U.S. Privacy Notice

Updated 2/5/2025

INTRODUCTION AND SCOPE 

Your privacy matters to us at Impel. This Privacy Notice (“Notice”) applies to the personal information collected by Impel when you interact with our website, products and services, and other websites or services that link to this Notice (“Personal Information”). 

When we use the terms “Impel”, “we”, “us”, or “our” in this Notice, we are referring to Augmented Reality Concepts, LLC (d/b/a Impel), and Impel’s affiliates.  Outsell was purchased in 2024 and is now owned and operated by Impel as an affiliate. As an affiliate, Outsell is subject to this Notice and other incorporated documents. 

In the Notice, “you” means a visitor to the https://impel.ai website or its sub-domains (or any other of our websites that link to this Notice) (“Sites”), including those visitors who interact with us through our Sites or social media channels.

This Notice explains how we collect, receive, use and share your Personal Information. This Notice also describes your choices and rights concerning your Personal Information. Please read this Notice carefully to understand what we do with your Personal Information and what your rights are.

If you have entered into a separate agreement with us, such as the Impel Terms and Conditions, Activation Agreement, or Services Rider, that separate agreement shall control, and only those terms within this Notice that do not conflict with such separate agreement shall apply.

1. IMPEL AS A DATA PROCESSOR

Impel serves as a “data processor” when:

• Impel Customers use our commercial products and services (“Services”), and collect Personal Information, and
• When we collect and process Personal Information on behalf of our Customers in connection with the Services (referred to as “Client Data” in our commercial Terms and Conditions). 

Our customers, not Impel, are the data controllers with respect to all Personal Information collection from our Customer’s and Customer’s customers (“Consumers” as defined above), and are responsible for complying with all laws, rules, and regulations that require providing notice and/or obtaining consent prior to collecting and using such Personal Information in connection with the Services.

2. TERMINOLOGY 

• Consumer: a customer of, or visitor to the website of, one of our Customers. Please refer to the privacy notice of the applicable Customer to learn about how the Customer (and Impel on behalf of the Customer) processes your Personal Information.
• Customer: any entity, including all users belonging to the entity, that uses Impel’s Services pursuant to a commercial agreement with Impel. Please refer to the DPA to learn about Impel processes Customer Personal Information.
• Cookies: are small text files that are placed on your hard drive by a web server when you access our Sites or Services. Cookies may either be first party cookies (placed by us) or third-party cookies (placed by third party vendors), and there are a few different types (described within the Automated Collection section below). You can learn more about cookies and how they work at www.allaboutcookies.org.

Pixels and Web beacons: are small pieces of code that are placed by third party vendors, on Sites or email for several purposes (described within the Automated Collection section below).

3. INFORMATION WE COLLECT 

Website Visitors and Prospective Employees

We collect Personal Information from you when you access, use, or navigate our Sites, submit Personal Information to us through our Sites, request information or book a demo via our Sites, or otherwise interact with our social media channels or communicate with us (including by phone, email, video communication, or otherwise).       

The types of Personal Information we collect include the following categories:

• Contact information – first name, last name, email address, mailing address, telephone number, location data, and employer and employment details.
• Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Job applicant information – If you are a job applicant, we may also collect information about you that you submit to us via our “Careers” page on our Site or a third-party platform to which we post job openings (e.g., LinkedIn). As part of your application, we may collect your contact information, education and previous employment information, resumes, cover letters, or other relevant documents. By submitting your resume or Personal Information for consideration of a job opening, you are giving us permission to collect, use, and retain your Personal Information for the purpose of evaluating your application for employment consideration for the specific position that you applied to, as well as other roles at Impel.  This Personal Information may be processed and stored by a third-party talent tracking solution provider as well as with vendors, consultants, and other service providers who need access to such information to carry out work relating to the recruitment process on our behalf.  

Our offline collection of information includes information you provide to us directly (whether or not in person), including at trade shows or similar events or that we may gather on-site when doing a demo of our products

4. INFORMATION WE COLLECT AUTOMATICALLY 

As with most websites, when you visit our Sites we automatically receive and collect information from your device. This information includes the following:

• Device Information – information about your device, such as the operating system, hardware, system version, the Internet Protocol (IP) address, device ID, and device language.
• Website Actions – specific actions that you take when you use our Sites, including but not limited to the pages and screens that you view or visit, search terms that you enter, how you interact with our Sites. Including, the time, frequency, connection, type, and duration of your use of our Sites.  
• Communications – information regarding your interactions with email messages, for example whether you opened clicked on or forwarded the email.  
• Cookies, Pixel and Web Beacons – please see Cookies, Pixels, Web Beacons, and Analytics section below. 
• Connectivity Information – Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module (“SIM”) operator, and SIM country.     

