EEA, UK and Swiss Privacy Notice

Introduction

Your privacy matters to us at Impel. This Privacy Notice (Notice) explains the personal information Impel may collect. It applies to our suite of digital merchandising products, our website, and our mailing list. If you have questions about the Notice, please feel free to contact us at support@impel.io. The Notice explains how we collect, use and share personal information. You have several rights concerning your information. Please read the Notice carefully to understand what we do and what your rights are.

Additional information is available for California residents.

Additional information is available for residents of the United States.

Who we are

We are Augmented Reality Concepts, Inc. (d/b/a Impel). We can be reached at support@impel.io or

Impel
Attn: Data privacy
344 S Warren St, Suite 200
Syracuse, NY 13202

We create interactive images of vehicles; display these images on the websites of our customers, such as car dealers; help our customers display relevant ads on websites; provide our customers with information about the use of their websites; and provide tools to respond to consumer inquiries via email or text message. References to “we,” “us,” and “our” mean Impel.

References to “third-party” mean someone who is not you or us.

We are a Processor of the personal information you provide to Impel.

Who you are

In the Notice, “you” means you as a:

• Consumer: a visitor to the website of one of our customers. If you are a Consumer, you have no direct relationship with Impel.
• Customer of Impel: a representative of a company that uses Impel’s services and is a customer of Impel.
• Prospective Customer of Impel: a visitor to the impel.ai website, who may submit a contact request form and may become a customer of Impel.

If you are a Customer or a Prospective Customer, you are a Controller of the personal information you provide to Impel.

What information do we collect?

As a Consumer, if you visit the website of one of our Customers, we may collect your IP address, the type of device or web browser used, and a record of pages viewed, items viewed on those pages, and amount of time spent viewing them. We may look up the IP address and store the corresponding geographic address. We do not collect your name, email, phone or other personal information unless you choose to provide this information by submitting an online contact form or replying to an email or text message. If you choose to provide personal information to us or one of our Customers, we or the Customer may collect this information and may combine it with your IP address, device and pageview information.

As an Impel Customer, we may collect your name, email address, phone number, mailing address, billing information and other details necessary to provide our services to you.

As one of our Prospective Customers, if you submit a contact request form on the impel.ai website, we may collect your name, email address, and any messages you send us.

How do we use personal information?

We use the information we collect from you as a Consumer to show you images of and information about relevant vehicles; to inform Customers about web pages, vehicles and vehicle features that Consumers have viewed; and to reply to your inquiries. 

We use the information we collect from Customers to set up and administer your account, to provide you with training and technical support, to send you reports via email, to market additional Impel services to you, and for billing purposes.

We use the information we collect from Prospective Customers to answer your inquiries and to market Impel’s services to you.

To market our services, or as a result of usage of our products, Impel may, directly or indirectly, contact Consumers, Customers, and Prospective Customers via a third-party service provider using the personal information that you provide to us or our partners.  This may include contacting you via regular mail, email, or text/SMS message or other medium. 

When do we share personal data?

We may share information about you with:

• Customers by providing reports about usage of their websites.
• Resellers who provide Impel’s services to our Customers on our behalf. These partners may have access to the same reports.
• Customers by forwarding the information you provide by submitting an online contact form or replying to an email or text message, but only if you submit such a form or reply.
• A third-party service to use your IP address to look up the corresponding geographic address.
• Vendors that help us manage email communications and support tickets for our customers.
• Vendors such as Criteo that display targeted advertising for our Customers. You can learn more about how Criteo’s services work by referring to Criteo’s privacy policy. You can learn in Impel’s Cookie Notice about cookies that may be set by Criteo when you visit the website of one of our Customers.

Where do we store and process personal data?

We store the information we collect from you on servers provided by Amazon Web Services in the U.S. and Ireland. For development and testing purposes, the information we collect from you may also be stored on computers used by Impel employees and partners in the U.S. and other countries. The information we collect from you in the EU, UK and Switzerland may be transferred from and kept outside the EU, UK and Switzerland because our operations are located in the U.S. We rely on Standard Contractual Clauses in order to transfer your information outside the EU, UK and Switzerland.  Information previously collected under the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks still is retained and provided adequate protection by other authorized means.

How long do we keep your personal data?

In our primary data store on Amazon Web Services, we retain your information for 180 days. We also may retain your information indefinitely in the following secondary data stores:

• Database backups
• Log files
• Reports that were generated using the information

Old records in the primary data store are detected and removed automatically using built-in Amazon Web Services functionality.

What are your rights?

You have the right:

• To know if we are collecting, using or sharing your information and to request access to this information.
• To request that we correct your information if it is inaccurate or incomplete.
• To ask us to erase your information if
  • Your information is no longer necessary for the purposes for which it was collected, used or shared.
  • You withdraw the consent on which the collection, use or sharing is based.
  • You object to the collection, use or sharing and there is no overriding legitimate interest for continuing the collection, use or sharing.
  • You object to the collection, use or sharing of your information for direct marketing purposes.
  • Your information was unlawfully collected, used or shared.
  • Your information has to be erased in order to comply with a legal obligation.
  • Your information was collected in order to offer online services to children.
• To obtain from us a restriction on the collection, use or sharing of your information if
  • You contest the accuracy of your information.
  • You have objected to the collection, use or sharing based on legitimate interest and we are considering whether our or a third party’s legitimate interest ground overrides your interest.
  • The collection, use or sharing is unlawful, and you oppose erasure and request the use be restricted instead.
  • We no longer need your information, but you require your information to establish, exercise or defend a legal claim.

• To be able to take with you the information you provided to us and to transmit that information to another organization where our collection, use or sharing of that information is carried out by automated means and is based on your consent or the performance of a contract.
• To object to collection, use or sharing based on the purposes of legitimate interest or performance of a legal task, direct marketing and scientific/historical research and statistics.
• Not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.
• To lodge a complaint with a supervisory authority.

California residents may have additional rights.

How do you exercise your rights?

As a Customer or Prospective Customer, you may access, correct, or delete your account information or cancel your account at any time by emailing us at support@impel.io. Please note that in some cases we may retain certain information about you as required by law or for legitimate business purposes to the extent permitted by law.

You can opt out of our marketing communications at any time, and you have the right to be removed from our email list at any time, using the opt-out link provided in our mailings. If you opt-out, we may still send you non-promotional communications, such as those about your account or about our ongoing business relations. Impel does not endorse or take responsibility for content on other websites accessed from links on impel.ai.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Additional information is available for California residents.

Additional information is available for residents of the United States.