This privacy policy (“Privacy Policy”) explains how we, goPMO, Inc. (“goPMO”, “we”, “us” and/or “our”), handle personal information and data for you (“User”, “you”, “your”), and for others that use our platform and related sites (the “Websites”). This Privacy Policy applies to our Project Delivery Platform and all software products offered.

Impel ^X is a fully owned product of goPMO, Inc. As such, it fully supports and implements Impel ^X ’s Privacy Policy.

KEY PRIVACY POINTS:

IF YOU CREATE PROJECTS:

• Your project data is owned by you. Not only that, but goPMO treats your projects as if they were private. We don’t sell them to anyone and we don’t use the project data you create for purposes unrelated to you or our services, except in a limited set of circumstances (e.g. if we are compelled by a subpoena, or if you’ve given us permission to do so).
• We safeguard users’ email addresses. We don’t sell these email addresses and we use them only as directed by you and in accordance with this Privacy Policy. The same goes for any email addresses collected by your projects.
• Project data is stored on servers located in the United States.  goPMO will process your project data on your behalf and under your instructions (including the ones agreed to in this Privacy Policy).

WHAT INFORMATION DOES goPMO COLLECT?

When you use goPMO, we collect information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.

INFORMATION WE COLLECT DIRECTLY FROM YOU

• Registration information. You need an Impel ^X account before you can create projects on Impel ^X . When you register for an account, we collect your name, password and email address. If you choose to register by using a third party account (such as your Google or Facebook account), please see “Information from third parties” below.
• Billing information. If you make a payment to goPMO, we require you to provide your billing details, such as a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder.
• Account settings. You can set various preferences and personal details on pages like your account settings page.
• Other data you intentionally share. We may collect your personal information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial, or participate in a goPMO contest.

We don’t share or abuse your users’ email addresses. Rest assured, we will not email your project participants, nor will we sell those email addresses to any third parties, unless it is at your specific direction.

INFORMATION WE COLLECT ABOUT YOU INDIRECTLY OR PASSIVELY WHEN YOU INTERACT WITH US

• Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most Websites today, the web servers for the Websites keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses.
• Device data. We collect data from the device and application you use to access our services, such as your IP address and browser type. We may also infer your geographic location based on your IP address.
• Referral data. If you arrive at the Websites from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
• Information from third parties. We may collect your personal information or data from third parties if you give permission to those third parties to share your information with us. For example, you have the option of registering and signing into the Websites with your Facebook account details. If you do this, the authentication of your logon details is handled by Facebook and we only collect information about your Facebook account that you expressly agree to share with us at the time you give permission for your goPMO account to be linked to your Facebook account.
• Information from page tags. We use third party tracking services that employ cookies and page tags (also known as  web beacons ) to collect aggregated and anonymized data about visitors to our Websites. This data includes usage and user statistics. Emails sent by goPMO or by users through our services may include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We do this to allow the email sender to measure the performance of their email messaging and to learn how to improve email deliverability and open rates.

HOW DOES goPMO USE THE INFORMATION WE COLLECT?

We treat your project data as information that is private to you. We do not use your project data other than as described in this Privacy Policy or unless we have your express consent. We do not sell your project data to third parties without your permission.

Generally, we use the information we collect from you in connection with providing our services to you and, on your behalf, to your project participants. For example, specific ways we use this information are listed below.

1. To provide you with our services.
   • This includes providing you with customer support, which requires us to access your information to assist you (such as with project design and creation or technical troubleshooting).
   • Certain features of our services use the content of your project data and your account information in additional ways. Feature descriptions will clearly identify where this is the case. You can avoid the use of your project data in this way by simply choosing not to use such features.
   • If you choose to link your goPMO account to a third party account (such as your Google or Facebook account), we may use the information you allow us to collect from those third parties to provide you with additional features, services, and personalized content.
2. To manage our services. We internally use your information, including certain project data, for the following limited purposes:
   • To monitor, maintain, and improve our services and features. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, project data and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. We may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research and development purposes.
   • To enforce our  Terms of Use .
   • To prevent potentially illegal activities.
   • To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
   • To create new services, features or content. We may use your project data and project metadata (that is, data about the characteristics of a project) for our internal purposes to create and provide new services, features or content. In relation to project metadata, we may look at project activity statistics for informational or marketing purposes. When we do this, no individual users will be identified or identifiable unless we have obtained their permission.
3. To facilitate account creation and the logon process. If you choose to link your goPMO account to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate the account creation and login process. For more information,
   Contact Us .
4. To contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You can’t opt out of these communications since they are required to provide our services to you.
5. To contact you for marketing purposes. We will only do this if you have consented to our contacting you for this purpose.
6. To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

WITH WHOM DO WE SHARE OR DISCLOSE YOUR INFORMATION?

WE DON’T SELL YOUR project DATA, UNLESS YOU EXPRESSLY PERMIT US TO!

When might we disclose your project data to third parties? Only for a limited number of reasons. We share your information with our service providers who help us to provide our services to you. We contractually bind these service providers to keep your information confidential and to use it only for the purpose of providing their services. For example, we use payment processors who help us to process credit card transactions. By using our services, you authorize goPMO to sub-contract in this manner on your behalf. In rare circumstances, we may share information if required by law, or in a corporate restructuring or acquisition context (see below for more details).

Sharing your projects with the public. By default, your projects are private. You are able to control who can participate your project by changing your settings. For example, projects can be made completely public (and indexable by search engines), password protected, or distributed to a restricted list of people.

We recognize that you have entrusted us with safeguarding the privacy of your information. Because that trust is very important to us, the only time we will disclose or share your personal information or project data with a third party is when we have done one of three things, in accordance with applicable law: (a) given you notice, such as in this Privacy Policy; (b) obtained your express consent, such as through an opt-in checkbox; or (c) de-identified or aggregated the information so that individuals or other entities cannot reasonably be identified by it. Where required by law, we will obtain your express consent prior to disclosing or sharing any personal information.