Cookies, Pixels or Web Beacons

Impel uses standard automated data collection tools, such as cookies, pixels or web beacons, and similar tools, to collect information about how people use our Sites and improve customers and consumers experience. We utilize third party vendors data collection tools to perform these functions for Impel. 

These automated data collection tools are used for more than advertising and analytics, they also provide our Sites with necessary, functional, and performance duties. For instance, necessary cookies provide security and compliance with data privacy regulations. This includes cookies that identify bot and protect against malicious spam attacks and user consent preferences for opt in or opt out under GDPR.

Any Sites visitor has the ability to opt out of the use of these data collection tools, however if you opt out of any cookies or other collection tools categorized as necessary then your website or browsing experience may be affected. You can opt-out from third party vendor cookies that are used for advertising purposes on our Sites.

At the present time our Sites do not respond to “Do Not Track” signals or similar mechanisms.

Website Analytics

We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our Sites. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at the link here. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at the link here.

5. AGGREGATE INFORMATION 

We may de-identify or aggregate Personal Information so that you are not identified as an individual, then use and provide that information to third parties without restriction. We may also provide aggregate usage information to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our Sites and our Services.

6. HOW WE USE PERSONAL INFORMATION 

In general, we collect Personal Information from you so that we can operate our business, operate our Sites, and provide information that you request from us. This includes the following uses and purposes: 

• Provide, operate, improve, maintain, and protect our Sites and Services.
• Provide you with technical and other support related to our Sites
• Communicate with you.           
• Send you Services and company updates, marketing communication, service information, and other information about Impel, our products and services, and products and services of third parties that we think you may be interested in.     
• Conduct research and analysis, monitor and analyze trends and usage of our Sites and Services.      
• Enhance or improve user experience, our business, and our Services, including the safety and security thereof. 
• Personalize our Sites to you by, for example, customizing content that you see. 
• Operate our business and perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Sites and our Services.
• Take action as necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request. 
• Enforce our contracts and applicable terms, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety Impel, our users, Customers, or the public as required or permitted by law.

7. HOW WE SHARE PERSONAL INFORMATION

• Impel Affiliates – We share the Personal Information as necessary with affiliates of the Impel group for the purposes defined above.
• Service Providers – We use third parties to assist us with operating our business and providing our Sites and Services, such as our third-party technology vendors that help us maintain our Sites and Services, and partners that assist us with our marketing and communication.  These service providers will have access to Personal Information to provide services to us. 
• As Directed by You and With Your Consent – Except as otherwise provided in this Notice, we share information with companies, organizations or individuals outside of Impel only at your direction or when we have your consent to do so.  

• Legal Proceedings – We may share information with third-party companies, organizations, governmental authorities, or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Comply with any applicable law, regulation, subpoena, legal process or governmental request; 
• Enforce a contract, including but not limited to any applicable terms, including investigation of potential violations thereof;
• Detect, prevent, or otherwise address fraud, security or technical issues; or
• Protect against harm to the rights, property or safety of Impel, our users, Customers or the public as required or permitted by law.

• Sale or Merger – We may share information about you as part of a merger or acquisition. If Impel is involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business by another company, we may share your Personal Information with that company before and after the transaction closes. In such a case, unless permitted or otherwise directed by applicable law, your Personal Information would remain subject to the terms of the applicable privacy notice in effect at the time of such transfer.

8. PRIVACY CHOICES           

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. Please see the jurisdiction specific sections of this Notice for your other rights depending on your location.

9. INTERNATIONAL TRANSFER

Impel is a global company and if you decide to use our Sites or Services, or share your Personal Information with us, please note that your Personal Information may be transferred across international borders to third countries outside of the country in which you are located. To ensure adequate protection for your information, we enter into data processing agreements with our suppliers, including the ones who process your Personal Information outside of the country in which you are located. When necessary, we also utilize approved transfer mechanism (such as adequacy decisions or the standard contractual clauses in the EU).

10. CHILDREN      

Our Sites and Services are not directed at children under age 16, and we do not knowingly collect information from children under age 16. If you are under age 16, please do not attempt to use our Sites or Services or send any information about yourself to us.  If you are the parent of a child under the age of 16, and you believe he or she has shared information with us, please contact us at privacy@impel.ai so that we can remove such information from our systems.

11. SECURITY OF YOUR INFORMATION      

We use reasonable security measures, including measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage to your Personal Information.  We also take certain measures to enhance the security of our Sites and Services. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your account login information.

