Privacy Policy

IMGE, LLC (“IMGE”, “Company”, we”, “us” or “our”) respects the privacy of our visitors and users of our services, and we have prepared this Privacy Policy to demonstrate our commitment to protecting your privacy. The terms and conditions described in this Privacy Policy apply to visitors to our website, www.imge.com (the “Website”) including any content, functionality, and services offered on or through the Website, whether as a visitor or registered users. This Privacy Policy also applies to other websites (public and password-restricted) controlled by the Company that link to the Website or post this Privacy Policy as well as our online services, including our DriveAction platform (collectively, the “Services”), to the extent the Services are not subject to a separate agreement that addresses privacy.

This Privacy Policy describes what personal information and other information IMGE collects on the Website or the Services, how it is collected, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

This Privacy Policy does not apply to information collected by us offline or through any other means, including to information collected by any third-party websites, plug-ins or applications to which we provide links, to information provided to, or collected by, third parties through cookies, web beacons, or other third-party technologies served during your visit to the Website.

By visiting the Website or using the Services, you agree that your personal information will be treated as described in this Privacy Policy.  If you do not agree with the terms of conditions of this Privacy Policy, please refrain from using our Website or Services.

Activities Covered

To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Privacy Policy.  Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”).  This Privacy Policy applies to the collection and processing of Personal Information collected by us when you provide us information directly, such as when you:

• Visit our Website;
• Open an account with us to access our Services;
• Access our Services;
• Visit our branded social media pages;
• Submit a job application;
• Subscribe to one of our e-newsletters;
• Communicate with us, including via emails, phone calls, texts or fax;
• Use our Services as an authorized user (for example, as an employee of one of our clients who provided you with access to our Services);
• Register for, attend or take part in our events, webinars, or contests; or
• Participate in hosted community chat rooms or other exchanges with other users.

Our Website and Services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.

What Information We Collect and How We Collect It

Information We Collect Automatically -- We automatically collect Personal Information from your browser when you interact with the Website. This information includes, but is not limited to, the type of your device, IP address, browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, any referring website address, and certain geolocation information.

We also may collect information about any Services you access or use, your interactions with content offered on the Website, and other online activity. For example, we may collect information about how many visitors visit a specific webpage, how long they stay on that page, and which hyperlinks, if any, they click on. We collect this information, in part, through the use of technologies such as cookies and web beacons, which are discussed in greater detail below.  This information is used for statistical and analytics purposes to improve our Website and Services.

Information You Provide Voluntarily -- In order to access Services offered on the Website, you may be asked to provide certain information, including:

• Personal Identifiers: Name, title, physical address (including zip code), email address, and phone number.
• Campaign Submissions: Information in the form of the content that you submit during your use of our DriveAction platform. This may include photos, your personal comments and positions on topics, which could include political information and other information that you choose to submit.
• Social: Username, or handle, from Facebook or X when you connect to us from them.
• Employment Information: Professional history, education, recommendations (when you apply for a job with us).
• Demographic Information: Employer, date of birth, title.
• Financial Information: Payment information.

Information May Vary – The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information.  When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal information, unless required for our services.

Payment Information – Because your credit card security is a high priority for us, we have taken reasonable steps to ensure your payment information is processed confidentially and securely through a trusted third party.

Registration – Authorized representatives of our clients will need to provide certain personal information (including name, phone number, email address, title and affiliation) to register with us and establish an account to access the Services, such as our DriveAction platform.  These authorized users will also be asked to provide a unique login ID and password.

From Third-Party Technologies and Social Network Sites – We may receive Personal Information about you from other sources with which you have interacted, such as through third-party technologies that are integrated into the Services like Facebook or X when you grant us permission to access these technologies to further use our Services. We may associate this Personal Information obtained from these sources with the other Personal Information we have collected about you from other sources as described in this Privacy Policy.