We may disclose:

• Your account details to your billing contact. If your details (as the account holder) are different to the billing contact listed for your account, we may disclose your identity and account details to the billing contact upon their request (we also will usually attempt to notify you of such requests). By using our services and agreeing to this Privacy Policy, you consent to this disclosure.
• Your email address to your organization. If the email address under which you’ve registered your account belongs to or is controlled by an organization, we may disclose that email address to that organization in order to help it understand who associated with that organization uses goPMO, and to assist the organization with its enterprise accounts.
• Aggregated or de-identified information to third parties to improve or promote our services. No individuals can reasonably be identified or linked to any part of the information we share with third parties to improve or promote our services.
• The presence of a cookie to advertise our services. We may ask advertising networks and exchanges to display ads promoting our services on other websites. We may ask them to deliver those ads based on the presence of a cookie, but in doing so will not share any other personal information with the advertiser. Our advertising network partners may use cookies and page tags or web beacons to collect certain non-personal information about your activities on this and other websites to provide you with targeted advertising based upon your interests. If you do not wish to have this information used for the purpose of serving you such targeted ads, you may opt-out by contacting us. You will continue to receive generic ads.
• Your information if required or permitted by law. We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.
• Your information if there’s a change in business ownership or structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between goPMO entities, you expressly consent to goPMO transferring your information to the new owner or successor entity so that we can continue providing our services. If required, goPMO will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.
• Information you expressly consent to be shared. For example, we may expressly request your permission to provide your contact details to third parties for various purposes, including to allow those third parties to contact you for marketing purposes. (You may later revoke your permission, but if you wish to stop receiving communications from a third party to which we provided your information with your permission, you will need to contact that third party directly.)

WHAT ARE YOUR RIGHTS TO YOUR INFORMATION?

You can:

• Update your account details. You can update your registration and other account information on your My Profile page. Information is updated immediately.
• Access and correct your personal information. You may access and correct the personal information that goPMO holds about you. This right may be exercised by visiting your My Profile page or by contacting customer support. This right is subject to some exceptions, such as where giving you access would have an unreasonable impact on the privacy of other individuals. We will respond to your request for access or correction within a reasonable time and, where reasonable and practicable to do so, we will provide access to your personal information in the manner requested by you.
• Download/backup your project data. Depending on what subscription plan you have, we provide you with the ability to export, share and publish your project data in a variety of formats. This allows you to create your own backups or conduct offline data analysis.
• Delete your project data. Deleting project data in the application not permanently delete project data immediately. As long as you maintain an account with us, we may retain your deleted data for a limited time in case you delete something by accident and need to restore it (which you can request by contacting customer support). To the extent permitted by law, we will permanently delete your data if you request to cancel your account. However, if your data was previously made available to the public through a public link, additional copies of your data may remain available on the Internet even after your account has been deleted.
• Cancel your account. To cancel and delete your account, please contact customer support. Deleting your account will cause all the project data in the account to be permanently deleted from our systems within a reasonable time period, as permitted by law, and will disable your access to any other services that require a goPMO account. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).

For how long do we retain your data? We generally retain your data for as long as you have an account with us, or to comply with our legal obligations, resolve disputes, or enforce our agreements. Data that is deleted from our servers may remain as residual copies on offsite backup media for up to approximately 12 months afterward.

SECURITY, COOKIES AND OTHER IMPORTANT INFORMATION

Changes to this Privacy Policy. We may modify this Privacy Policy at any time, but if we do so, we will notify you by publishing the changes on the Website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you do not cancel your subscription and continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our Privacy Policy. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you may close your account at any time.

• Details about goPMO’s security practices are available in our Security Statement. We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the internet.
• Data locations. Our servers are based in the United States, so your personal information will be hosted and processed by us in the United States. Your personal information may also be processed in, or transferred or disclosed to, countries in which goPMO subsidiaries and offices are located and in which our service providers are located or have servers.
• We use cookies on the Websites. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies for several reasons:
  • To make our site easier to use. If you use the “Remember me” feature when you sign into your account, we may store your username in a cookie to make it quicker for you to sign in whenever you return to goPMO.
  • For security reasons. We use cookies to authenticate your identity, such as confirming whether you are currently logged into goPMO.
  • To provide you with personalized content. We may store user preferences, such as your default language, in cookies to personalize the content you see. We also use cookies to ensure that users can’t retake certain projects that they have already completed.
  • To improve our services. We use cookies to measure your usage of the Websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimize the content we display to users.
  • To advertise to you. We, or our service providers and other third parties we work with, may place cookies when you visit our Websites and other websites or when you open emails that we send you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. For instance, we may evaluate which ads are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don’t want to receive ads that are tailored to you based on your anonymous online activity, you may “opt out” of many of the companies that are involved in such tailoring by going to
    http://www.aboutads.info . Opting out in this way does not mean you will not receive any ads; it just means that you will not receive ads from such companies that have been tailored to you based on your activities and inferred preferences.
  • Google Analytics. In addition to the above, we have implemented on our Websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our Websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad
    Preferences Manager  and learn more about how Google serves ads by viewing its
    Customer Ads Help Center . If you do not wish to participate in Google Analytics, you may also download the
    Google Analytics opt-out browser add-on .

We don’t believe cookies are sinister, but you can still choose to remove or disable cookies via your browser. Refer to your
web browser’s configuration documentation  to learn how to do this. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our Websites. By using our Websites and agreeing to this Privacy Policy, you expressly consent to the use of cookies as described in this Privacy Policy.

YOUR CALIFORNIA PRIVACY RIGHTS

A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes.