Your privacy is important to you and to us, and we are committed to protecting your privacy. This policy was created in order to comply with the Privacy Act (1974), the Personal Information Protection and Electronic Documents Act (PIPEDA), and any other relevant legislation. To the extent there is additional protection afforded to you pursuant to the law, which is not set forth herein, we agree to take such measures to give full effect to such additional protection.
Safe Harbor-Compliant Affirmative Commitment
InMoment complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce in consultation with the European Commission and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce in consultation with the Federal Data Protection and Information Commissioner of Switzerland regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. InMoment has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor Frameworks, and to view InMoment’s certification, please visit http://www.export.gov/safeharbor/.
InMoment’s Clients and How This Relates to Your Privacy
What is Personal Information?
Personal Information is information about an identifiable individual. It may include your full name, address, zip code, telephone number, date of birth, email address, demographic/classification information (e.g. education or age), and any other information that identifies who you are or would allow someone to contact you. It also may include client program membership or loyalty numbers. Your contact information may be used as required to follow up on your feedback so you can be contacted by client employees or representatives. Personal Information only becomes known to InMoment when you voluntarily provide it to us, or it is provided to InMoment by the InMoment client that invited you to take a survey.
Collection and Use of Personal Information
We will not collect any Personal Information from you that you do not volunteer. Participation in surveys or other data collection is completely voluntary and you have a choice whether or not to respond and whether or not to disclose any requested information. We do not sell, share, or rent Personal Information to third parties unless you expressly agree to have InMoment share your Personal Information as described below.
Telephone ANI Visibility
When you dial a toll-free number in the United States, the party you are calling pays for the call. The called party is able to identify your telephone number using a telephone network technology called Automatic Number Identification (ANI). FCC rules limit parties that own toll-free numbers from distributing the telephone numbers identified through ANI and require telephone companies to inform customers that their telephone numbers are being transmitted to toll-free numbers in this way. If you take a InMoment telephone survey, both InMoment and its clients may have access to your ANI, but, per FCC rules, will not distribute that telephone number further.
IP Addresses and Cookies
Using and Sharing Personal Information
The following paragraphs describe in more detail how InMoment may use your personal information in specific circumstances. Depending on the specific interaction you have with InMoment, one or more of the following may apply.
Assistance to Complete a Survey
In certain circumstances you may require assistance from InMoment to complete a survey. If the survey is being administered by telephone, you may be required to leave a voice message. If the survey is being administered online or by other text media, you may be asked to post a message to InMoment using an e-form or e-mail. Personal Information may be required. In this case, the Personal Information will only be used to contact you for the intent of resolving their difficulty in accessing and completing a Survey.
Promotional and Incentive Contests
InMoment or its clients may offer various promotions, incentives, or sweepstakes from time to time. When entering a promotional contest, we, our client, or our client’s fulfillment vendor may ask for your name, date of birth, address (e-mail and/or residential), financial information (such as income level), or phone number so that we may communicate with you in the event you are a winner.
Our Sites’ contact forms may request your name and contact information, potentially including telephone numbers. An email address is required to post a message to InMoment using an e-form.
For certain surveys and other opt-in services, InMoment may collect profile (e.g. personal interests) and demographic information (e.g. household income, etc). This information will be used to communicate specific information to you based on the profile and demographic information you provide. Some surveys and opt-in services offer visitors the option of participating in additional surveys or receiving information from InMoment or from a InMoment client or business partner. Visitors must opt-in if they wish to participate or receive such information, and if they do, their Personal Information may be used by InMoment and/or shared with a client of InMoment or business partner for that purpose.
Fulfilling Your Transaction Request
If you request something from a InMoment web site, for example, a product or service, a whitepaper, a callback, or specific marketing materials, we will use the information you provide to fulfill your request. To help us do this, we may share information, with others, for instance, other parts of InMoment and business partners involved in the fulfillment. If you request information about our products or services, we may follow up with you in the future with additional information that we think may be of interest to you. You will always have an opportunity to opt out of receiving such communications. In connection with a transaction, we may also contact you for market research purposes.
The Sites may make chat rooms, forums, message boards and/or news groups available to its visitors. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.