12. THIRD PARTY WEBSITES AND SERVICES

Our Sites may contain links to other websites and services operated by third parties, and may include social media features such as social media buttons or links. These third-party websites and services may collect information about you if you click on a link or visit those websites or services, and the social media sites may automatically record information about your browsing behavior every time you visit a website that has a social media button. Your interactions with these features and third parties are governed by the privacy notice of the third party, not by this Notice.

13. IMPEL AND US DATA SUBJECTS

This section of the Notice pertains to Prospective Customers of Impel in the United States – visitors our Sites, who may submit a contact request form and may become a customer of Impel.

Personal information collected from California:

In the preceding 12 months, we have collected the following categories of Personal Information:

• Identifiers (IP address, anonymous unique identifier)
• Internet or other electronic network activity information (type of device or web browser used, record of pages viewed, items viewed on those pages, time spent viewing those items)
• Geolocation data (geographic address corresponding to an IP address)
• Any Personal Information you chose to enter if you submit a contact request form or an inquiry via email, text message or web chat
• Business contact details for our Customers

We collect the following Personal Information from these categories of sources:

• Device or web browser used
• Geolocation service
• Identifiers (e.g. name, postal address, etc.), but only if you choose to enter such information when you submit a contact request form or an inquiry via email, text message or web chat
• Business contact details provided by our Customers and Prospective Customers

Our business or commercial purposes for collecting the Personal Information are:

• To show images of and information about relevant vehicles
• To inform Customers about web pages, vehicles, and vehicle features Consumers viewed
• To display targeted ads
• To reply to a Consumer’s inquiry via email, text message or web chat
• To manage our Customers’ accounts, such as by providing reports and invoices
• To market our products and services to Customers and Prospective Customers

We do not have actual knowledge that we collect Personal Information of children under 13 years of age.  We will remove such information if we become aware of it.

To opt out of the sale or sharing of your Personal Information, click below.

Do not sell my information

We do not have actual knowledge that we sell or share Personal Information of children under 16 years of age.

Retention of Personal Information from California

We primarily store the information we collect on servers provided by Amazon Web Services in the U.S. for 180 days.  Personal information also may be retained indefinitely in the following secondary data stores:

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

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

Personal Information from California Disclosed 

In the preceding 12 months, we have disclosed for business purposes to third parties the following categories of information:

• Identifiers (e.g., IP address, postal address)
• Commercial Information (e.g., products or services purchased)
• Internet or other electronic network activity (e.g., browsing history, interaction with an internet website)
• Geolocation Data
• Business contact details for our Customers and Prospective Customers

Our business or commercial purposes for disclosing Personal Information are:

• To show images of and information about relevant vehicles
• To inform Customers about web pages, vehicles and vehicle features Consumers viewed
• To display targeted ads
• To reply to a Customer’s inquiry via email, text message, or web chat
• To manage our Customers’ accounts, such as by providing reports and invoices
• To market our products and services to Customers and Prospective Customers

We do not have actual knowledge that we have disclosed to third parties for business purposes Personal Information of children under 16 years of age.

Record of CCPA requests and responses

In the past 12 months, we have not received any right-to-know, right-to-delete, right to correct, or opt-out requests.

Your Rights as a California resident

You have the right:

• To request the information we collect, use, disclose, sell and share
• To request deletion of your Personal Information collected by us
• To request correction of your inaccurate Personal Information maintained by us
• To opt out of the sale or sharing of your Personal Information by us
• To request the categories of personal data disclosed for a business purpose.
• Not to receive discriminatory treatment for the exercise of these privacy rights

(“CCPA rights”).

You can make a request for your information twice every 12 months. If you are making an erasure request, it will help us if you include details of the information you would like erased. We may need to ask you for additional information to fully identify you. If we can’t identify you, we may not be able to erase your information. 

Please note that if you request that we remove your information, we may retain some of the information for specific reasons, such as to resolve disputes, troubleshoot problems, and as required by law.

Furthermore, some information is never completely removed from our databases due to technical constraints and the fact that we regularly back up our systems. Therefore, not all of your Personal Information will ever be completely removed from our databases.

We will respond to you on these requests as quickly as received your note but it may take us up to 45 days. If we need more time than that, we will let you know.

We will not discriminate against you for submitting a rights request.

Virginia, Colorado, Connecticut, Utah, Montana, Texas, Oregon, Delaware, Nebraska, New Jersey, Tennessee, Maryland, New Hampshire and Minnesota Residents (“US State Laws”)

As residents of the above-named states, you also have rights under each of applicable privacy laws implemented by each state. 

Under each of the applicable legislation,

• you can request that Impel provides you information to:
• conduct and document data protection assessments about Impel;
• ask Impel to demonstrate Impel’s compliance with its obligations under each of the US State Laws mentioned above;
• request that Impel implements appropriate technical and organizational measures; and to assist you in the event of a data security and/or data breach notification.

