Impact Maker provides this Privacy Policy to let you know our
policies and procedures regarding the collection, use and disclosure of
information through www.impactmaker.co (the "Site”), and any other related,
applications, software and services (together with the Site, the "Service”), as
well as any information Impact Maker collects offline in connection with the Service.
It also describes the choices available to you regarding the use of, your
access to, and how to update and correct your personal information. Note that
we combine the information we collect from you from the Site, through the
Service generally, or offline.
Please note that certain features or services
referenced in this Privacy Policy may not be offered on the Service at all
times. Please also review our Terms of Service, which governs your use of the
Service, and which is accessible at https://www.impactmaker.co/cms/view/2.
We’ve provided short summaries in this Privacy
Policy to help you understand what information we collect, how we use it, and
what choices or rights you may have. While these summaries help explain some of
the concepts in a simple and clear way, we encourage you to read the entire
Privacy Policy to understand our data practices.
1. INFORMATION
COLLECTION
Users of the Service may be Clients (Customer), Freelancers (Tasker),or Agencies
(as each is defined in the Terms of Service).
1.1
Information You Provide to Us
When you use the Service, you may provide us with
information about you. This may include your name and contact information,
financial information to make or receive payment for services obtained through
the Impact Maker platform, or information to help us fill out tax forms. When
you use the Service, we may also collect information related to your use of the
Service and aggregate this with information about other users. This helps us
improve our Services for you. You may also provide us with information about
your contacts or friends if, for example, you’d like to add those contacts to a
message room. Agencies may also provide us with information about Freelancers
associated with the Agency.
You do not have a statutory obligation to provide
us with any information, but you may have a contractual obligation to do so,
and if we do not receive certain information from you, then we will not be able
to provide our Service to you. If you have any questions regarding whether
provision of information is mandatory and the consequences for withholding such
information, please contact us atinfo@impactmaker.co.
1.2
Information Received from Third Parties
Third parties may also give us information about
you. If we combine that information with information about you collected
through the Service, we will still treat that combined information as set forth
in this Privacy Policy.
We also may receive information about you from
third parties. For example, we may supplement the information we collect with
outside records or third parties may provide information in connection with a
co-marketing agreement or at your request (such as if you choose to sign in
with a third-party service). If we combine the information we receive from
others with information we collect through the Service, we will treat the
combined information as described in this Privacy Policy.
1.3 Information Collected Automatically
Like other online companies, we receive technical
information when you use our Services. We use these technologies to analyze how
people use our Services, to improve how our Site functions, to save your log-in
information for future sessions, and to serve you with advertisements that may
interest you.
We and our third party service providers, including
analytics and third party content providers, may automatically collect certain
information from you whenever you access or interact with the Service. This
information may include, among other information, the browser and operating
system you are using, the URL or advertisement that referred you to the
Service, the search terms you entered into a search engine that led you to the
Service, areas within the Service that you visited, and other information
commonly shared when browsers communicate with websites. We may combine this
automatically collected log information with other information we collect about
you. We do this to improve services we offer you, to improve marketing,
analytics, and site functionality.
The information we collect also includes the
Internet Protocol ("IP”) address or other unique device identifier ("Device
Identifier”) for any device (computer, mobile phone, tablet, etc.) used to
access the Service. A Device Identifier is a number that is automatically
assigned or connected to the device you use to access the Service, and our
servers identify your device by its Device Identifier. Some mobile service
providers may also provide us or our third party service providers with
information regarding the physical location of the device used to access the
Service.
Impact Maker and its partners use cookies or similar
technologies to analyze trends, administer the website, track users’ movement
around the website, and to gather demographic information about our user base
as a whole. The technology used to collect information automatically from Impact Maker Users may include the
following:
In addition, we and our marketing partners,
affiliates, analytics, and service providers may use a variety of other
technologies (such as tags) that collect similar information for security and
fraud detection purposes and we may use third parties to perform these services
on our behalf.
1.3 HOW WE RESPOND TO DO NOT TRACK SIGNALS
Impact Maker does not respond to, or alter its
practice, when a Do-Not-Track signal is received.
