Last updated: July 13th, 2021
WHAT INFORMATION DO WE COLLECT?
Implus collects information about you from a variety of sources, including information that you provide directly to us when you contact us, sign-up for a customer account, and purchase products from us through the Website, and information that we automatically collect about you when you access and use the Website.
Information You Provide Us. To manage and provide the System and to market our products, if you sign-up for a customer account, purchase products, or contact us through the Website, we and/or our service providers collect the requested information that you provide including your name, order information, email, phone number, address, and payment information.
Information Collected Automatically. We collect information automatically from you when you visit and use the Website. Such information includes the following:
Usage information. We collect information about how you interact with the Website to operate and improve the Website. This includes information such as the dates and times that you visit the Website, the page you view, referring / exit URLs, and your browser type. In some cases, we collect this information through cookies and similar technologies. To learn more about these technologies, please see the Cookies section below.
Device Information. To manage the Website, we collect information about the devices you use to access the Website, including your device model, IP address, inferred geolocation information, operating system, and unique device identifiers.
Transaction Information. We collect other transaction details related to your purchases through the Website.
By placing a small file known as a "cookie" on your device, Implus’s and its third party providers’ servers passively gather information about all visitors' use of the System for the following purposes: statistics collection and analysis, System optimization, analytics, market research, and maintenance of user login information. The information that we and our third party providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the System, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the System), how you were directed to the System, which specific pages you access on the System, how long you view each page, the time and date you access our System and the total number of visitors to the System and any portions thereof. We, and/or our third party providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the System. This data helps us and our third party providers improve our respective product and services.
Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly or more slowly.
The table below lists the cookies we collect and what information they store.
|Cookie Name||Cookie Description|
|FORM_KEY||Stores randomly generated key used to prevent forged requests.|
|PHPSESSID||Your session ID on the server.|
|GUEST-VIEW||Allows guests to view and edit their orders.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history, if you have asked for this.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|MAGE-CACHE-SESSID||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE-SECTION-INVALIDATION||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-TIMEOUT||Facilitates caching of content on the browser to make pages load faster.|
|SECTION-DATA-IDS||Facilitates caching of content on the browser to make pages load faster.|
|PRIVATE_CONTENT_VERSION||Facilitates caching of content on the browser to make pages load faster.|
|X-MAGENTO-VARY||Facilitates caching of content on the server to make pages load faster.|
|MAGE-TRANSLATION-FILE-VERSION||Facilitates translation of content to other languages.|
|MAGE-TRANSLATION-STORAGE||Facilitates translation of content to other languages.|
We appreciate your questions and comments about the System and Services and welcome your messages at email@example.com. If you correspond with Implus through the System or via email, the personal information that we collect may include the content of, and metadata regarding, any correspondence that you may have with us. We may share your messages with those within our organization who are most capable of addressing the issues contained in your message. We may retain your message.
HOW DO WE USE THE INFORMATION THAT WE COLLECT?
Implus and our third party service providers collect and use the personal information to operate the System and deliver the Services, including to provide certain services and improve the user experience, address System integrity or security issues, and conduct research and analysis to maintain, protect, develop, and improve the System.
We may also use your personal information to send you promotional materials, whether through email or through the System, regarding Implus, products that we think might interest you, or any third party entity or individual affiliated with individual members of Implus.
Additionally, we may retain and use certain personal information to facilitate and otherwise address certain inquiries or requests regarding the Services or the System, or respond to your questions or requests for information about or from Implus. We may also use personal information as necessary to ensure compliance with any Implus policies and any applicable law, regulation or order.
In addition to the above uses, Implus will also use your personal information if:
- you expressly authorize Implus to do so,
- it is necessary to allow Implus’s service providers, agents, or other third parties to provide products or services for or to Implus,
- we may integrate your personal information with our affiliates’ tools and databases and such affiliates may use your personal information to offer you products and services and for other marketing purposes,
- for developing analytics regarding how users interact with the System and our users’ commercial tendencies,
- Implus is sending you other information that may be useful to you,
- subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on Implus’s behalf,
- it is necessary to protect the confidentiality or security of your records,
- it is necessary in connection with other business purposes including, without limitation, verifying identity, age, and/or payment details, investigating complaints about the System, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution, or
- it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, to exercise or enforce our legal rights, for your protection or in connection with an investigation or prosecution of possible unlawful activity.
WITH WHOM DO WE SHARE INFORMATION THAT WE COLLECT?
