Table of Contents
- Personal information you give to us
- When you use our websites. We may collect any personal information that you choose to send to us or provide to us, for example, on our “Contact Us,” “Request a Demo” or similar online form. If you contact us through our websites, we will keep a record of our correspondence.
- When you use our services. When you use our services, we collect personal information, such as names, e-mail addresses, postal addresses, phone numbers, and job titles, in order to provide you with the services. We also collect information related to the actions you have taken in our applications.
- Support/Professional Services/Training If you engage us for support, professional services or participate in training, you may request such services directly from us in which case we collect your name and contact information directly from you. You may, alternatively, sign up for such services – or be signed up for such services – by or through a third party such as one of our certified partners, or your own employer. We may also use independent contractors to conduct the services and third parties to provide the training venues. Your personal information will be stored in our database and may also be shared with our certified partners, trainers, and/or the venue hosting the event (to verify your identity when you arrive). Our certified partners, trainers, and training venue hosts have agreed not to share your personal information with others and not to use your personal information other than to provide you with our products and services.
- Certification When you sign up to take one of our certification exams, we will collect your name and contact information. We will also collect and store personal information you provide to us about your need for special accommodations. This personal information may be shared with our computer-based exam hosting service. The computer-based exam hosting service may also share with us personal information you provide to them to verify your identity in taking the exam. We will collect your exam results and, in conjunction with maintaining your certification(s), your record of participation in continuing privacy education. Only authorized employees within the iManage companies have access to your certification exam scores and personal information pertaining to any special accommodations you may request.
- Correspondence with the iManage companies (including job applicants) If you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the personal information contained in it and use it to respond to your inquiry (including job applications); to notify you of conferences, publications, or other services; or to keep a record of your complaint, accommodation request, and the like. As always, if you wish to have us refrain from communicating with you, please contact us at firstname.lastname@example.org.
- Live events and web conferences We host many in-person conferences and live web conferences throughout the year (collectively, “events”). We will collect your name and contact information, which we will store in our database(s) and use to provide you with information and services associated with the event.
- Publications You may wish to subscribe to our publications without becoming a user of our services. To receive our newsletters by email, you will need to create a “profile” with us which involves providing us with at least your first name and last name and email address. We do not share this personal information with any third party other than to store the personal information in our databases.You may manage your subscriptions by subscribing or unsubscribing at any time. If you have any difficulties managing your email or other communication preferences with us, please contact us at email@example.com.
- Personal information we get from third parties. From time to time, we receive personal information about individuals from third parties. This may happen if your employer is a user of our services and signs you up for training, certification, support, or an event. One of our third-party partners may also share your personal information with us when you sign up for services through that partner.We also collect personal information from publicly or commercially available sources that are deemed credible. Such personal information may include your name, address, email address, preferences, interests, and demographic/profile data. The personal information we collect from public or commercial sources may be used along with the personal information we collect when you visit our websites. For example, we may compare the geographic information acquired from commercial sources with the IP address collected by data collection tools to derive your general geographic area.
- What happens if you don’t give us your personal information.You can enjoy many of our services without giving us your personal information. Much of the information on our websites is available even to those who are not our users. Some personal information is necessary so that we can supply you with the products or services you have purchased or requested, and to authenticate you so that we know it is you and not someone else. You may manage your subscriptions and you may opt-out of receiving marketing communication at any time.
The following sections provide additional information about commonly-used web technology tools.
- Web beacons. Our websites and third-party web pages, applications, and HTML-formatted email use web beacons alone or in conjunction with cookies to compile information about your website usage and your interaction with email, as well as to measure performance on our websites and applications. A web beacon is an electronic image, called a single-pixel (1×1) or clear GIF. Web beacons can recognize certain types of information on your computer such as cookies, the time and date of a page viewed, and a description of the page where the web beacon is placed. Depending on the context, web beacons may also refer to content on a third-party server, and may be used by service providers to deliver relevant advertising to you.You may be able to disable web beacons in email messages by not downloading images contained in the message you receive (this feature varies depending on the email software used on your personal computer). However, doing this may not always disable a web beacon or other automatic data collection tools in the email message due to specific email software capabilities. If you choose to receive marketing emails or newsletters from us, we may automatically collect personal information about you. For example, through web beacons and personalized URLs embedded in these emails or newsletters, we can track whether you’ve opened those messages and whether you’ve clicked on links contained within those messages.
- Embedded Web links. Emails from us often use links designed to lead you to a relevant area on the web, after redirection through our servers. The redirection system allows us to change the destination URL of these links, if necessary, and to determine the effectiveness of our marketing initiatives.In emails, such web links may also allow us to determine whether you have clicked a link in an email, and this information about the interaction may be connected to your personal identity. If you do not want us to collect information about the links that you click, you can choose not to click links in an email that we send.
- “Do Not Track” disclosures. Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to web sites visited by the user about the user’s browser DNT preference setting. We do not currently commit to responding to browsers’ DNT signals with respect to the iManage websites and/or services, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. We take privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
- We will use the personal information we collect via our websites:
- To administer our websites, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
- To improve our websites to ensure that content is presented in the
most effective manner for you and for your computer; and
- As part of our efforts to keep our websites safe and secure.
