the information we collect

We may use the information we collect from you to:

Provide products/services to you
Bill/invoice you
Manage any accounts that you may have with us
Validate your identity
Send personalized marketing messages via email, post, and telephone. Where required by applicable law, we will only send these messages with your consent, and you have the right to opt-out of receiving marketing messages by contacting us
Serve relevant advertising on our site and third-party sites related to our products and services personalized to your interests
Provide you with notice of product releases, special events, training, promotions, or other matters relevant to you
Respond to your inquiries
Improve the services you receive from us
Solicit your feedback
Prevent you from having to re-enter Personal Information about you on future visits to our websites or subsequent use of our applications
Facilitate your access to third-party services and resources
Operate, evaluate, and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing, and other internal functions)
Detect and prevent fraud and other unauthorized activity and enforce our terms of use
Comply with applicable legal requirements, relevant industry standards, and our policies

We also use the information we obtain about you in other ways to provide specific notice at the time of collection.
If you are an individual in the E.U., we may be required to have a legal basis to process your Personal Information for these purposes under applicable E.U. law. Therefore, we may ask for your consent in certain circumstances as indicated above, but if we do not ask for your specific permission:

We use your Personal Information for specific purposes as it is necessary to comply with contractual obligations we have to you, including when we provide our “Product/Service” to you following the applicable terms and conditions
We may also use Personal Information to comply with our legal obligations, such as financial reporting obligations and compliance with subpoenas or similar court orders or orders of government/statutory/federal agencies
Where not strictly required by contract or by law, we use Personal Information to:
- Meet our legitimate business interests (when your data privacy rights do not override the use) in running our business efficiently
- Advertise our products and services to existing and prospective customers
- Understand how our business is performing
- Defend our interests and legal rights
- Keep our records accurate and up to date

We take steps to ensure that your Personal Information is not used in ways other than those you would expect, and subject to laws in the country where you live, you have the right to object to our uses of Personal Information on this basis.

How we may share information

Internally, Personal Information is shared for legitimate business purposes, such as managing our relationship with you and other external parties, compliance programs, or systems and network security. We do this to improve efficiency, save cost and collaborate internally between our subsidiaries. Our internal access to Personal Information is restricted and granted only on a need-to-know basis. Sharing this information is subject to the appropriate intracompany arrangements, policies, and security standards.

In certain circumstances, Personal Information may be subject to disclosure to government agencies in accordance with judicial proceedings, court orders, or legal processes. We may also share Personal Information to protect the rights of Impetus or others when Impetus believes that such rights may be affected, for example, to prevent fraud.

How we protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the Personal Information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

We also ensure that we do not retain Personal Information longer than necessary in compliance with applicable law. When Personal Information is no longer needed, we have processes to securely delete it, for example, by erasing electronic files and shredding physical records.

Links to other websites

Our website may contain links to websites maintained by third parties whose information and privacy practices differ from ours, including, for example, websites that process online payments. We are not responsible or liable for the content of any such websites, any use of such websites, or the information or privacy practices employed by the providers of such websites. We encourage you to read the privacy statements of all third-party websites before using such websites or submitting any Personal Information or any other information on or through such websites.

Not for use by children

The Services are not directed to, and we do not knowingly contact or collect Personal Information from individuals under the age of 16 years. Therefore, if you are under the age of sixteen, these Services are not intended for you, and you should not provide us with any Personal Information.

Access and correction and option to unsubscribe

To request a copy of the Personal Information, update or correct inaccuracies in that information, or request to remove your information from our systems and stop contacting you, please email privacy@leaplogic.io with a detailed request, including your full name, physical address, and email address. You also have, in particular circumstances, the right to object to or restrict our usage of your Personal Information and the right to have personal data transmitted in the electronic form to you or a third party (the right of “data portability”).

How to contact us

If you have any comments or inquiries about this Privacy Policy, would like to update your information, or exercise your rights, send an email to privacy@leaplogic.io.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. However, if you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country in which you live via their Website.

This Policy will be governed by and construed according to the laws of the United States of America and by the laws of the State of California /India and by the law of court of Indore, subject to the jurisdiction of the Courts at Indore.

FOR EU RESIDENTS – DATA PRIVACY RIGHTS

Below is an overview your various rights granted by EU-GDPR

You have the right to access to the personal data we hold about you.
The correction of your personal data when incorrect or incomplete.
The deletion of the data we hold about you, in specific circumstances. For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
Restriction of the use of your personal data, in specific circumstances, generally whilst we are deciding on an objection you have made.

You may also ask us:

That we stop processing your personal data, in specific circumstances. For example, when you have withdrawn consent, or object for reasons related to your individual circumstances. Please be advised, however, your employer may reasonably object as the customer having direct contract relationship with us, and we reserve the right to notify your employer or organization of such as request and advise them that removal may impair the intended use or enjoyment of our product and services functions.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Right to Stop Direct Marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

This right does not include communications and information functions, such as alerts and notices, which are displayed in any application or product interface of ours which is part of the operation of or relates to a normal function of our product. By logging into our products or services, you are expressly giving your consent for such purposes. If you disagree with that then do not log-in or use our products or services.

You can contact us and request to exercise these rights at any time by sending an email to privacy@leaplogic.io.

If we choose not to honour your request to exercise data privacy rights, we will explain the reasons for our refusal.

PRIVACY NOTICE AND DISCLOSURES FOR CALIFORNIA RESIDENTS

This section applies solely to the personal data of users (i.e., a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017, however identified, including by any unique identifier) (“You“) and supplements the information contained in our Privacy Policy. We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA), and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices: The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to specific information and Data portability rights: You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you: (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting or selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information, if any; (v) the specific pieces of Personal Information we collected about you (also called a data portability request); (vi) if we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion request rights: You have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the Personal Information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion rights: To exercise the access, data portability, and deletion rights described above, please email a valid consumer request to privacy@leaplogic.io.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for access or data portability twice within 12 months. A valid consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collect Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Therefore, we will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response timing and format:We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover 12 months preceding the verifiable consumer request’s receipt. The response we provide will also explain why we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine that the proposal warrants a fee, we will tell you why we decided and provide you with a cost estimate before completing your request.
Non-discrimination:We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you Products or services; (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggests that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you specific financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website with an effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.