Scope of Privacy
Notification of Changes to this Policy
We are continually improving our methods of communication and adding new functionality and features to the Website and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. We encourage you to check this page frequently to review this policy so that you are aware of any changes, since any changes shall take effect upon posting.
Collection of Personal Data Including E-mail Addresses
You may choose to buy products from us or receive additional information or services from us. When you purchase our products and services or request additional information, we (or a third-party provider) will request personal information about you such as your name, postal address, e-mail address, telephone number and payment details. We may also ask for demographic information to enable us to provide a personalized service to you. The information you provide is either manually or electronically stored in our databases. We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate postal or zip codes are received, we may use third party software to correct them.
Use of Personal Data
We will use your personal data to fulfill your requests and we will ask only for data that is adequate, relevant and not excessive for these purposes. Where we send you information for any purpose, it may be sent by e-mail or regular mail. When we ask you for personal data it may relate to, but is not limited to, the following purposes:
- We may contact you to inform you of new products and services we will be providing;
- We may send you regular updates on issues we think are of interest to you;
- We may send you requested information on our products and services;
- We may use your personal data for marketing purposes and market research; and
- We may use your personal data internally to administer the Website and to improve our services.
We hope you will be delighted with our products and services. If you no longer wish to receive electronic mail or regular mail, please reply to the e-mail with the word “remove” in the subject heading, or, by writing to us at: The IMAGINE Group, LLC., 1000 Valley Park Drive, Shakopee, MN 55379, Attn: Manager – Customer Service
Anonymous Data Collected Through this Website
In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Website. For example, our web server automatically logs which pages of the Website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our Website. The Website contains hyperlinks to other pages on the Website. We may use technology to track how often these links are used and which pages on our Website our visitors choose to view. Again, this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.
In order to collect the anonymous data described herein, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies should not damage your computer, and you can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it.
We also use your IP address to help with server problem diagnosis and to administer the Website. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from (i.e., gmail.com, yourcompany.com, etc.) to more accurately gauge our users’ demographics.
Disclosure of Your Personal Data
- In order to provide you with the information, services or products which you have requested, personal data may occasionally be transferred or shared with other companies within our group of companies, with other companies that you work with and third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented. For example, sometimes a third party may have access to your personal data in order to support our information technology, process payment or to handle mailings on our behalf.
- We will keep your contact details on our database and may where you have consented deliver via e-mail or regular mail information about our other products and services. If you do not wish to receive e-mails or mail from us for these purposes, please let us know by following the “unsubscribe” procedure described herein.
- Where you have consented, we may also share your personal data with other companies within our group of companies or disclose your personal data to other businesses who may contact you on our behalf or about their products or services that may interest you.
- We may share, transfer or disclose the information in our databases and server logs to comply with a legal requirements, for the administration of justice, to interact with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this Website, to protect us from legal liability, or in the event of our sale, merger, reorganization, dissolution or similar event.
Where appropriate, before disclosing personal data to a third party, we may contractually require a third party to take adequate precautions to protect that data and to comply with applicable law.
Data Access and Corrections
You may ask us in writing to identify for you the personal data we hold about you, and we are permitted to charge you for the costs of gathering such information. We will also correct, amend or delete any personal data that you represent to us as inaccurate and we will notify any third-party recipients of the necessary changes. You may update any information you have given to us by contacting us at firstname.lastname@example.org. Requests to delete personal data are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.
Links to Other Websites
Transfer of Data Abroad
Contact Us; Mail Unsubscribe
If you no longer wish to receive electronic mail or regular mail, please reply to the e-mail with the word “remove” in the subject heading, or, by writing to us at: The IMAGINE Group, LLC., 1000 Valley Park Drive, Shakopee, MN 55379, Attn: Manager – Customer Service.
Privacy Notice for California Residents
Effective Date: January 1, 2020
Last Reviewed: December 15, 2019
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months.
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include the following:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from CCPA’s scope, such as the following:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).
Imagine obtains the categories of personal information listed above form the following categories of sources:
- Directly from you. For example, from forms you complete.
- Indirectly from you. For example, through information we collect in the course of providing services.
- Directly and indirectly from activity on any of our Websites. For example, from submissions through a website portal or website usage details collected automatically.
- Directly from third parties, such as your employer, partners and service providers who work with us in relation our services, and publicly available sources, such as public websites, open government databases or other data in the public domain, to help us maintain data accuracy and provide and enhance our services.
Use of Personal Information
We may use or disclose the personal information for one or more of the following business purposes:
- To fulfill or meet the reason for which the information has been provided.
- To provide you with information, products, or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services, or events or news that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis, and product development, including to develop and improve our Website, product, and services.
- As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Imagine may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers
- Our affiliates
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
In the preceding twelve (12) months, Imagine has disclosed the following categories of personal information for business purposes:
- Category A: Identifiers
- Category B: California Customer Records personal information categories
- Category C: Protected classification characteristics under California or federal law
- Category I: Professional or employment-related information
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumer (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Imagine disclose specific information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, a separate list identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Imagine delete any of your personal information that we collected from you and retained, subject to specific exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to perform the following:
- Complete the transaction for which we collected the personal information, provide a good or service that you request, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Comply with a legal obligation
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either of these methods:
- Calling us: 888-776-5566
- Visiting theimaginegroup.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.
You may make a verifiable consumer request for access or data portability only twice within a 12-month period. The verifiable consumer request must contain the following:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information, if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verifiable when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forth-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures that we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not perform the following:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCP that can result in different prices, rates, or quality levels. Any CCPA-permitted financial inventive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at the following:
Phone: 952-641-1777 or 800-368-1056