PRIVACY POLICY

Version: 1.0
Last Updated: August 2025
Classification: Public
Contact: legal@impgent.com

Impgent Ltd ("Impgent", "we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, services, or interact with us.

1. INFORMATION WE COLLECT

1.1 Information You Provide

We collect information you voluntarily provide, including:

Identity Data: Name, username, title
Contact Data: Email address, telephone numbers, addresses
Professional Data: Company name, job title, department
Account Data: Username, password, preferences
Transaction Data: Payment details, purchase history
Communication Data: Feedback, support requests, correspondence
Marketing Data: Preferences, subscriptions

1.2 Information from Use of Services

We automatically collect:

Technical Data: IP address, browser type, device information
Usage Data: Pages visited, features used, interaction data
Log Data: Access times, duration, error logs
Cookie Data: As per our Cookie Policy

1.3 Information from Third Parties

We may receive information from:

Payment processors (transaction confirmations)
Analytics providers (usage patterns)
Marketing partners (lead information)
Public sources (company information)

2. HOW WE USE YOUR INFORMATION

2.1 Primary Purposes

We use your information to:

Provide and maintain our Services
Process transactions and send related information
Send administrative information and updates
Respond to inquiries and provide support
Monitor and analyze usage and trends
Detect and prevent fraud or security issues
Comply with legal obligations

2.2 Marketing and Communications

With appropriate consent, we may:

Send promotional communications
Provide information about new features
Share relevant industry insights
Invite participation in surveys or events

2.3 Legal Bases for Processing

We process personal data based on:

Consent: Where you have given clear consent
Contract: To perform our contract with you
Legal Obligation: To comply with laws
Legitimate Interests: For business operations, provided your rights are protected

3. HOW WE SHARE INFORMATION

3.1 Service Providers

We share data with providers who assist us:

Cloud hosting (AWS)
Payment processing (Stripe)
Email services
Analytics tools
AI services (Anthropic, OpenAI)

3.2 Legal Requirements

We may disclose information to:

Comply with legal obligations
Respond to lawful requests
Protect rights and safety
Investigate potential violations

3.3 Business Transfers

In connection with mergers, acquisitions, or asset sales, your information may be transferred.

3.4 Consent

We share information with your consent or at your direction.

4. DATA SECURITY

We implement appropriate technical and organizational measures:

Encryption in transit (TLS) and at rest (AES-256)
Access controls and authentication
Regular security assessments
Employee training and confidentiality
Incident response procedures
Business continuity planning

While we strive to protect your information, no method is 100% secure.

5. DATA RETENTION

We retain personal data for:

Active Accounts: Duration of service provision
Closed Accounts: 30 days for operational data
Financial Records: 7 years per legal requirements
Marketing Data: Until consent withdrawn
Cookies: As specified in Cookie Policy

6. YOUR RIGHTS

6.1 Access and Control

You have the right to:

Access your personal data
Correct inaccurate data
Request deletion (right to be forgotten)
Restrict processing
Data portability
Object to processing
Withdraw consent

6.2 Exercising Rights

To exercise rights, contact: privacy@impgent.com

We will respond within 30 days and may request identity verification.

6.3 Complaints

You may lodge complaints with supervisory authorities:

UK: Information Commissioner's Office (ICO)
EU: Relevant national authority

7. INTERNATIONAL DATA TRANSFERS

7.1 Transfer Mechanisms

We transfer data internationally using:

Standard Contractual Clauses
Adequacy decisions
Your explicit consent

7.2 Safeguards

All transfers include appropriate safeguards to protect your data.

8. COOKIES AND TRACKING

8.1 Types of Cookies

Essential: Required for site operation
Functional: Remember preferences
Analytics: Understand usage
Marketing: Deliver relevant ads

8.2 Managing Cookies

You can control cookies through browser settings. Essential cookies cannot be disabled.

9. CHILDREN'S PRIVACY

Our Services are not directed to individuals under 18. We do not knowingly collect children's personal data.

10. CALIFORNIA PRIVACY RIGHTS

California residents have additional rights under CCPA:

Right to know categories and specific pieces of data
Right to delete personal information
Right to opt-out of sale (we do not sell data)
Right to non-discrimination

11. REGION-SPECIFIC PROVISIONS

11.1 European Union (GDPR)

Legal basis required for all processing
Enhanced rights including data portability
Privacy by design implementation

11.2 United Kingdom (UK GDPR)

Equivalent protections to EU GDPR
ICO as supervisory authority
UK-specific international transfer rules

11.3 Canada (PIPEDA)

Consent requirements for collection and use
Access and correction rights
Accountability for transferred data

11.4 Australia (Privacy Act)

APP compliance
Overseas transfer restrictions
Breach notification requirements

12. AUTOMATED DECISION-MAKING

We use AI/ML for:

Service optimization
Feature recommendations
Support routing

You have the right to:

Be informed about automated processing
Request human review of decisions
Object to automated decision-making

13. CHANGES TO THIS POLICY

We may update this Policy periodically. We will notify you of material changes via:

Email notification
Service announcement
Website notice

14. CONTACT US

For privacy inquiries or to exercise your rights:

Data Protection Officer
Impgent Ltd
71-75 Shelton Street
Covent Garden
London WC2H 9JQ
Email: legal@impgent.com

For general inquiries: hello@impgent.com