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Privacy and cookie policy

At Impero (in the following us / we / Impero A/S or Impero) we respect your privacy. Security and compliance are a top priority for us. Whether you provide data or we collect it, Impero will always process the information in accordance with applicable rules and regulations. 

If you have any questions or queries regarding our data processing, you are always welcome to contact us here: 

Klamsagervej 27, 2
DK-8230 Åbyhøj
mail@impero.com
(+45) 70 22 53 64
Data Protection Manager (DPM) is Morten Christensen.

This Privacy Statement outlines your rights to privacy and our commitment to safeguarding your personal data when you:
– visit our website;
– visit our offices;
– receive marketing or sales communications from us, including emails, phone calls or texts;
– register or attend our events or webinars;
– apply for a job with us.

We also process personal data in the role of processor on behalf of Impero customers. Please contact your employer or us if your personal data has been submitted through the Impero platform and you want to know more.

 

Personal data we collect about you and how we collect it

We will collect and process the following data about you:

Information you give us

• When you complete a form or survey via our website, register for a demo or otherwise contact us to request information about our products and services, we will typically obtain contact information such as your name, employer, company email address and company telephone number.

• If you use our “chat” function or similar features, register for an event, webinar, or download certain content, we may require that you provide your contact information such as your name, company name, job title, address, phone number or email address.

• If you contact or correspond with us (for example, using any support function made available by us or if you are interested in our product or services) then we may keep a record of that correspondence (either directly or through our service providers).

• If you visit our offices, you may be required to register as a visitor and provide your name, email address, phone number, company name and time and date of arrival.

• If you apply for a job with Impero. 

Technical information

• If you use and interact with our webite and/or emails, we automatically collect information about your computer or mobile device for system administration and analysis, including for example your IP address, URL clickstreams, unique device identifiers, operating system, and network and browser type.

• We may also collect other information about your use of the website, including for example the pages you have viewed, the duration spent, and how you navigate through the website.

Information we receive from other sources. 

• We may also receive further personal data about you which is publicly available, such as your seniority, years of experience and employment history and similar work-related background, from third party services such as LinkedIn or from providers who provide contact enrichment and lead generation services to us.

• We work closely with third parties (including for example, business partners, subcontractors and analytics providers) and may receive information about you from them.  Details of third party providers are set out in the section below entitled “Who we share your personal data with”.

 

 

How we use your personal data

Where we have collected, received or generated personal data from or about you, we may use this for the purposes, and on the legal bases, as set out below.

Providing our website and services. We process your personal data to provide you with access to our website, support and services. We rely on our legitimate interest to operate and administer our website and to provide you with content you access and request (e.g., to download content from our website).

Promoting the security of our website and services. We process your personal data by tracking use of our website and services, creating aggregated, non-personal data, verifying users and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others.

Providing necessary functionality. We process your personal data to perform our contract with you for the use of our website and services; where we have not entered into a contract with you, we base the processing of your personal data on our legitimate interest to provide you with the necessary functionality during your use of our website and services.

Managing user registrations. If you have registered for an account with us on behalf of your employer (i.e. a potential customer of Impero), we process your personal data by managing your user account for the purpose of performing our contract with your employer for our services, e.g. a demo or free trial.

Handling contact and user support requests. If you use our “chat” function or request user support, or if you contact us by other means including via e-mail or a phone call, we process your personal data to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.

• Managing event or webinar registrations and attendance. We process your personal data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you.

Developing and improving our website and services. We process your personal data to track and analyze your use of our website and services to the extent it is necessary for our legitimate interest in developing and improving our website, ads and services and providing our users with more relevant content and services, or where we seek your valid consent.

Assessing and improving user experience. We process device and usage data as described in ‘Technical information’ above. Sometimes these data may be associated with your personal data, in order to analyze trends in order to assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving services, or where we seek your valid consent.

Identifying customer opportunities. We process your personal data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences.

Registering visitors to our offices. We may process your personal data for security reasons, and register visitors to our offices if we deem it necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access.

Displaying personalized ads and content. We process your personal data to conduct marketing research, advertise to you, provide personalized information about us – on and off our website. We provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our website, content and product or, where necessary, to the extent you have provided your prior consent.

