Introduction

This privacy policy ("Privacy Policy") is incorporated by reference into the Imparture’s Terms of Service. The terms "Imparture" "we," and "us" include Imparture, Inc., a New York corporation, Imparture Limited, a United Kingdom limited company (8017133) and any parent, subsidiary, or affiliate of any of the foregoing.

Why we’ve created a Privacy Policy

This Privacy Policy explains how Imparture may collect and use the personally identifiable information or personal data ("Personal Information") that we obtain through your use of the Imparture website accessible at www.imparture.com (the "Site") and our class-based instructional products that are delivered through a variety of modalities, both in-person and online (together, the "Services"), and makes you aware of how and why your Personal Information will be used and the rights you have to access and control the use of your Personal Information.

How we apply the principles of this Privacy Policy

By engaging with the Site and Services, you acknowledge that you have read and understood this Privacy Policy. For users based in the EU and the UK, we are required to describe our role and our responsibility for Personal Information.

  • If you access and use the Site and/or the Services in your individual capacity, we are the “data controller” under EU privacy law.

By using the Site or the Services, you are authorizing us to gather and retain data related to the provision of the Site and Services in accordance with this Privacy Policy, and (for non-EU residents) you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with Imparture or the Site or Service will be in accordance with the Terms of Service.

The types of data points we collect

Personal Information includes any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (i.e., anonymized or aggregated data).

The categories of Personal Information about you that we may collect, use, store, and transfer include the following, some of which constitute Personal Information only when combined with personal identifiers:

Identity Data: Information we use to identify you, authenticate you as an authorized user of the Services, communicate with you, and record any transactions you make. This includes first name, maiden name, last name, job title where required for reporting purposes.

Contact Data: Includes billing address, postal address, email address, telephone number, and mobile phone number.

Technical Data: Includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site and Services.

Usage Data: Includes information about how you use the Site and Services.

Transaction Data: Includes details of the Services for which you have previously registered and/or in which you have been enrolled.

Financial Data: In limited circumstances, we may collect payment information for processing of payments, but this information generally is collected and processed directly by our payment services providers.

Profile Data: Includes your interests, preferences, website browsing history, demographic information such as age, gender, or education level, and feedback and survey responses.

Marketing and Communications Data: Includes your preferences with respect to receiving marketing from us and/or our third-party partners and your communication preferences.

How we use these data points

We have set forth below the ways in which we may use your Personal Information, along with the legal bases and legitimate business interests on which we rely to do so where appropriate.

Please note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. These activities include:

  • To identify you and your account and to enable you to register to use the Services
  • To manage and process payments, fees, and charges for the Services
  • To facilitate and deliver the Services
  • To manage our relationship with you, including:
    • Notifying you about any changes to our Services, timetables for the Services, requirements for the Services, and any technical requirements
    • Providing you with feedback on your participation and performance in the Services
    • Notifying you of any changes to this or any other policy
    • Asking you to complete a review or take a survey
  • To provide our Site and its content to you and to enhance users’ experience
  • To improve the functionality of the Site or Services and to provide related customer service
  • To administer and protect the Site and Services (including troubleshooting, data analysis, testing, and system review)
  • To respond to your communications and to send you information that you request or agree to receive, via regular or electronic mail, text message, or other marketing channels
  • To make suggestions and recommendations to you about other courses and services that may be of interest to you
  • To allow you to partake in a competition or promotion
  • To send you advertisements or other marketing materials via email, text message, or other marketing channels about other programs, promotions, or services (or those of our affiliates), including our newsletter, that we think may be of interest to you if you have requested or agreed to receive such information, or where we are otherwise permitted by local law to contact you for these purposes

How we use aggregated, anonymized and non-identifiable data points

Aggregated or anonymized data may be derived from your Personal Information but is not considered to be Personal Information under applicable privacy laws as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated or anonymized data with your Personal Information in such a way that that it can directly or indirectly identify you, we treat the combined data as Personal Information and only use it in accordance with the terms of this Privacy Notice.

