Last modified: October 8, 2019

This Data Privacy Policy (“Privacy Policy”) describes how Imanum Consulting (herein referred to as “We”/“Us”/“Our”), processes personally identifiable data and personal information (“Personal Data”) as data controller.

This Privacy Policy applies to individuals who are visiting our owned or operated Websites such as www.theactframework.com (collectively referred to as “Sites”).

As part of our efforts to facilitate and make your experience with our Site as user-friendly, enjoyable and productive as possible, We may collect and use certain information you provide to us directly or we may receive indirectly from another legally permissible basis.

Please review the entire policy to learn about the types of Personal Data We process, what Personal Data is disclosed to third-parties, and how We protect Personal Data.

1. Information We Collect – Categories of Personal Data

As you interact with Us and use our Sites, We collect and use Personal Data such as:

General contact information. Contact details include name, email address, physical (work) address, phone number, company, job title, gender, as well as account information.

Digital ID. Information regarding your digital identity, such as login name, screen name, nickname, or handle; device information like manufacturer and model of your device; Internet Service Provider (ISP); Internet Protocol (“IP”) address (or another device identifier); browser type; and operating system as well as metadata (e.g. location, cookies, access times and dates, referring/exit pages, clickstream data, pages of the Sites that you visit; the time spent on those pages or interacting with certain portions of the Sites, information you search for on the Sites).

Any other not listed and voluntarily given personal information about you.

We do not collect or use any sensitive Personal Data and do not want you to provide us with such. Sensitive Personal Data are special categories of Personal Data which is by law considered more sensitive, such as: racial or ethnic origin, political opinions, religious and philosophical beliefs, or trade-union membership, genetic or biometric data, health data, sex life or sexual orientation.

2. How is Personal Data Collected – Source of processing

2.1 Information you directly provide to Us. If you use our Sites or communicate with us (email, web forms, social media or other means of communication), you may be required to provide us certain information and Personal Data, by filling in forms on our Sites, subscribing to or using our information, posting material, requesting further information or services; or by responding to surveys that We ask you to complete for research purposes.

2.2 Information from your use of our Sites. We collect your usage information on our Sites, including your access times, location, browser types and language, and IP addresses to track and aggregate information (e.g. We use IP addresses to monitor the regions from which you navigate our Sites or when you log into our Sites). We may collect device-specific information when you access our Sites, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device's interaction with our Sites. This information is collected automatically by our servers when you access our Sites and is statistical data, which may or may not include Personal Data, but We may maintain it or associate it with Personal Data We process in other ways or receives from third-parties. It helps us to improve and to deliver better and more personalized services, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our services according to your individual interests, speed up your searches and recognize you when you return to our Sites.

The technologies We use for this automatic data collection may include:

  • Cookies. A cookie is a small file placed on your computer. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see section below “Cookies”.
  • Web Beacons. Pages of our services or our e-mails may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

We also collect Personal Data from interactions with and use of certain functionalities, such as:

  • Messaging. The Sites provide messaging to enable users to communicate with one another and/or with us. We collect communications made between users using the Sites’ messaging for legitimate business purposes, including in the course of customer service investigations regarding user complaints and disputes between users.
  • Public Forums. If you use any bulletin board, chat room, comment posting feature, or other public communication service, forum, or feature offered through the Sites, or post any information available for viewing by other users, any of the information that you share will be visible to other users. The information that you make available can be read, used, and collected by other users to send you unsolicited messages outside of the Sites. We is not responsible for the manner in which the Personal Data that you decide to share in this way will be used by other users.
  • Information from Other Sources. We may also collect information about you from:
    • publicly available sources;
    • our business partners, including marketing partners, service providers or hosting services;
    • our events you may attend, or from social networks, and
    • third-party analytics service providers.
3. Legal basis for Personal Data Processing

We process Personal Data about you only if we have a valid legal basis for such a processing, which may be as follows:

  • Consent. You have given Us or any third party on behalf of Us the consent that We are allowed to process your Personal Data. If the processing of your Personal Data is only based on your consent, you have the right to withdraw and/or reject your consent at any time (see section 8).
  • Contract. For the performance of a contract between Us and you or to take steps prior to entering into such a contract;
  • Legitimate Interest. In case the processing is necessary to pursue the legitimate interest of We or a third party. In all circumstances, We will limit a processing based on the legitimate interest to what is necessary for its purpose. If the processing of your Personal Data is only based on our legitimate interest, you have the right to object such processing of your Personal Data at any time (see section 8). Legitimate interest includes but is not limited to the following data collection:
    • communications, marketing and intelligence – including processing data for direct marketing purposes and to determine the effectiveness of our promotional campaigns and advertising;
    • fraud detection and prevention (crime prevention);
    • enhancement of our cybersecurity, including improving the security of our network and information systems; and
    • general corporate operations and due diligence;
  • Compliance. In case the processing is necessary for compliance with any legal rights and obligations to which We are subject.
4. Usage of your Personal Data

We use Personal Data only in compliance with the purposes for which your Personal Data was collected or subsequently authorized by you. We will take reasonable technical and organizational measures to ensure that Personal Data is relevant to its intended use, accurate, complete, and current.