If you register for a subscription (e.g. to a newsletter or other communication) we will use the registration information that you submit to process your request. We will keep this information in a database. In addition, we may contact you about future publications and InMoment services that may be of interest to you. You will always have an opportunity to opt out of receiving such communications.
Disclosure of Aggregate Information
InMoment reserves the right to use non-personal customer and/or employee data in aggregate for the purposes of generating “norms” and industry benchmarks, etc.
If you submit a job application to InMoment, we may use the Personal Information that you supply, such as your email address and phone number, to contact you about possible job openings. We may also contact previous employers and references, unless you instruct us not to.
Disclosures Required by Law
New Use of Personal Information
Should InMoment wish to use your Personal Information for a purpose not contemplated at the time of initial collection, such as additional services, products, or promotional offers that may be of interest to you, we will use your contact information, including your email address, to ask for your consent to use your Personal Information for the new purpose.
Our phone systems and web servers do automatically recognize some non-personal information. Specifically, when you visit InMoment Sites, we collect information regarding:
- your Internet location (IP address)
- the software (and its configuration) you use to visit our site
- the dates and times you visit our site
- the pages you visit on our site, and
- other, non-personal information, which we use to analyze our web traffic and administer our servers.
Links to Third-Party Sites
Security, Storage, and Retention of Information
The Sites (including, but not limited to: websites, surveys, reporting applications, and data transfer applications), have commercially reasonable security measures consistent with industry standards in place to protect against the loss, misuse and interception of information by third parties. InMoment holds its physical hosting facilities to these same standards. Nevertheless, InMoment assumes no liability for interception, alteration or misuse of information transmitted over the Internet.
InMoment imposes strict internal controls over employees with access to Customer Information. Such access is granted only on a need-to-know basis.
InMoment will retain Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) will remain valid after termination of our interaction with you.
Our Worldwide Practices
InMoment conducts business globally, with people, processes, and systems that cross borders. Our privacy practices are designed to provide protection for your Personal Information, all over the world. Some countries may provide less legal protection for your information. In such countries, InMoment will still handle information in the manner we describe here.
How to Correct or Update Your Personal Information
If you need to correct or update your Personal Information registered with us, contact the privacy officer and use “personal profile update” as the subject of the message. Please make sure to include your previously registered name, address, email address and phone number along with any new Personal Information in the body of the message. InMoment will record your Personal Information change in our web database and will make this change available to our proper business groups.
We created GoRecommend to make it easy for you to recommend product and service brands and locations to your friends on Facebook. Use of GoRecommend often requires you to share with us and other users certain Content that you have provided to us. In addition, portions of your Account Information such as your Facebook account name may be associated with your Content. However, we understand you may not want everyone in the world to have all the User Information available to GoRecommend. As such, through your Facebook account settings, you control what User Information is made available to GoRecommend, including your contact and personal information, pictures and interests.
All use of GoRecommend takes place through Facebook and involves use of User Information that is made available by Facebook for use by GoRecommend and involves the use Content that you input through your use of GoRecommend. For further information about safe use of Facebook, see Safe Use of Facebook: https://www.facebook.com/terms.php.
Collection and Use of User Information and Content
When you install and use GoRecommend, we are provided access to various types of your personal information including:
1. Personal information that you knowingly disclosed to Facebook in your Facebook account and that you allow to be provided through your Facebook Privacy Settings, which may include your name, your email address, your telephone number, your address, your gender, schools attended, and any other personal or preference information provided to Facebook and made available by Facebook to GoRecommend (referred to as “Account Information”);
2. When you use GoRecommend in any way, you may send messages, refer friends to GoRecommend, post comments and other materials, and otherwise transmit information through various channels, all of which is collected and stored by us (referred to as “Content”);
3. We may also collect information about you from outside sources and other users of the Application (referred to as “Public Information”).
All of the above is collectively referred to as “User Information”.
By using GoRecommend, you consent to have your User Information transferred to, stored, and processed in Canada and the United States of America, and you consent that User Information may be used in any of the following ways:
1. We may occasionally use your User Information to send you notifications regarding new services or applications offered by us and to notify you whether you have been selected as a contest winner in any sweepstakes or promotional contest that we may operated from time to time and for which you are eligible to enter.
