IMTC Privacy Policy

This Privacy Policy (“Policy”) explains what data IMTC collects from visitors and users of the IMTC and app.IMTC.com web sites (collectively called the “Site”), why the information is collected, and how it is used. This Policy also explains user options for accessing and managing information, our Site’s data security practices, and other matters. We may amend this Policy at any time by posting the amended version on the Site.

I. Information We Collect

IMTC collects many kinds of information in order to operate effectively and provide you the best products, services and experiences we can. We collect information when you provide it to us, such as when you purchase a product/service, register, sign in, or call us for support. We may also automatically collect information when you use our sites, products and services. We also may get information from other companies or third parties. We automatically collect this information in a variety of ways, including from web forms, through technologies like cookies, web logging, and software on your computer, mobile, or other devices. The type of information we collect may depend on the IMTC features you use. For those who contact us via the “Let’s get connected” form on the Site, we collect your name, email address, and data concerning the purpose of message. We will also collect whatever other Personal or Commercial Information we deem necessary, to comply with our legal anti-money laundering (“AML”) obligations, or other legal/regulatory obligations.

II. How We Use Your Information

IMTC uses the information we collect to operate, improve and personalize the products and services we offer, to run our business, to develop new products, or to market to you the IMTC services and other products and services you might be interested in. More specifically, we collect your information to stay in contact around new product updates and information necessary to you as an IMTC client. We use your email address to identify your account and communicate with you. We may also use the business information you provide to us to help categorize your account based on business demographic information (such as size, industry, location, etc.), either alone or in aggregate form with data from other users. This demographic information helps us understand our customer base, improve the content and administration of the Site.
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 data. Please contact us at info@IMTC.com if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

We also may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

III. With Whom We Share User Information

Except as described in this Policy, we will not, without your permission, sell, publish or share information you entrust to us that identifies you, your company or any other person. We may share your personal information and demographic portfolio information as needed to complete any transaction or provide any service you have requested or authorized with third party vendors or affiliates working on our behalf. We may also share or disclose your personal information with IMTC’s affiliates. If you would like to inquire further on whom we have shared your information with, you may request this information by writing to Info@IMTC.com.

We may share or disclose your personal information in certain exceptional circumstances, such as to protect against illegal hackers, to protect our legal rights (including enforcement of the Terms of Use), to address actual or threatened illegal or harmful conduct, or as required by law or legal process (e.g., a search warrant, subpoena or court order). We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other regulatory agencies. We will not share your personal information with third parties for their own purposes or benefit.

We may also use non-personal information (i.e. de-identified data) for academic, research, policy, or marketing purposes. We will only share or make available anonymous or aggregate information that cannot be used to identify you or any other person with third parties for research, policy, or academic purposes and those third parties may publicly report the findings of their research or analysis. If IMTC or its assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and any other information concerning your relationship with us or described in this Policy. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Site and such third parties will assume the rights and obligations regarding such information as described in this Policy.

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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@imtc.com.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis for which we are doing so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required by law.

IV. Security of Your Data

IMTC takes the security of your data seriously. We offer secure pages to collect information on our Contact Form. We also use administrative, physical, and technical precautions to help protect the confidentiality, security, and integrity of personal information stored on our system. IMTC is based on the Microsoft Azure Cloud and as such utilizes the security safeguards provided by Microsoft Azure to protect your data, such as identity and access management, encryption, secure networks, threat management, and compliance with international and industry-specific safety standards and practices.
While we will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information, you understand and acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

V. Retention of User Data

We currently retain user data throughout the scope of our engagement, and for a period of one (1) year thereafter. We may then purge our system of inactive historical data. We may purge inactive historical data sooner as needed to manage available data storage resources. In compliance with the General Data Protection Regulation (“GDPR’), and other privacy protection regulations, we enable all users (regardless of jurisdiction) to request for their Personal Information to be purged on an earlier date. You may also contact us to request we stop the usage of your data, correct incorrect information, and/or ask questions regarding your data usage and storage.
Notwithstanding the above, we will retain documents (including electronic documents) containing personal data to the extent that we are required to do so by law; if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

VI. Children’s Information

The Site and our services are not intended for use by children. Please note that we do not intend to collect any personal information from children and no child should submit any personal information to the Site. Should we discover that any such personal information has been delivered to the Site, we will remove that personal information as soon as possible.

VII. Cookies; Web Beacon and Similar Technologies

We use cookies and similar technologies, including mobile app identifiers, to help us recognize you across different services, products, learn about your interests both on and off our services, improve your experience, increase security, offer products, measure use and effectiveness of our services, and serve advertising. Most browsers provide you with the ability to control (i.e. block, delete, or disable) these technologies. You should be aware that some technologies are essential and you will not be able to disable or turn off this functionality. If you choose to reject cookies or similar technologies, some services may not be available or some functionality may be limited or unavailable. Please review your browser manufacturer’s help pages for assistance with changing your settings. By visiting our services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Policy. For more information regarding cookies, please refer to our Cookie Policy. If you have concerns about the essential tracking technologies, please contact info@IMTC.com.

VIII. Your Consent to This Policy

By using the Site, you agree to this Policy. This Policy supersedes any prior communication on this topic and reflects the entire and exclusive policy for the Site. This Policy is subject to any further contract formed between IMTC and the User, which take precedence over any conflicting Policy provision. We may change our Policy by posting a new version of it on our Site. Please review the content of this Policy periodically. All changes are effective immediately upon posting on the Site and your continued use of our Site and services after an update to the Policy is posted constitutes acceptance of the latest version of this Policy.

IX. Your Rights Regarding Personal Information

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact info@IMTC.com.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Under certain circumstances, if you are located in the United Kingdom or Europe, under applicable data protection laws, you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate personal information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

X. Contact Us

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us via info@imtc.com

Last updated: January 2024