We reserve the right to use anonymous or aggregated data for any purpose, including, but not limited to, those set forth above. We may also disclose such anonymous aggregate information to our partners or third-party service providers, excluding any Personal Information, except as otherwise provided in this Privacy Policy.

How we collect your data

We collect your Personal Information when you:

  • Register or apply for a Course, Class, Workshop, or any other Services on the Site, through any of the Services or via a third-party website;
  • Participate in our surveys, promotions, and competitions;
  • Interact with us on various social media channels such as Facebook, Twitter, LinkedIn, etc.;
  • Post information to the Site or Services that includes Personal Information, for example, by posting in a chat room or on a blog post;
  • Communicate with us, for example, by submitting queries regarding the Site or the Services, interacting with our customer support, marketing, or sales teams, or requesting additional information from us, including newsletters or other marketing materials; and
  • Sign up, in person or online, for events or programs that are run by us or by the third-party organizations with which we partner.

Hmmmm…let’s talk about cookies

When you visit the Site or use the Services, we and our third-party service providers, which may include third-party analytics service providers and third-party advertisers, may use cookies, server logs, and other similar technology to collect and store your preferences, usage statistics, website traffic, and performance data, as well as other information such as your IP address, the type of Internet browser or device you use, any website you have come to the Site or Services from, and your operating system.

We may also receive Personal Information about you from various third parties and public sources e.g. Pardot and Maxmind.

Cookies are small text files that include a unique reference code placed on a visitor’s device to store their preferences and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser.

Other cookies are used to remember you when you return to our Site or Services and will last for longer. Some cookies are necessary to enable you to move around the Site and use the Services such as accessing the secure areas of the Site, and they enable us to provide you with the Services you have requested. “Performance cookies” collect aggregated, anonymous, statistical information on how visitors use our Site and Services.

We use this information to make improvements to the Site and our Services and to enhance your overall experience. Other cookies, called “functionality cookies,” allow the Site and Services to remember choices made whilst browsing or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.

We and our third-party vendors, including Google, use first-party cookies and third-party cookies to gather information about the pages visited through our advertising partners, both on our Site as well as other websites that you visit, so as to place you in a "market segment." This information is then used by us and our third-party vendors to serve interest-based advertisements when you visit our Site and other websites and our third-party vendors will combine it with other information from your visits to other websites and apps to learn more about your interests.

For more information about this type of interest-based advertising, and about how to opt out of the automated collection of information by third-party ad networks, please visit the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at https://bit.ly/1mNJxHA. Without these cookies, advertisements you encounter will be less relevant to you and to your interests.

We also use Google Analytics Advertising Features including Google Analytics Remarketing to advertise across websites, Demographics and Interest Reporting, and AdWords and AdSense integrations to collect data about our Site traffic via advertising cookies and anonymous identifiers.

We do not facilitate the merging of personal information with non-personally identifiable information previously collected through any Google advertising product. Google may serve ads across other websites that you visit based upon your past visits to our Site and may also serve our advertisements on other websites. Site visitors can opt out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ad Settings found at https://bit.ly/2KR1ubS. You can also opt out of Google Analytics tracking with the Google Analytics opt-out browser add-on found at https://bit.ly/1DjdmHw.

In addition to cookies, we use the following similar technologies:

  • Pixel & Web Beacons: These are small image files that may be placed by us or third parties on the Site or Services, or within the body of our newsletters so we or third parties can understand which parts of the Site and Services are visited or whether particular content is of interest.
  • Flash cookies: We do not serve Flash cookies but Adobe Flash Player may be used by third parties serving advertisements to the Site in cases where these advertisements are served with flash related content. It is not possible to block or restrict Flash cookies using your browser settings; however, information on how to do this is available from the Adobe website at https://adobe.ly/2xdXbW5.

Disabling Cookies

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can use your browser to notify you each time a cookie is set or to block and delete cookies from your browser.

The effect of disabling cookies depends on which cookies you disable, but please note that if you do that, the Site and Services may not work properly and you may not be able to take full advantage of the Site or our Services.