2. We may send you announcements from time to time through the general operation of GoRecommend or Facebook. Generally, you may opt out of such emails by sending an emailing to firstname.lastname@example.org specifying that you wish to opt out and indicating your Facebook user name. However, we reserve the right to send you notices regarding your specific use of GoRecommend even if you opt out of all voluntary email notifications.
3. We may use your User Information without identifying you as an individual to third parties. We do this for purposes such as aggregating how many people in a network use GoRecommend.
4. We may use Public Information to make GoRecommend more beneficial and customized to you. If you do not want to this to be done or would like us to take other actions that limit the use of such Public Information, please email us at email@example.com specifying that you wish to opt out and indicating your Facebook user name.
5. We do not provide contact information to third party marketers without your permission. We share your User Information with third parties only in limited circumstances where we believe such sharing is (1) reasonably necessary to offer GoRecommend, (2) legally required, or (3) permitted by you. Without limiting the generality of the foregoing, for example, we may provide User Information to service providers to help us offer and operate GoRecommend. Specifically, we may use third parties to facilitate our business, such as to host the User Information at a co-location facility for servers, to send out email updates about GoRecommend Application, to remove repetitive information from our User lists, to process payments for products or services, to offer an online job application process, or to provide search results or links (including sponsored links). In connection with these offerings and business operations, our service providers may have access to your User Information for use for a limited time in connection with these business activities. Where we utilize third parties for the processing of any personal information, we implement reasonable contractual and technical protections limiting the use of that information to GoRecommend specified purposes.
6. Since GoRecommend is considered a platform application of Facebook, you may also opt-out of any sharing of certain of the Account Information through the Privacy Settings of your Facebook account. You can report to Facebook any suspected misuse of information that occurs as a result of GoRecommend and they will investigate such claim.
7. We may be required to disclose User information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal User Information until we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. Additionally, we may any other information about you in our possession or control when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through GoRecommend, to protect improper use of our company or product names, or to prevent imminent bodily harm. This may include sharing information with Facebook officials, police, other companies, lawyers, agents, or government agencies.
8. GoRecommend may permit you to share User Information with marketers or other companies who are offering services through GoRecommend. You will be able to know when another company is involved in any service provided on GoRecommend Application, and we may share User Information with that company in connection with your use of that service offered by such company.
Third Party Advertisements
We take appropriate precautions to protect your User information and we have reasonable security measures in place to protect against the loss, misuse and interception of User Information by third parties. However, we assume no liability for interception, alteration or misuse of User Information transmitted over the Internet.
We cannot control the actions of other Users with whom you may choose to share Content and User Information. Therefore, we cannot and do not guarantee that any Content you post or User Information made public from you as a result of your use of GoRecommend will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained in GoRecommend or Facebook. You understand and acknowledge that, even after removal, copies of Content may remain viewable in cached and archived pages or if the other Users have copied or stored your Content. We collect and retain Content and User Information so that we can provide you the features of GoRecommend and to offer personalized features.
If you become aware of any third party that is collecting or misusing any Content or User Information please contact us at goRecommend@empathica.ca any provide us with particulars so that we may investigate and take appropriate action.
Referrals and Privacy
If you choose to refer friends to use GoRecommend, we will ask you for information needed to send your friends an invitation to use GoRecommend, such as the friend’s Facebook account name, their name, and email address. We will automatically send your friend a one-time email or message through Facebook inviting him or her to install GoRecommend and we may indicate that you have referred such person to us. We store the information you have provided to us so that we can send this one-time invitation and to track the number of referrals. Your friend may contact us at firstname.lastname@example.org to request that we remove this referral information from our database.
InMoment does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use GoRecommend. If you are under 13, please do not attempt to install or use GoRecommend, or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 should provide any personal information to us through GoRecommend. In the event that we learn that we have collected personal information from a child under 13 without verification of parental consent, we will delete that information as quickly as possible. However, we have no obligation to search for, confirm, or identify such information. If you believe that we might have any information from or about a child under the age of 13 please contact us by email at email@example.com and provide particulars of the situation.
Privacy Questions and Access
If you have questions or suggestions about this privacy statement, the practices of our Sites, or an account of the use that has been made with your information or your interactions with InMoment, simply contact the following:
Privacy Officer Contact:
Privacy Officer Address:
Attn: Privacy Officer
310 East 4500 South, Suite #450
Salt Lake City, Utah 84107