Purpose of Processing

Categories of Personal Data

Legal Basis

Contract. We use your Personal Data to carry out our obligations and enforce our rights arising from any contracts entered between you and/or our business partners and us, and collection and to notify you about changes.

General Information

Fulfilment of a contract (if it is a direct contract) or our legitimate interest (if you are an employee of our contracting party) to fulfil our contractual obligations.

Marketing Communication. We use your Personal Data to send you news and information and to communicate with you. You may opt-out at any time of receiving promotional emails from us by following the instructions in those emails.

General Contact Information

Digital ID

Your consent and/or our legitimate interest to promote our products and services.

Compliance. To protect our rights or property to investigate and prevent fraud or other illegal activities

General Contact Information

Digital ID

Any additionally given information

Our legitimate interest and legal obligation to protect our interests

Data Accuracy. We use your Personal Data to compare information for accuracy and verify your identity.

General Contact Information

Digital ID

Fulfilment of a contract (if it is a direct contract) or our legitimate interest (if you are an employee of our contracting party) to fulfil our contractual obligations, improve and secure our Sites, customer support or any other communication.

Specific Purpose. We may use your Personal Data for any other purpose disclosed to you relating to our services or to fulfil any other purpose for which you provide your Personal Data.

General Contact Information

Digital ID

Any additionally given information

Your consent and/or our legitimate interest to such specific purpose.

We may combine Personal Data about you that We have collected from different sources, for example, by combining publicly available information from various sources to help analyse sales opportunities.

5. Sharing of Personal Data – Recipients

Processors. We share Personal Data with contractors, service providers and other third parties who carry out the processing of Personal Data on behalf of Us (“Processors”) under a written contract and only with such Providers who provide sufficient guarantees to implement appropriate technical and organisational measures to protection your Personal Data. Furthermore, Processors are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which We disclose Personal Data to them. We may provide Personal Data to our Processors including but not limited to facilitate the Sites; to provide the Sites or portions of the Sites on our behalf; to perform related services including, maintenance services, database management, fulfilment, web analytics, and improvement of the features or functionality; or to assist us in analyzing how the Sites are being used.

Third Parties. We share Personal Data with third parties who determine the purposes and means of processing on its own. We share Personal Data for any lawful purpose to which you have expressly consented or directed, or to fulfil the purpose for which you provided the Personal Data to us. For a detailed list of third-parties, please see visit https://www.theactframework.com/partners. In case We may disclose Personal Data to another third party not listed, We will inform about such a disclosure at the time first disclosed to such third party. Please note, recipients of Personal Data may be located in another state where you are located (see section International Transfer).

  • Law and Protection. We may release Personal Data when We believe in our sole discretion, that such release is appropriate and necessary: to comply with any court order, subpoena, law or legal process, including to respond to any government or regulatory request; to enforce agreements, We have in place with you, to protect the rights, property, or safety of Us, our business partners or others; to prevent activity that We believe in our own discretion, may be or may become illegal, unethical, or legally actionable (including exchanging Personal Data with other companies and organizations for fraud protection).
  • Advertisers/Cookie Providers. We may release aggregate and anonymized/pseudonymized Personal Data to advertisers and other third parties in order to promote or describe use of the Sites.
6. Retention of your Personal Data

We retain Personal Data for a period consistent with the purpose of processing. We keep Personal Data for no longer than reasonably necessary for the use of our Sites and for a reasonable period afterward. We also may retain Personal Data during the period needed for us to pursue our legitimate business interests (such as back up and archive, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements (if any).

7. Rights to Personal Data

In addition to the information provided in this Privacy Policy, you have the following rights.