User Contributions – The Website may contain interactive features (collectively, "Interactive Services") that allow users to post, submit, publish, display, or transmit to other users or other persons (hereinafter, "post") content or materials (collectively, "User Contributions") on or through the Website or Services. Any User Contributions you post to the Website or Services will be considered non-confidential and non-proprietary. You are advised that any Personal Information that you post in User Contributions may be available to other users may become publicly available and could be collected or used by anyone.  We therefore urge you to exercise discretion and caution with respect to your Personal Information before posting in User Contributions.

Third-Party Analytics – Third parties who provide us with analytics services for our Platform and Services may collect some of the information previously described, including, for example, IP address, access times, browser type and language, device type, device identifiers and Wi-Fi information. For instance, we use Google Analytics and similar services to perform certain analytical tasks about our web user’s activities.

Sensitive Personal Information – We do not knowingly collect “sensitive” or “special categories” of personal information, except for political affiliation, which is needed to access some of our Services.  Any payment information, including credit card information, is provided directly to a secure third party vendor.  IMGE does not collect, maintain, or otherwise have access to any payment information at any time.

Job Applicants - If you apply for a position with us via the Careers page https://imge.com/careers/ on the Website, you will be asked to provide certain Personal Information to enable us to process your application: name, telephone, email address, resume and physical/mailing address.  Note that if you submit your job application information via email or regular mail, your included Personal Information will also be treated in accordance with this Privacy Policy.

How We Use Your Information

We may use your Personal Information in the following circumstances:

• Where we need to perform a contract we have entered into with you or with a client;
• Where we need to comply with a legal obligation;
• Where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
• Where we need to protect your vital interests (or someone else’s vital interests);
• Where it is needed in the public interest or for official purposes;
• To send you direct marketing communications about new or other products or services that may be of interest to you.  You have the right to withdraw consent to our marketing at any time by contacting us at [email protected].

We may use information that we collect about you to:

• Deliver the products and services that you or a client has contracted for;
• Complete a transaction involving you or a client;
• Manage your account and provide you with customer support;
• Process information you have submitted through one of our Campaign forms;
• Improve the content, functionality and usability of the Website and Services;
• Diagnose and prevent service or technology problems associated with the Website and the offered Services;
• Perform security, credit or fraud prevention;
• Perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or other content offered on the Website or the Services;
• Respond to your inquiries or otherwise communicate with you by email, postal mail, telephone, and mobile devices about products or services that may be of interest to you;
• Develop and display content and advertising, if any, tailored to your interests on our Website or third-party websites;
• Enforce this Privacy Policy; and
• Manage our business and perform functions as otherwise described to you at the time of collection of your information.

Anonymous and Aggregate Information – We reserve the right and discretion to create, use and disclose anonymous and aggregate information, i.e., information about specific individuals or groups of individuals from which personal identifiers have been removed and specific individuals cannot be identified.

Text Messaging

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties.  Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested.  In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number.  In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.  You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

How We Share Your Information

We do not sell or lease your Personal Information to any third party.  We may share your Personal Information to third parties for a business purpose, including, but not limited to:

• Affiliated Companies – These may be subsidiaries or affiliates in the same group of companies as us.  These companies will only use your Personal Information consistent with this Privacy Policy.

• Authorized Service Providers – These are third parties who provide a service to us. These third parties will only be allowed to use your Personal Information in accordance with our instructions and not for any other purposes.  They are also required to keep your information confidential and secure. For example, we use third party payment processors to facilitate payments to us.

• Law enforcement, Regulators and Other Parties for Legal Reasons – These are third parties to whom we may be under a legal obligation to disclose your Personal Information to or who we need to disclose your Personal Information to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.

• Buyers of our business – We may share Personal Information in connection with a substantial corporate transaction, such as the possible sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. We may also need to share your Personal Information to permit us to pursue available remedies or limit damages we may sustain. In such circumstances, we will ensure your information is used in accordance with this Privacy Policy.