1.4 User Profiles
Freelancers may create a profile, with certain or
all information publicly available. Clients and Agencies may also create
organization profiles.
You may have the opportunity to create a profile,
which consists of information about you, and may include Personal Information,
photographs, examples of your work, information on work previously performed
via the Service and outside the Service, skills, tests taken, test scores,
hourly pay rates, feedback/rating information and other information, including
your username ("Profile”). The information in your Profile may be visible to
all Impact Maker Users and the general public subject to the privacy choices
you make within your Impact Maker Profile. You may edit certain information in
your Profile via your account and may choose to limit who is able to view
certain content you post to your Profile. Clients and Agencies of associated
individual users or companies may also have the opportunity to create an
organization Profile. If, in any case, you believe that an unauthorized profile
has been created about you, you can request for it to be removed by contacting
us atinfo@impactmaker.com
1.5 Messaging
Freelancers, Agencies, and Clients may communicate
with each other through the Service. For example, Freelancers, Agencies, and
Clients may wish to discuss Client needs and Freelancer work proposals. If you
communicate with an Agency or Client, that Agency or Client will also be a
"data controller” with respect to such communications.
1.6 Community Forums
We may offer public forums or blogs. If you
participate, your comments and questions will be publicly displayed.
The Service may provide you the opportunity to
participate and post content publicly in forums, on blogs, through interactive
features Impact Maker and through other communication functionality ("Community Forums”). You may choose, through
such features or otherwise, to submit or post questions, comments, or other
content (collectively, "User Forum Content”). Please note that
certain information, such as your name and Profile may be publicly displayed on
the Service along with your User Forum Content. Please note that your use of
Community Forums is subject to the Impact Maker Forum Rules and our Terms of
Service.
Note that anything you post to a Community Forum is
public — others will have access to your User Forum Content and may use it or
share it with third parties. If you choose to voluntarily disclose Personal
Information in your User Forum Content or use Community Forums to link to your
Profile, that information will be considered public information and the
protections of this Privacy Policy will not apply.
To request removal of your personal information
from our blog or community forum, contact us at legal@usebraintrust.com. In
some cases, we may not be able to remove your Personal Information, in which
case we will let you know if we are unable to do so and why.
1.7 Testimonials
We display personal testimonials of satisfied customers
on our Service, in addition to other endorsements. With your consent we may
post your testimonial along with your name. If you wish to update or delete
your testimonial, you can contact us atinfo@impactmaker.co.
1.8 Work Listings Through the Service
If you choose to post a work listing via the
Service as a Client, the contents of such listing will be viewable publicly,
unless you designate the listing as only viewable through the Service or as private
using the settings available on the applicable website. Work listings include
information such as budget, location, history of work listing(s) by the Client,
the names of other Freelancers performing work for the Client, Client feedback
and rating information and timing of project performance.
1.9 Feedback
We collect feedback from Impact Maker Users about
their experience with other Impact Maker Users of our Service. Please note that
any feedback you provide via the Service or feedback provided about you is
publicly viewable via the Service. On very rare occasions, we may remove
feedback pursuant to the relevant provisions of our Terms of Service.
2.0 Email to Friends and Referral Program
Impact Maker lets you send project postings to
friends via email. Impact Maker also offers the ability to send friends emails
about providing or purchasing services through the Service. If you choose to
use either feature, your friend’s email address will be used to send the
requested posting and your email address will be used to copy you on the
message to your friend or to send the message on your behalf. Impact Maker
stores this information for the sole purpose of sending this one-time email and
tracking the success of our referral program.
Your friend may contact us at
legal@usebraintrust.com to request that we remove this information from our
database.
2.1 Social Networking Services
You may register for an account directly with our
Site, or through a social networking service. If you register with a social
networking service (or later link your account to one), we will collect certain
information about you from that social networking service, and what we collect
depends on your privacy settings with that social networking service. The
Service may also allow you to "like” or share content with social networking
services.