Submitting a request

• In order to exercise your CCPA and other US State Laws rights, you can email to privacy@impel.ai or call +1-844-384-6735. You also can use the same link, email address, and telephone number if you have opted out and wish to opt back in. However, please note that in some cases we have no direct relationship with Consumers and therefore may not be able to locate your information and you should contact our Customer instead. 

You may designate an authorized agent to make right-to-know and right-to-delete requests on your behalf by emailing privacy@impel.ai or calling +1-844-384-6735 and providing a proof of attorney or a written and signed permission.

14. IMPEL and GDPR

This section applies to data subjects in the EU, EEA, the UK and Switzerland.

Data Controller details: Augmented Reality Concepts, LLC (d/b/a Impel). 

We can be reached at privacy@impel.ai or

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

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.

Data subject rights under GDPR

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.

How do you exercise your rights?

You may access, correct, or delete your account information or cancel your account at any time by emailing us at privacy@impel.ai. 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 our Sites.

15. IMPEL AND CANADIAN DATA SUBJECTS

Electronic Marketing

Individuals may voluntarily sign up on our Sites to receive marketing materials electronically, including event invitations, product updates, and other marketing material. From time to time we will send electronic marketing materials to individuals with whom we have an existing business relationship.

Each electronic marketing communication includes a link to unsubscribe from any further marketing communications. To unsubscribe from all electronic marketing materials, you can email privacy@impel.ai.

Website Privacy

We use cookies that identify your browser. The cookies collect and store information when you visit our Sites, and may collect Personal Information about you and your use of the site. For more information about cookies and how we use them, please see the Cookies section of this Notice. 

Our Sites may present links to other websites. The operators of linked websites may collect your Personal Information and information generated through the use of cookies when you link to their websites. We are not responsible for how third party websites collect, use or disclose your Personal Information.

Internet Advertising

We use third parties to assist with our electronic marketing and advertising on third party websites. These companies may use cookies, tokens, or other tools to track how you interact with our advertisements or electronic marketing communications. The information generated from this tracking assists us in providing tailored advertising and helps us better understand our digital brand impact. 

Disclosing Personal Information outside of Impel

Impel may only disclose Personal Information for purposes related to providing legal or other services, as required or authorized by law, or with your express consent.

Personal information may be disclosed across provincial and international borders. This includes the Personal Information of individuals residing in Quebec being disclosed outside of the province.

We use service providers, contractors and other agents to store, handle and process Personal Information. These providers, contractors and agents are located within and outside of Canada. We require such providers, agents and contractors to demonstrate comparable privacy protection to our own, either by ensuring the applicability of adequate privacy legislation, through contractual terms, of through the use of technological measures (e.g., encryption).

We may disclose Personal Information to other Impel affiliates bound by contractual terms that ensure comparable privacy protection to our own.

We do not sell any Personal Information.

Legal grounds

Impel will obtain consent for the collection, use, and disclosure of Personal Information. There are some circumstances when we rely on privacy legislation to collect Personal Information without consent. 

We may also use or disclose Personal Information in the absence of consent if we are required or authorized by law to do so. When we receive Personal Information from our customers or third parties, we rely on the party providing it to us having obtained the information lawfully and in accordance with applicable privacy legislation.

Limiting Collection, Use and Disclosure

We limit the type and amount of Personal Information we collect, to that which is necessary to fulfill the purpose for which it was collected. When we disclose Personal Information, we only disclose the type and amount of Personal Information that is needed to fulfill the purpose of the disclosure.

Impel will retain information, including Personal Information, for as long as it is needed for the purposes for which it was collected, and in compliance with legal requirements. 

Individual Rights

Impel will make reasonable efforts to ensure that Personal Information we collect, use and disclose is accurate and complete. Individuals may request access to, correction or deletion of the Personal Information we hold about them by sending a written request to privacy@impel.ai. Please note that we may ask to confirm your identity before we action such request. We will provide you with access to the requested information where we are able to; in some cases we may withhold information because we are required or permitted by law to do so. In these cases, we will tell you why have declined to provide access to it.

16. CHANGES TO THIS NOTICE           

We may make changes to this Notice from time to time. When we do, we will post the updated version on this page. We encourage you to read this page each time that you use our Sites or Services so that you will be aware of any changes, and your continued use shall constitute your acceptance of any such changes. Changes to this Notice take effect from the date of publication, unless stated otherwise.

17. CONTACT US      

If you have any comments, questions, concerns, or suggestions about Notice, or about our privacy practices in general, please contact us at privacy@impel.ai. 

We can be reached at privacy@impel.ai or by mail at: 

Attn: Data Privacy Officer
344 S Warren St, Suite 200
Syracuse, NY 13202