  • Right of access: You have the right to obtain a confirmation as to whether or not Personal Data concerning you are being processed by Us and, where that is the case, access to the personal data and receive detailed information about the concrete processing.
  • Right to rectification: You have the right to obtain correction or change of your Personal Data if your Personal Data are inaccurate or out of date. In addition, and considering the purposes of the processing, you have the right to have your Personal Data completed, including by means of providing a supplementary statement.
  • Right to be forgotten: You have the right to obtain a deletion of your Personal Data if your Personal Data is no longer necessary for Us to retain. If you want to completely delete all your Personal Data, your account may become deactivated and filed information will be irrevocable deleted. However, We may retain an archived copy of your records as required by law or based on our legitimate interest, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes. In such instance, We will inform you accordingly.
  • Right to restriction: You have the right to obtain a restriction of the processing of your Personal Data, if you have contested the accuracy of your Personal Data, the processing if unlawful, We no longer need the Personal Data or you have objected the processing of your Personal Data, provided that all legal requirements are met.
  • Right to object/withdraw: You have the right to object to process your Personal Data, if We do not have no other legitimate grounds besides your consent on doing so, unless We can demonstrate compelling legitimate grounds for a further processing.
  • Right to data portability: You have the right to receive a copy of your Personal Data which We process.
  • Right to lodge a complaint with a supervisory authority. Since We are located in Austria, you have the right to lodge a complaint pursuant to Art 77 GDPR with the Austrian Data Protection Authority “Datenschutzbehörde” (www.dsb.gv.at).

We do not base its decisions solely on automated processing of Personal Data, including profiling, which would produce legal effects or similarly significantly effects on you.

If you have any question regarding your privacy rights or if you want to update or correct information about yourself you can contact us any time (see section, contact details below).

8. Third-Parties: Service Providers, Links to other Sites, Third-Party Advertising

This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by third parties that you may visit e.g. via a link provided through the Sites or on a website maintained by any third party. We are not responsible for and does not control the (privacy) practices of any third-party websites or service providers to whose websites We may link.

Some content or applications, including advertisements, on or through our Sites are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third-parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Sites. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. Please contact the responsible provider directly.

9. International data Transfer

We process and store Personal Data in the United States and other countries and uses third-party service providers, which may be outside of your country of origin.

We are committed to comply with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data. Where the law of your country of origin requires your express consent to disclose Personal Data to service providers located in countries outside of your country of origin, you consent to such disclosure and acknowledge in respect of such disclosure that (i) you may not be able to seek redress under the laws applicable in your country of origin, (ii) the overseas recipient may not be subject to the same privacy obligations, (iii) you may not be able to seek redress in the overseas jurisdiction; and (iv) the overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

 

10. Security

We employ administrative, physical, and technical measures designed to protect your information from unauthorized access. We take a proactive approach to its security program to ensure the level of security is appropriate to the risk, considering technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms.

Please note that no security system is impenetrable. Accordingly, We cannot guarantee the security of our databases, nor that information you supply won't be intercepted. We are not responsible for circumvention of any privacy settings or security measures contained on or within our Sites. Where you have chosen a password for access to certain parts of our Sites, you are responsible for keeping this password confidential and you should not share your password with anyone.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Data to you via email or posting through the Sites in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

11. Children’s Privacy

Our Sites are directed to business users only and not directed to minors younger than sixteen (16) years of age nor intends to process Personal Data from minors under 16. If you are under 16 years, do not use the Site and do not send any information about yourself to us.

12. Cookies

We use cookies on our Sites, and you are giving consent in accordance with this Privacy Policy to cookies being used by accepting the notification banner. If you do not agree to the use of cookies in the way as described herein, you need to set your browser settings accordingly or not use our Sites.

  • Cookie Definition. Cookies are small files that are sent to and stored on your computer or mobile device. They are generally used to make websites and cloud-based services work better and more efficient, e.g. they can recognize you and remember important information that will make your visit of a website or cloud-based service more convenient (e.g., by allowing you to enter a password less frequently or remembering user preferences). Taken alone, cookies do not personally identify you – rather, they merely recognize your web browser. Unless you choose to identify yourself to Us, either by opening an account, filling out a web form (such as by signing up for a free trial) or you have previously identified yourself to us, you remain anonymous.
  • Cookie Usage. We may use cookies and other tracking technologies to deliver and improve our Sites, to display relevant content, products and services, and for other important purposes which are identified herein. This section describes how We may use cookies and other tracking technologies to deliver and improve the Sites, to display relevant content, products and services on the Sites, and for other important purposes and applies when you visit, access, or use our Sites that are owned or operated by Us.

By clicking “Agree and Proceed” on our cookie pop-up notice or clicking to close the cookie pop-up notice on our Sites, you agree that you have affirmatively consented to and opted-in to our use of cookies as described herein. Further, by using the Sites, you agree that We can use these technologies as described herein.