You may register to join the Service directly via
the Service or by logging into your account with a third party social networking
service ("SNS”) via our Service (e.g., LinkedIn, and other third party
services that let you sign in using your existing credentials with those
services). If you choose to register via an SNS, or to later link your account
with the Service to your account with an SNS, we will use the Personal
Information you have provided to the SNS (such as your name, email address,
gender and other information you make publicly available via the SNS) to create
your account. Note that the information we collect from and through an SNS may
depend on the privacy settings you have set with the SNS and the permissions
you grant to us in connection with linking your account with the Service to
your account with an SNS. Other than what we may share with the SNS as described
below, the Personal Information an SNS has about you is obtained by the SNS
independent of our Service, and Impact Maker is not responsible for it.
The Impact Maker Service also may permit additional
interactions between it and a third party website, service, or other content
provider, such as enabling you to "like” or share content to a third party SNS.
If you choose to "like” or share content, or to otherwise share information
from or via our Service with a third party site or service, that information
may be publicly displayed, and the third party may have access to information
about you and your use of our Service (and we may have access to information
about you from that third party). These features may collect your IP address,
which page you are visiting on our site, and may set a cookie to enable the
feature to function properly. Your interactions with third parties through an
SNS or similar features are governed by the respective privacy policies of
those third parties.
You can disable the link between your Impact Maker
account and your SNS account at any time though the "Settings” section of our
Service. Please note that your relationship with any SNS is governed solely by
your agreement(s) with such SNS. If your SNS account terminates, then functions
enabled through the link between your Impact Maker account and your SNS account
will terminate as well.
2. USE OF
INFORMATION
We use information collected through the Service to
provide and improve the Service, process your requests, prevent fraud, provide
you with information and advertising that may interest you, comply with the
law, and as otherwise permitted with your consent.
2.1WE USE
INFORMATION WE COLLECT:
We use your Personal Information for the purposes
described above:
3. DATA
RETENTION
Impact Maker retains account and purchase data as long as it is necessary to facilitate a User’s access and use of the Services. When an account is terminated, Personal Information collected will be deleted in accordance with the requirements of applicable law. Personal Information obtained from Site visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a visitor exercises its right to opt-out of requested communications or information-based services. Anonymized and Pseudo-anonymized data will be retained as long as Impact Maker determines such data is commercially necessary for it legitimate business interests.
4.
INFORMATION SHARING AND DISCLOSURE
We may share information about you to provide the
Services, for legal and investigative purposes, in connection with sweepstakes
and promotions, or if we are part of a merger or acquisition. We may also share
non-identifying information with third parties. You have choices as to whether
we share your personal information with third parties for their own marketing
purposes.
We may share aggregated Non-Identifying Information
and we may otherwise disclose Non-Identifying Information (including, without
limitation, Hashed Information) to third parties. We do not share your Personal
Information with third parties for those third parties’ marketing purposes
unless we first provide you with the opportunity to opt-in to or opt-out of
such sharing. We may also share the information we have collected about you,
including Personal Information, as disclosed at the time you provide your
information, with your consent, as otherwise described in this Privacy Policy,
or in the following circumstances:
5. THIRD
PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES
We may work with advertising agencies and vendors
who use technology to help us understand how people use our Site. These vendors
may use technologies to serve you advertisements that may interest you. You can
choose to opt out of receiving interest-based advertising.
Impact Maker works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us.If you wish to opt out of interest-based advertising, click here (or if located in the European Union, click here). If you choose to opt out, please note you will continue to receive generic ads.
While we may use a variety of service providers to
perform advertising services, some of these companies are members of the
Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA”) Self-Regulatory Program
for Online Behavioral Advertising. You may want to visit here, which provides
information regarding targeted advertising and the "opt-out” procedures of NAI
members. You may also want to visit here, which provides information regarding
targeted advertising and offers an "opt-out” by participating companies in the
DAA Self-Regulatory Program.