• Aggregated and Non-Personal Information – We may share aggregated and non-Personal Information we collect with third parties and affiliated companies to develop and deliver interest-based advertising on our websites and on websites of third parties. We also may share aggregated information with third parties, including service providers, advisors, advertisers and investors, for the purpose of conducting analytics regarding our Website and Services and for general business analysis. We also may combine non-Personal Information we collect with additional non-Personal Information collected from other sources.

• Marketing Communications – From time to time we may share your contact information with selected providers of goods and services that may be of interest to you. If you prefer not to receive information from these providers, you can notify us at any time by contacting us at [email protected].

• With Your Consent – We may disclose your Personal Information to a third party if and when you give us express permission to do so.

Cookies and Other Tracking Technologies

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use cookies to improve the Website, for example by remembering you when you return; to provide, analyze, understand and enhance the use of our services; to enforce our terms; to prevent fraud; to improve the Website’s performance, monitor visitor traffic and actions on the Website; and to deliver and tailor our marketing or advertising, and to understand interactions with our emails, marketing, and online ads on third party websites.

The following is a description of the types of implemented cookies:

• Strictly Necessary Cookies: These cookies are strictly necessary to provide the Website. Without these cookies, services you have requested cannot be provided.  For example, they are used to authenticate and identify returning users.

• Performance and Functionality Cookies: These cookies provide statistical information on site usage, such as web analytics.  They also help us to personalize and enhance your online experience.

• Advertising Cookies: These cookies are used to create profiles or personalize content to serve you interest-based advertisements that we think are most relevant to you.  These cookies and resettable device identifiers use information about your use of this Website and other websites and apps, your response to ads and emails, and to deliver ads that are more relevant to you.

Some of these cookies may be activated only for the time you are viewing a website (“session cookies”).  Other cookies may remain on your computer after you have closed your browser or turned off your computer (“persistent cookies”). Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Website. Just like any other usage information we collect, this information allows us to improve the Website, customize your online experience, serve interest-based advertising on other websites, and as otherwise described in this Privacy Policy.

You have the option to set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. However, if you set your browser to disable all cookies or opt out, some features of the Website may not function properly. To disable or opt out of cookies, please see below (“Your Choices”).

This Privacy Policy does not cover the use of cookies used by third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Website.

Interest-Based Advertising – Third party advertisers may download cookies onto your computer, or use other technologies like web beacons, to enable them to recognize your computer each time they send you an advertisement, even when you are visiting another website. As a result, the advertiser would have the ability to deliver interest-based advertisements that they believe would be of most interest to you. We do not have access to or control of the cookies that may be placed on your computer by third-party advertisers.  To find out how to opt out of interest-based advertising, please see below (“Your Choices”).

Other Tracking Technologies -- Like many websites, we may use standard Internet technology, such as web beacons, site tags, clear GIFs and other similar technologies, to collect and maintain information about your activity when visiting the Website and or other websites, as well as third-party websites. We also may include web beacons or pixels in advertisements and promotional e-mail messages determine whether advertising or messages have been acted upon. The information we obtain in this manner enables us to customize the services we offer our visitors to deliver interest-based advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

Your Rights Under State Law

Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act of 2018 (“CCPA”), the Colorado Privacy Act (“CPA”), the Virginia Consumer Data Protection Act (“VCDPA”), or other applicable state data privacy laws.

Personal Information Collection and Disclosure. In the preceding 12 months we have: (1) collected the following categories of Personal information; (2) disclosed such categories of Personal Information for a business purpose; and (3) disclosed Personal Information to the following categories of third parties.  Please note that we do not disclose or transfer Personal Information that would constitute “selling” of Personal Information under the CCPA, CPA or VCDPA.