You can learn more about cookies by visiting https://bit.ly/1rJvvMF, which includes additional useful information on cookies and how to block cookies using different types of browsers.

Details on how to review your cookie settings and disable cookies on the most popular browsers are set forth below:

Microsoft Internet Explorer:

  1. From the menu bar, choose “Tools” then “Internet Options”.
  2. Click on the “Privacy” tab.
  3. Select the appropriate settings.

Google Chrome:

  1. From the menu bar, choose “Chrome” then “Preferences”.
  2. On the “Settings” page, scroll down and click “Advanced”.
  3. Under ''Privacy and Security,'' click ''Content settings'' then “Cookies”.
  4. Select the appropriate settings.

Safari:

  1. From the menu bar, choose “Safari” then “Preferences”.
  2. From the “Preferences” box, choose the “Privacy” tab in the menu bar.
  3. Select the appropriate settings in the “Website tracking” menu.
  4. Click on “Manage Website Data” and make the appropriate selections.

Mozilla Fox:

  1. From the menu bar, choose “Firefox” then “Preferences”.
  2. Click on the “Privacy” tab on the menu bar.
  3. Select the appropriate settings in the “Tracking” menu.
  4. Click on “remove individual cookies” and make the appropriate selections.

What happens if we change the purpose for data usage

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you would like an explanation as to how the new purpose is compatible with the original purpose, please contact us at hello@imparture.com. If we need to use your Personal Information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do this.

What happens if you want to opt-out of future communications

Every marketing communication sent digitally has a supporting one-click unsubscribe link that will remove you from all future mailings.

If for whatever reason this does not function and you do not want us to contact you with marketing communications or other information regarding our products and services (or if you agreed to be contacted for such purposes at the point Personal Information was collected by us but you no longer wish to be contacted or have your information used in such way), you can let us know by following the unsubscribe instructions on any communications sent to you. You can also unsubscribe at any time by contacting us at hello@imparture.com.

How we may share your information

Vendors and Third-Party Service Providers

We may share any information we receive, including your Personal Information, with vendors and third-party service providers, including Instructors, retained in connection with the provision of the Site or Services.

This includes those providing website and data hosting services (e.g., Amazon Web Services), distributing communications and supporting or updating marketing lists (e.g. Salesforce), facilitating feedback on our services (e.g., Wufoo); and providing IT support services from time to time.

These organizations (which may include third-party suppliers, agents, subcontractors, and/or other companies in our group) will only use your information to the extent necessary to perform their support functions. In addition, where necessary, we have entered into Data Processing Agreements with these third-party service providers.

Payment Transactions

All payment transactions are conducted through our PCI-compliant secure payment solutions provider Stripe, Inc.

For additional information on how Stripe secures your payment card information during transmission and storage, please refer to Stripe’s privacy policy located at https://bit.ly/2IemnjC.

You will be providing debit or credit card information directly to our payment solutions provider that operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment.

Information that you supply to our payment solutions provider is not stored by us or within our control, and is subject to our payment solutions provider's own privacy policy and terms and conditions. We do not hold any credit / debit card information internally.

Social Networking and Other Websites

The Site or Services may allow you to post information to social networking websites. We do not share your information with such social networking websites unless you direct the Site or Services to share it. The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data.

As Required by Law and Similar Disclosures

We may access, preserve, and disclose your Personal Information, other account information, usage information and device identifier (including IP address), and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order, warrant or subpoena; respond to your requests; enforce our policies related to our Site or Services, or other applicable policies; or protect yours, ours, or others' rights, property, or safety.

Unless prohibited by law or court order, or unless we determine in our sole discretion that notification is inappropriate under the circumstances, we will take all reasonable steps to notify all affected users of a legal request for information or intended disclosure prior to disclosure.

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information, including Personal Information, may be sold or transferred as part of such a transaction as one of the transferred assets as permitted by law and/or contract.

We cannot control how such entities may use or disclose such information.

With Your Consent.