For marketing and sales communications. We will process your personal data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing information, newsletters, telemarketing calls or SMS) about us and our affiliates and partners, including information about our products, promotions, content or events as necessary for our legitimate interest in conducting direct marketing or, alternatively, to the extent you have provided your prior consent (please see the “Your rights” section, below, to learn how you can control the processing of your personal data by Impero for marketing and sales purposes.

Processing job applications and recruitment. In general applicants are not requested to sign a consent statement. All data regarding applicants is deleted after ended recruitment processes. If deemed necessary to keep data on applicants after a recruitment process/from unsolicited applications, the applicants shall be requested to sign a consent statement distributed by the hiring manager.

Complying with legal obligations. We process your personal data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires processing or disclosure of personal data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our website, protecting personal property or safety, pursuing means available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

 

 

Who we share your personal data with

We may share your personal data with selected third parties in accordance with this Privacy Policy, including:

• subprocessors, service providers (for example of IT services), business partners and/or suppliers, in the course of undertaking marketing activities, including Microsoft, HubSpot and MailChimp, who provide marketing, referrals and CRM management, training, sales and delivery services.

• analytics and search engine providers that assist us in the improvement and optimisation of our marketing activities and the analysis of data supplied via the platform for contact enrichment and lead generation purposes, including Google, Hotjar, LinkedIn, Facebook, MailChimp and HubSpot; and

• government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons.

We require all our third party service providers and partners to take appropriate and stringent security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data to other third parties in the following circumstances:

• if we sell or buy any business assets or receive investment into our business, we may disclose your personal data to the prospective or actual buyer, seller or investee of such business or assets;

• if Impero or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your data and data about our customers, suppliers and correspondents will be one of the transferred assets;

• we may disclose your personal data to our legal advisers if they need to have access to this information in order to advise us on our legal rights and obligations; and

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or other contracts between us and you or your employer (if applicable); or to protect the rights, property or safety of us, our customers or others.

Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.

 

International data transfers

All of the data in the Impero platform, that our customers submit, is hosted within the EU. But some of our service providers for analytics, communication and support infrastructure are based outside the European Economic Area (“EEA”), predominantly in the United States.  We may transfer your personal data to those services providers in the United States or other countries outside the EEA in order to undertake marketing, sales and support activities.

We have put in place appropriate measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the EU laws on data protection, including putting in place written contractual agreements to meet EU-approved data protection obligations.  If you require further information about these protective measures, please contact us at mail@impero.com.

 

 

Security

We maintain appropriate technical and organizational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your information, we will use strict procedures and security features which are appropriate to the type of personal data you have provided to try to prevent unauthorized access or inadvertent disclosure, which may include two factor authentication and end-to-end encryption.

 

How long we keep your personal data

We will not store your personal data for longer than is reasonably necessary to use it in accordance with this Privacy Policy or with our legal rights and obligations.

We will retain your personal data for a period consistent with the original purpose of collection (see the “How we use your personal data” section above). We determine the appropriate retention period for personal data on the basis of the amount, nature and sensitivity of your personal data processed, the potential risk of harm from unauthorized use or disclosure of your personal data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

To avoid doubt: Aggregated and anonymised data and information other than personal data can be stored indefinitely.

 

Consent from you

Where consent is required for our use of your personal data, by ticking the appropriate consent box or otherwise communicating your consent to us (whether by phone, email or other means), you consent to our use of that personal data as set out in this policy. If you disclose someone else’s personal data to us, you confirm that you have their consent to disclose this to us and for us to use and disclose it in accordance with this policy.

 

Your rights  

You have the following rights in regards to your personal data:

Access. You have the right to access information about the personal data we hold about you. We reserve the right to charge a reasonable fee in response to unreasonable or repetitive requests, or requests for further copies of the same information.

Right to object to processing.  You can object to processing of your personal data where that processing is being undertaken by us on the basis of our legitimate interest (or a third party’s). In such cases we are required to cease processing your data unless we can demonstrate compelling grounds which override your objection.  You can alsoobject at any time to the processing by us of your personal data for direct marketing purposes.