  • Types of Cookies. We use different types of cookies on our Sites to make your interaction easy and meaningful. The Sites may include first-party cookies, that send data directly to Us and contractors acting on our behalf, including cookies used to monitor, analyze, and administer the Sites, and third-party cookies, that send data to our contractors for their own commercial use. Further, We use session cookies, which exist only during one session and disappear from your computer or device when you close your browser, and persistent cookies, which remain on your computer or device after you close your browser.
  • Strictly Necessary Cookies. These cookies are essential to the operation of our Sites. They are used to facilitate our log-in process, authenticate users, and enable you to navigate the Sites and to use their features. They are also used by our employees for in product messaging and analytics. Without these cookies, We may not be able to provide certain Sites may not perform as smoothly for you as We would like.
  • You have no option to opt-out of the use of strictly necessary cookies, since they are essential to operate our Sites.
  • Functionality Cookies. These cookies allow us to remember the choices you make while visiting our Sites and to provide enhanced and more personalized content and features, such as customizing a certain webpage or application page, remembering if We has asked you to participate in a promotion and for other services you request, like watching a video or commenting on a blog. To permit your connection to the Sites, our servers receive and record information about your computer and browser, potentially including your IP address, browser type, and other software or hardware information. These features help us to improve your visit and assist in navigation of the Sites’ features.
  • You may manage, or to opt out of the use of functionality cookies on our Sites, please see instructions below. Opting out may impact the functionality you receive when using our Sites.
  • Analytics Cookies. We and our service providers may use analytics cookies, to collect information and enable us to improve them by collecting information how you use the Sites, for instance, which pages you go to most. The information allows us to see the overall patterns of usage, help us record any difficulties users may have while using the Sites and show us if our advertising is effective.
    • We use Google Analytics. Google Analytics is a website analytics technology. Google places cookies on our Sites so that our Sites can users interact with our Sites. For information on how to reject or delete this cookie, please visit: https://www.tools.google.com/dlpage/gaoptout 
  • You may manage, or to opt out of the use of analytics cookies on our Sites, please see instructions below. Opting out may impact the functionality you receive when using our Sites.
  • Advertising Cookies. We may also use cookies and similar tools to correlate your use of the Sites to personal information obtained about you. For example, if you have asked us to provide you information about our upcoming products, our services or any promotions, We may utilize our cookie and/or clickstream data about your activities when you engage with us on the Sites. By evaluating this information, We may more clearly target the information provided to you to the specific items We thinks you will find interesting, based on your prior online activities and preferences. We also use third-party advertising cookies. We and our service providers may use advertising cookies to deliver ads that We believes are more relevant to you and your interests.
  • You may manage, or to opt out of the use of advertising cookies on our Sites, please see instructions below. Opting out may impact the functionality you receive when using our Sites.
  • Third-Party Cookies/Social Plugins. We may work with third-parties to provide services on our Sites. We use analytics services supported by third-party companies who generate analytics cookies. We may not have access to these cookies, although We may use statistical information arising from the cookies provided by these third parties to customize content and for the other purposes described above. These companies may also transfer this information to other parties where required to do so by law, or where such other parties process the information on their behalf.

We do not control these third-party cookies; their use is governed by such third-parties. You can visit their privacy policy here and cookies information here.

  • Control of Cookies. If you want to control cookies, you could view cookies stored on your hard drive, choose if to permit cookies to be set by default by changing browser settings or delete the cookies stored on your hard drive. The main web browsers allow you to change your cookie settings directly through their sites and are typically found in the ‘options’ or ‘preferences’ menu of your browser. Please be aware, that your decision to control cookies may affect your experience of our Sites. Turning cookies off, for instance, will prevent you from registering for, signing in to, and using many of the services on our Sites.
  • “Do not Track”-Signal. Some web browsers may be configured to send “Do Not Track”-signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies may not be used to track the user’s online activity.
13. Changes to Privacy Policy

From time to time We may change this Privacy Policy with or without prior notice to you. You can tell when changes have been made to the Privacy Policy by referring to the version. Please review this Policy regularly to ensure that you are aware of any changes. If We materially change the usage and disclosure of Personal Data, We will post a notice on our Site and send an e-mail to our registered users. We will also keep prior versions of this Privacy Policy in an archive for your review.

14. Contact

If you have any questions or concerns about this Privacy Policy or your Personal Data, please contact us:

Email: contact@theactframework.com