We may also disclose your information, including your Personal Information, where you have specifically provided your consent for the disclosure.

You may withdraw consent to disclosures where you have previously give a specific consent by emailing us at hello@imparture.com.

How we secure your data

We have implemented appropriate physical, technical, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

In addition, we limit access to your Personal Information to only those employees, agents, contractors, and other third parties who need to have access to such information for the operation of our business, including operation of the Site and Services. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

As noted above, all payment transactions are conducted through our PCI-compliant secure payment solutions provider Stripe, Inc.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or the Services like message boards. The information you share in public areas may be viewed by any user of the Site or the Services.

Unfortunately, no electronic data transmission or storage of information can be guaranteed to be completely secure or error free and we cannot warrant or guarantee the security of any Personal Information transmitted to our Site or Services. Any transmission of Personal Information is at your own risk.

How long we keep your data

We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Information are available on request by emailing us at hello@imparture.com.

Accessing your data

Under the General Data Protection Regulation 2016/679 (the GDPR) data subjects located in the EU have the right under certain circumstances:

  • To be provided with a copy of your Personal Information held by us;
  • To request that we correct any of your Personal Information held by us;
  • To request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example);
  • To object to any further processing of your Personal Information, including the right to object to marketing;
  • To request that the Personal Information you have provided be transferred to a third party;
  • To withdraw consent: Where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent without detriment at any time;
  • To request that we delete any of your Personal Information held by us.

To exercise any of the rights outlined above, please email us at hello@imparture.com.

You will not have to pay a fee to access your Personal Information (or to exercise any other rights). We may, however, charge a fee if we believe your request is excessive, unfounded, or repetitive. Alternatively, we may refuse to comply with your request in these circumstances.

In response to any of the requests outlined above, we may need to request specific information from you to enable us to confirm your identity and to ensure you have the right to access your Personal Information (or to exercise any of your other rights).

This is a security measure to ensure that your Personal Information is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response time.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated.

If your request or concern is not satisfactorily resolved by us and you are located in the EU, you may approach your local data protection authority (see https://bit.ly/2GMFRHa) who can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.

How to tell us about an update to your data

It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information that you have provided to us through your use of the Site or Services by sending an email to hello@imparture.com.

If you have questions about unsubscribing from email or other communications, you may send an email to hello@imparture.com.

Please share any suggestions you may have for improving this Privacy Policy, by sending an email to hello@imparture.com.

Website Disclaimer

Whilst Imparture uses all reasonable efforts to ensure that the information published on this website is accurate, current, and complete at the date of publication, no representations or warranties are made (express or implied) as to the accuracy, currency or completeness of such information.

Imparture cannot accept any responsibility (to the extent permitted by law) for any loss arising directly or indirectly from the use of, or any action taken in reliance on, any information appearing on this website or any other website to which it may be linked.

Imparture makes no warranty that this website is free from errors, defects or viruses.

Use of External Links

The Site or Services may, from time to time, contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We have no control over these third parties and we are not responsible for the content of such websites or for the privacy policies or practices of such third parties.

You should review the privacy policy carefully for any third-party website that you visit.

Copyright notice

The entire contents of this website (except the crown copyright location maps) are the property of Imparture and are subject to copyright with all rights reserved. You may download or print individual sections of the website for personal use and information only provided that these properly indicate Imparture’s copyright and other proprietary notices.

You may not reproduce (in whole or in part), modify, decompile, disassemble or transmit or use for any commercial purpose whatsoever any information from this website without Imparture’s prior written consent.

How this Privacy Policy might change

From time to time, we may revise or update our Privacy Policy. We will notify you of any changes by posting updates to the Privacy Policy on this web page. The date the Privacy Policy was last revised is identified at the top of the page.

Get in touch

If you have any further questions about this Privacy Policy or Imparture’s privacy practices, please contact us at the information below:

Imparture Inc

80 Broad Street, 5th Floor, New York, NY 10004, United States

Email address: hello@imparture.com

Phone: +1 855 344 4847

Last Updated: 24th May 2018