Rectification. You have the right to request that we rectify any inaccurate personal data that we have about you.

Erasure. To the extent permitted by applicable data protection laws, you have the right to request that we erase any personal data that we hold about you, based on one of a number of grounds, including the withdrawal of your consent (where our processing of that data is undertaken on the basis of your consent), or if your object to our continued processing (as mentioned above). This right does not extend to information which is not personal data. We also reserve the right to retain your personal data in an anonymised form for statistical and benchmarking purposes.

Request to restriction of processing. This enables you to ask us to restrict the processing of your personal data in certain circumstances, for example if you want us to establish its accuracy or the reason for processing it.

Portability. You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies. 

Automated processing. Not to be subject to a decision which produces legal effects based solely on automated processing, including profiling, (“Automated Decision-Making”) without your explicit consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) in accordance with applicable data protection laws. However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Or we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

To update billing information on behalf of your employer (where your employer is an existing Impero customer), discontinue your account and/or request return or deletion of your personal data or to exercise any of your other rights, please contact us by emailing mail@impero.com. Please allow at least 7 working days for your request to be actioned.

 

Your preference for email and SMS marketing communications

If we process your personal data for the purpose of sending you marketing communications, you may manage your receipt of marketing, sales and non-transactional communications from Impero by clicking on the “unsubscribe” or “update subscription preferences” link located on the bottom of Impero sales and marketing emails, by unsubscribing if you receive Impero SMS communications, or by writing to us at mail@impero.com.

Please note that opting out of marketing communications does not opt you out of receiving important service communications related to your current relationship with us, such as communications about any contract you have entered into with us, event registrations, service announcements, customer support or security information.

 

Our Cookie policy

For the pages to be displayed properly in your browser, the IP address and other information about the browser of the end device user must be processed. We use cookies and tracking to support our website and applications. Read on to find out more about why we use them and how they work. 

 

Cookies

We use cookies on our website and applications. 

 

What are cookies? 

Cookies are small text files that that are stored in your computer or device via your browser. These cookies are necessary to enable certain functions of this website and to increase user friendliness. This enables our system to recognize your browser and capture and remember certain information. We use cookies to compile and aggregate data about website and platform traffic and interaction so that we can offer you a better experience and tools in the future. Please note that cookies cannot see personal information about you such as name or specific location. Cookies do not install nor launch any programs or other applications on your computer.

 

Cookie consent

The first time you visit our website, you will see a banner with cookie information and a ‘read more’ option, which takes you to this page. If you would like to opt out of cookies, most web browsers will allow you to delete and/or choose which sources you accept cookies from. Therefore, you can follow the instructions for cookie controls provided by your hosting web browser if you want to change your cookies. You should be aware that by opting out of cookies, most services and features become unusable. 

 

If you make your choice in our banner on which cookies to accept, the cookies are set according to your choice.  You can find more information about each individual cookie we use and the purposes for which we use them, by clicking in the cookie-banner, which will bring up a list. 

 

Advertising

Cookies and other technologies are also used for advertising purposes. These assist us in targeting advertising to users who we believe are interested in Impero and our solution. These cookies may be set through our website by third parties. Cookies set by Impero on our own website are called first party cookies. We also use third party cookies, which are cookies from a different domain to the website you are visiting, for our advertising and marketing efforts. 

 

 

Changes to this privacy and cookie policy  

Any changes we may make to our Privacy Policy will be posted on this page and where appropriate may be notified to you by email. Continued use of the website will signify that you agree to any such changes.

How to contact us

We have appointed a data protection manager (“DPM”) who is responsible for overseeing questions in relation to this Privacy Policy. You can contact our DPM by emailing mc@impero.com or writing to us at: Impero Data Protection Manager, Klamsagervej 27, 2., 8230 Åbyhøj, Denmark.

We are committed to resolving any privacy concerns you have. However, if you feel we have not addressed your specific concern, you have the right to make a complaint at any time to the relevant supervisory authority in your country responsible for data protection issues.

 

Updates

This privacy policy and cookie policy is updated when deemed necessary. It was last updated 15 January 2020.