We engage service providers who may collect or receive your personal information on our behalf. Overall, the categories of recipients to which we transfer personal information, or who collect personal information on our behalf, for our business purposes include payment processors, hosting platforms, web tracking providers, data analytics providers, marketing consultants, tax processing service providers, common carriers, and package tracking services. We disclose the following categories of personal information for our business purposes: name, order information, email, phone number, address, payment information, usage information, transaction information, and device information.
These service providers will only have access to the information needed to perform these limited functions on our behalf and are typically prohibited from using the information for other purposes except as permitted by law, such as for fraud detection and maintaining their services, or upon your consent.
We do not sell, rent, or lease our user lists or the identity of individual users to third parties.
We may also disclose personal information if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose personal information to establish or exercise our legal rights, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the well-being of any person.
As Implus grows and develops its business, it is possible that its corporate structure or organization might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, personal information generally is, and should be expected to be, one of the transferred business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.
Any personal information you provide us when applying for a career position with Implus will be used solely to consider and act upon your application. We may retain your personal information for a period of time, but only for as long as necessary for such purposes. We may disclose your personal information to our agents for the purpose of evaluating your qualifications for the particular position you applied for, or other available positions. We may also disclose your personal information to third parties hired by us to collect, maintain, and analyze candidates for career positions.
WHAT CHOICES DO YOU HAVE?
When submitting information, corresponding, making requests for information, and otherwise interacting with Implus and its representatives through or in connection with the System, you generally choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Any promotional email we send to you will contain a link which will allow you to opt-out of receiving any further correspondence.
HOW CAN I OPT-OUT OF PROMOTIONAL CORRESPONDENCE?
We may send you emails with promotional offers. If you would no longer like to receive information, newsletters or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions, or alternatively you may contact us at firstname.lastname@example.org with the word “UNSUBSCRIBE” or “REMOVE” in the subject line. Your email address will be removed from our marketing list. Please allow us a reasonable period of time to satisfy your request, as some promotions may already be in process.
HOW DO WE PROTECT INFORMATION COLLECTED BY YOU?
Implus takes commercially reasonable measures to secure and protect information transmitted via or stored on the System. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure.
Any information, communications, or material of any type or nature that you submit to the Website or any mobile application by email, posting reviews, messaging, or otherwise (collectively, a “Submission”) is done at your own risk. We cannot control the actions of other users of the System and we are therefore not responsible for any Submissions contained on the Website.
Additionally, in the event that we offer a message board or any other interactive or social-type feature on the Website, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information. We encourage you to be wary of giving out any personal information, or any personal information of others to which you may have access, in such forums. The information you post can be collected and used by other people.
The System is intended for a general audience and is not intended for use or view by children under 13 years of age.
VISITING THE SYSTEM FROM OUTSIDE THE UNITED STATES
If you are visiting the System, or any part thereof, from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy.
CALIFORNIA RESIDENTS’ PRIVACY RIGHTS
If you are a California resident, you may request certain information from or certain action by us, such as exercising the access and deletion rights described below, or you may authorize an agent to make such a request on your behalf. We will seek to verify your identity and your agent’s authority when we receive an individual rights request from you or on your behalf to ensure the security of your personal information, and may need to collect additional personal information to do so.
California residents have the right to request the deletion of personal information, but we may not delete some or all personal information, as required or permitted by applicable law, such as if the requested information is necessary to:
- Complete your transaction;
- Provide you with a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our Services in the case of a bug;
- Protect the free speech rights of you or other users;
- Protect the free speech rights of you or other users;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
If you are a California resident, you may also request to receive details about how we collect, use, and share your personal information. You may also request to receive the specific pieces of personal information that we have collected about you.
If a business sells personal information, you have a right to opt-out of that sale. We do not, and do not intend to, sell the personal information of California residents and, furthermore, do not have actual knowledge that we sell the personal information of consumers under 16 years old.
Businesses may not, and we do not, discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.
OTHER DATA PROTECTION RIGHTS
Depending on the country in which you reside, and subject to applicable data protection laws, you may have the following data protection rights: To access; correct; update; port; delete; restrict; or object to our processing of your personal information. We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. Please send such requests to email@example.com. We may ask you to verify your identity in order to help us respond efficiently to your request.
DO NOT TRACK REQUESTS
Certain state laws require that we indicate whether we honor “Do Not Track” settings in your browser. We take commercially reasonable efforts to respond to “Do not Track” requests.
WHOM CAN YOU CONTACT FOR MORE INFORMATION?
If you have any questions or suggestions about the System, Implus, or our privacy practices, please contact us at firstname.lastname@example.org.
RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”) AND THE UNITED KINGDOM
Consent. We will make it clear if we rely on your consent to process your personal data and you are free to withdraw your consent at any time. If you wish to do so, please contact us at email@example.com.