Category	Examples	Collected	Disclosed for Business Purpose?	Categories of third parties with whom Personal Information is Shared
A. Identifiers	Name, postal address, e-mail address, IP address	Yes	Yes	Authorized service providers and professional advisors, Business partners, Analytics providers, Marketing channels
B. Personal information categories listed in the California Customer Records statute	Name, telephone number, credit card and debit card information	Yes	Yes	Authorized service providers and professional advisors, Business partners, Analytics providers, Marketing channels
C. Protected classification characteristics under California or federal law	None	No	No	N/A
D. Commercial information	Records of products purchased, obtained, or considered	Yes	Yes	Authorized service providers and professional advisors, Business partners, Analytics providers, Marketing channels
E. Biometric information	None	No	No	N/A
F. Internet or other similar network activity	Information on a consumer's interaction with the website	Yes	No	Authorized service providers and professional advisors, Business partners, Analytics providers, Marketing channels
G. Geolocation data	Postal Address	Yes	Yes	Authorized service providers and professional advisors, Business partners, Analytics providers, Marketing channels
H. Sensory data	None	No	No	N/A
I. Professional or employment-related information	Identifiers, professional and education history	No	No	N/A
J. Non-public education information collected by certain federally funded institutions	None	No	No	N/A
K. Inferences drawn from other personal information	Profile reflecting a person's preferences	Yes	No	N/A

Your Consumer Rights

If you are a California, Colorado, or Virginia consumer, as defined by the CCPA, the CPA or the VCDPA, respectively, you may be afforded additional rights with respect to your “Personal Information” or “Personal Data” as that term is explicitly defined under the CCPA, CPA, and VCDPA.  Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Such information can include:
   1. The specific pieces of personal information we have collected about you;
   2. The categories of personal information we have collected about you;
   3. The categories of sources from which the personal information is collected;
   4. The business or commercial purpose for collecting personal information about you; and
   5. The categories of third parties with whom we have shared personal information about you.
2. Correction.  You can correct what Personal Information our Website or Service databases currently contain by accessing your account directly, or by contacting us to request that we correct or rectify any Personal Information that you have provided to us.
3. Prohibit Data Sharing.  When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information.  When such prohibitions are not possible to provide our services to you, we will advise you accordingly.  You can then choose to exercise any other rights under this Privacy Policy.
4. Portability.  Upon request and when possible, we can provide you with copies of your Personal Information.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Privacy Policy
5. Deletion.  You have the right to request that we delete any of your Personal Information, 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.  Where applicable, we will ensure such changes are shared with trusted third parties.
6. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
7. Non-Discrimination. If you exercise your rights under applicable state law, including the CCPA, CPA, and VCDPA, we shall not discriminate against you by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
8. Exercising your rights. If you are a California, Colorado, or Virginia resident who chooses to exercise the rights listed above, you can contact us using one of the following methods:

1. Via web form. If you wish to exercise any of your California privacy rights via our website, please click here https://imge.com/ccpa-request.
2. Via Email. If you wish to exercise any of your California privacy rights via email, please email us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.  If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Other California Privacy Rights

“Shine The Light” Law – California residents with whom IMGE has an established relationship have the right to request certain information with respect to any Personal Information IMGE may have shared with third parties for their direct marketing purposes. Alternatively, IMGE may provide a cost-free means to opt out of such sharing. IMGE has opted to provide you with a cost-free means to opt out of such sharing. If you do not want IMGE to disclose your Personal Information to other companies for their marketing purposes, please email us at [email protected].

Individuals Under 18 – For California residents under the age of 18 and registered users of our Website or Services, California law provides that you can request the removal of content or information you posted on Websites.  Any such request should be sent to us at [email protected] along with a description of the posted content or other information to be removed.  Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.

Do Not Track – Some web browsers and devices allow you to broadcast a preference that your activities online not be “tracked.” At this time, the Website does not honor “do not track” signals.

Your Privacy Preferences and Choices

We strive to provide you with appropriate choices regarding the Personal Information you provide to us. We have created the following mechanisms to provide you choices and control over your information.

Other Uses – We will not collect, use, or disclose your Personal Information in any ways or for any purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will update this Privacy Policy as described below in the Changes to this Privacy Policy” section.