- We may use the personal information we collect from you when contacting us, when enquiring about using our services, or from our customers and their users in connection with the services we provide for a range of reasons, including to:
- For purposes made clear to you at the time you submit your personal information – for example, to fulfill your request for a demo, to provide you with access to one of our webinar’s or whitepaper’s or to provide you with information you have requested about our services;
- To set up a user account
- Provide, operate and maintain the services
- Process and complete transactions, and send related information, including transaction confirmations and invoices;
- Manage our customers’ use of the services, respond to enquiries and comments and provide customer service and support;
- Send customers technical alerts, updates, security notifications, and administrative communications;
- Investigate and prevent fraudulent activities, unauthorized access to the services, and other illegal activities; and
- For any other purposes about which we notify customers and users.
The legal basis we rely on to process your personal information is Article 6(1)(b) of the GDPR, which relates to processing necessary to enter into a contract or to perform it once concluded. Not providing us with this information may prevent us from properly identifying you as our client and providing you with efficient services or answers tailored to your requests.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Regulatory provisions such as the Limitation Act 1980 or the VAT Act 1994 require us to keep some basic information, such as contracts concluded with our clients or service delivery records for six (6) years after the end of a contract. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
- Applying for a job When you apply for a job with us, we may process the personal data necessary to assess your suitability for the job you apply for. The data collected may include identity and contact details, previous experience, education and references. Depending on stage of the recruiting process, other information may be required such as criminal records.The legal basis we rely on for processing your personal data in this context is Article 6(1)(b) of the GDPR, which relates to processing necessary to perform a contract or to take steps at your request before entering a contract. This information is necessary for us to decide if we want to hire you and to enter into an employment contract with you.If your application is unsuccessful, the data will be retained for 1 year from the end of the recruitment process. If the application is successful, the data, as well as additional human resources data, will be retained for at least the period of employment. In this case, your employee file will be retained for 6 years from the end of employment.
We do not rent or sell your personal information. We may share and disclose information, including personal information in limited circumstances as described below.
- Vendors, consultants and other service providers. We transfer personal information to third parties such as vendors and service providers who perform tasks on our behalf such as for processing and storage purposes. These companies include, for example, our payment processing providers, website analytics companies (e.g., Google Analytics), product feedback or help desk software providers (e.g., Zendesk), CRM service providers (e.g., Salesforce), marketing service providers, and email service providers.
- We may transfer personal information pursuant to our own Privacy Shield self-certification, as described further below, or to other organizations that participate in the Privacy Shield for transfers from the EEA or Switzerland to the U.S;
- We may transfer personal information to countries that are covered by adequacy decisions; or
- We may enter into contractual provisions between us and the recipient, approved by the European Commission, to impose on the recipient the same protection and security obligations as if they were in the EEA.
Privacy Shield Frameworks
We are subject to the jurisdiction of the U.S. Federal Trade Commission for purposes of Privacy Shield enforcement.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at DPO@iManage.com.
We have further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
Under certain limited circumstances, individuals in the EEA may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.
If we have received your personal information under the Privacy Shield and subsequently transfer it to a third-party service provider for processing, we will remain responsible if they process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Under data protection laws, you have various rights, such as the right of access, that gives you the right to ask us for copies of any of your personal information that is in our possession; the right to rectification that allows you to rectify and complete information that you think is inaccurate or incomplete; and the right to erasure that gives you the right to ask us to erase your personal information in certain circumstances. You also have the right to restriction of processing, to object to processing and to data portability.
These rights available to you may depend on our reason for processing your information and the circumstances. You are not required to pay any charge for exercising your rights, unless your request is clearly unfounded, repetitive or excessive. We will respond to any legitimate requests within one month. In the event that your request is clearly unfounded, repetitive or excessive or if we are not in a position to identify you, we are entitled to refuse to act on your request.
If you wish to confirm that we are processing your personal information, or to have access to the personal information we may have about you, please contact us at DPO@imanage.com.
California residents have the right to know what personal information the business collects, discloses and/or sells if applicable. Under the California Consumer Privacy Act (“CCPA”), consumers have the right to access what personal information has been collected about them by making a verifiable consumer request.
Once we confirm your verifiable consumer request, we will share with you the categories of personal information that we have collected about you in the preceding 12 months, the categories of sources for the personal information we collected, the business or commercial purpose for which the personal information was collected, the categories of our affiliates and/or third parties with whom we share this information, and specific pieces of personal information we collected about you.
If we have sold your information (as defined in the section 1798.140(t) of the CCPA) or disclosed it for a business purpose, we will disclose the sales and disclosures, specifying the personal information category that was sold or disclosed to our affiliates and/or third parties. Furthermore, we will disclose the categories of third parties with whom the information was sold and/or disclosed.
iManage has not sold (as the term is defined in section 1798.140(t) of the CCPA) personal information in the past 12 months.
As a California resident you have the right to opt out of the sale of your personal information at any time. Subject to some exceptions, you have the right to request that we delete your personal information. You have the right to request that your personal information is transferred to a third party. We will not discriminate against you for exercising your CCPA rights.
Our business operates exclusively online. If you are a California resident and would like to submit a consumer request, please submit a written request to DPO@imanage.com.
To help protect the privacy of personal information you transmit to us, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal information to those employees who need to know that personal information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at firstname.lastname@example.org.
540 West Madison, Suite 300
Chicago, IL 60661
Data Protection Officer
15 Old Bailey
020 3367 1245