Legitimate Interest. Another reason we might use your personal data is because we have—or a third party has—a legitimate interest in doing so. We do so when responding to your inquiries about our products and services; to provide services and technical support to you; and to enable internal administrative processes, such as account administration.
Providing Your Data. One reason we might use your personal data is because you’ve inquired into entering into a contract with us or you’ve entered into a contract with us and we need to provide services under that contract. We may not be able to fulfill that contract if you choose not to provide us with your personal data.
Automated Decision Making. We do not engage in any automated decision making as a part of our Services.
Your Right to Rectification. We want our records to be as accurate as possible, so please advise us of any errors and we will make corrections accordingly. Although a difference of opinion or view does not necessarily mean that personal data is inaccurate. If you have a difference of opinion, we will do our best to add that opinion to our records.
Erasure and your “Right to be Forgotten”. Please contact us at firstname.lastname@example.org if you want us to delete your personal data. We will do our best to honor your request, but we may have an obligation to keep records for audit and legal purposes. We may also be able to “Restrict Processing” or delete specific information or a document, which we will do without undue delay, for example, where it has been sent to us in error.
Your Right to Object to Processing. In certain circumstances, you have the right to object to our use of your personal data, such as if we are using your personal data for direct marketing; for our or a third party’s legitimate interests or the public’s interest; or for scientific or historical research and statistics. Please contact us at email@example.com if you would like us to do so.
Right to Restrict Processing. Under some circumstances, you may request that we limit how we use your data or “Restrict Processing.” Simply a difference of opinion or view does not necessarily justify a restriction, but we will always consider your opinion. We will always inform you before we lift any restriction.
Your Right to Access Data. You have a right to receive a copy of your personal data from us. If you would like to do so, please contact us at firstname.lastname@example.org and we will advise you of the next steps as soon as possible, and in no more than one month.
Right to Data Portability. At your request, we are happy to provide your personal data in a machine-readable or “portable” format so you can move it or store it wherever you want, subject to certain limitations. We can also send it to another controller where technically feasible. If you would like to do so, please contact us at email@example.com and we will advise you of the next steps.
Right to Complain. If you have a complaint about how Implus uses your personal data, we hope that in the first instance you will contact us and we will promptly address your concern. However, you can always file a complaint with the supervisory authority in your jurisdiction. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA are available at https://edpb.europa.eu/about-edpb/board/members_en; and contact details for the data protection authority in the UK are available at https://ico.org.uk/.
Charges/Fees. We do not charge you a fee for exercising any of your rights described above.
RESIDENTS OF AUSTRALIA
This section explains how we handle personal information relating to individuals who are Australian customers, so as to ensure we meet any obligations under the Australian Privacy Act. In this section, "personal information", is defined in the Australian Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, or recorded in a material form or not. Personal information includes a person's name, address, contact details, date of birth, gender, sexuality and race.
We retain the personal information that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services you requested or to comply with an applicable legal requirement).
Direct Marketing. We will not use or disclose personal information for the purposes of direct marketing to you unless:(a) you have consented to receive direct marketing materials; or (b) you would reasonably expect us to use your personal details for this purpose; or (c) we believe you may be interested in the material but it is impractical for us to obtain your consent.
In every instance, we will ensure that our direct marketing material incorporates an option for you to elect to receive no further such communications.
Please note also that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services, questionnaires and other factual information. This form of communication is not regarded as "direct marketing" under the Australian Privacy Act.
Overseas Disclosure. Personal information may be sent outside of Australia to our related bodies corporate, as permitted by the Australian Privacy Act, which are located in the United States of America. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach our privacy obligations relating to your personal information. However, you should note that United States jurisdictions may not offer the same level of statutory privacy protection for personal information as Australia does. By providing your personal information to us, you consent to our disclosure of your personal information to these entities.
Access, Correction and Further Information. We will take such steps as are reasonable to ensure that the personal information which we collect remains accurate, up to date and complete.
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Upon such request we will endeavor to provide you with access to your personal information held by us unless we are permitted under the Australian Privacy Act to refuse to provide you with such access. Please contact us via the details below if you:(a) wish to have access to the personal information which we hold about you; (b) consider that the personal information which we hold about you is not accurate, complete or up to date; or (c) require further information on our personal information handling practices.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information if you so request.
We will respond to all requests for access and/or correction within a reasonable time.
Complaints. If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should advise us via the above contact details.
If you remain unsatisfied with the way in which we have handled a privacy issue, we suggest you approach an independent advisor or contact the Office of the Australian Information Commissioner for guidance on alternative courses of action which may be available. We will provide our full cooperation in the event that you elect to pursue this course of action.
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