Promotional and Marketing Messages – You can opt-out of receiving our or third party marketing or promotional email communications by using the “Unsubscribe” feature at the bottom of each email from us or by requesting to opt out by emailing us at [email protected]. Please note that you cannot opt-out of receiving transactional communications from us regarding Services you request or use or other transactional or administrative issues.

Cookies – You have the ability to disable or opt-out of certain cookies by going to the Cookie Preferences of your browser.  Also, you can find out more information about how to change your browser cookie settings at www.allaboutcookies.org.  If you choose to disable cookies or opt-out, please note that you may not be able to sign in or use some of the features offered on the Website or Services.

Online Advertising – This Website adheres to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising, which administers a program to help inform consumers about data collection and advertising practices and provides consumers a means to exercise choice with respect to certain advertising practices of participating companies. For more information about the DAA and the choices available via the program, please visit the DAA website at www.aboutads.info. Be advised that this opt-out tool is provided by third parties and may not be available with respect to all interest-based advertising that is presented to you. We do not control or operate these tools or the choices that advertisers and others provide through these tools.  Even if you opt out of receiving interest-based advertising, you may still receive generic ads.

Google Analytics – We use Google Analytics to help us manage and improve the Website. Google provides a Browser Add-On that allows you to opt-out by downloading and installing the add-on for your web browser, available at https://tools.google.com/dlpage/gaoptout.

We will make reasonable efforts to ensure your Personal Information is accurate and complete and we will update or correct your information as needed when notified by you. If you would like to request access to your personal information, request to verify your personal information, confirm the accuracy of our personal information, or change your personal information in any way, please contact us at [email protected].

How Long We Keep Your Personal Information

We retain your Personal Information as reasonably necessary to fulfill the purposes for which we collected it, and to comply with our legal obligations.

How We Secure Your Personal Information

We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Information we process or use.

While we follow generally accepted standards to protect Personal Information, no method of storage or transmission is 100% secure.  If you have any questions about the security of our Website or Services, please contact us by using the information in the “Contact Us” section, below.

If you establish an account with us, please do not provide your login information, including your password, to another person.  You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions.  We cannot be responsible for a data breach or other incident if a password is used by unauthorized persons.

Located in the United States

IMGE is located in the United States.  We do not warrant or represent that this Privacy Policy or the Website’s or Services’ use of your Personal Information complies with the laws of any other jurisdiction.  If you are visiting our Website and accessing the Services from outside the United States, please be aware and understand that your Personal Information will be transferred to, stored, and processed in the United States where our servers are located and operated.  The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country.  We take reasonable measures to ensure that your Personal Information remains secure.  By using our Website and Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

Children

The Website and Services are intended exclusively for persons 18 years and older.  We do not knowingly collect Personal Information or other information from persons under 13 years of age. If you are under 13, you should not provide your Personal Information to us.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If you believe that we might have any Personal Information from a child under 13, please contact us at the details at [email protected] so that we may delete it.

Third-Party Links

The Website and the Services may include links to other websites controlled by third parties.  IMGE does not control or manage these third-party websites and we are not responsible for the privacy practices of other companies and their websites.  You are encouraged to review the privacy practices of all companies and websites before you disclose your Personal Information.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Website.

Changes to this Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the “Effective Date” at the top of the policy. By continuing to use our Website and Services after we modify this Privacy Policy, you accept the new version of the Privacy Policy. Therefore, it is important that you read this page periodically to ensure you are familiar with the most updated version.  If you do not agree to the changes, you should not continue to use the Website or Services and should instead contact us by emailing us at [email protected].

How We Communicate with You

If we need, or are required, to contact you concerning your Personal Information, you agree that we may do so by email, telephone, or mail that we have on file.

Contact Us

If you have questions regarding this Privacy Policy and how your Personal Information is handled, you can contact us as provided below:

IMGE LLC
108 South Washington Street
Alexandria, VA 22314
[email protected]