Impact Maker uses Google Analytics as a web analytics tool to track user behavior on the Site. Google Analytics collects anonymized information in accordance with their Privacy Policy. However, if you do not want Google Analytics to track your use, you may opt-out by installing Google Analytics Opt-out Browser Add-on.
6. YOUR
CHOICES AND RIGHTS
You have certain choices regarding how we may
communicate with you.
Registered Impact Maker Users may update their
choices regarding the types of communications you receive from us through your
online account. You also may opt-out of receiving marketing emails from us by
following the opt-out instructions provided in those emails. Please note that
we reserve the right to send you certain communications relating to your
account or use of the Service (for example, administrative and service
announcements) via email and other means and these transactional account
messages may be unaffected if you opt-out from receiving marketing
communications. You may opt-out of receiving text messages by replying "STOP”
to any text message received. Registered Impact Maker Users who access the
Service by using an Impact Maker mobile application may, with permission,
receive push notifications. Similarly, registered Impact Maker Users who access
the Service by using certain desktop browsers may, with permission, receive
push notifications. Notification preferences can be modified in the settings
menu for the mobile application or the applicable browser.
All Users may request access to or correction of
any Personal Information we have about them or delete their account and/or
request deletion of all Personal Information we have about them. In certain
jurisdictions, Users may have certain rights with regard to their Personal
Information. We will honor User requests to the extent we can reasonably do so
and as required by law. Upon request Impact Maker will provide you with
information about whether we hold any of your personal information. You may
access, correct, or request deletion of your personal information by making
updates to that information or by contacting Impact Maker through your online
account. If you request to access all personal information you’ve submitted, we
will respond to your request to access within 30 days or as otherwise required
by applicable law. If you completely delete all such information, then your
account may become deactivated. If your account is deactivated or you ask to
close your account, you will no longer be able to use the Service. Depending on
where you are located, you may have certain rights with regard to your Personal
Information (including, in certain cases, under the Privacy Shield, described
below). If you are located in the European Economic Area ("EEA”), in addition
to the rights described above, you may contact us at the contact information
provided below to (1) request a restriction on the processing of your Personal
Information, (2) object to the processing of your Personal Information, or (3)
exercise other rights with respect to your Personal Information. Impact Maker
uses automated means to calculate the Job Success Score of Freelancers. If you
believe that our services have miscalculated your Job Success Score or you
would like to exercise any other rights with regard to your Personal
Information, please email us at legal@usebraintrust.com for assistance. We may
be able to assist you by conducting a manual review of your Job Success Score,
such as by assessing whether the information you’ve provided us is accurate.
While we strongly encourage you to first raise any questions or concerns about
your Personal Information directly with us, you have a right to lodge a
complaint with the relevant supervisory authority.
We will use commercially reasonable efforts to
honor your requests for deletion; however, certain information will actively
persist on the Service even if you close your account, including information in
your Work Diaries and messages you posted to the Service. In addition, your
Personal Information may remain in our archives and information you update or
delete, or information within a closed account, may persist internally for our
administrative purposes, to the extent permitted by law. It is not always
possible to completely remove or delete information from our databases. In
addition, we typically will not remove information you posted publicly through
or on the Service. Bear in mind that neither you nor Impact Maker can delete
all copies of information that has been previously shared with others on the
Service.
7. SECURITY
We take a number of steps to protect your data, but
no security is guaranteed.
Impact Maker takes commercially reasonable steps to help protect and secure the information it collects and stores about Impact Maker Users. All access to the Site is encrypted using industry-standard transport layer security technology ("TLS”). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology ("SSL”). We also use HTTP strict transport security to add an additional layer of protection for our Impact Maker Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, Impact Maker cannot ensure and does not warrant the security of any information you transmit to us.
8.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Because we are a German company, we process and
store your information in Germany and our service providers may process and store it
elsewhere.
Impact Maker is a German company. If you are located outside the Germany and choose to provide information to us, Impact Maker transfers Personal Information to the Germany for processing, and our service providers may process Personal Information in Germany and elsewhere. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to Germany, we will protect it as described in this Privacy Policy.
When we transfer Personal Information from
territories in the U.S. or with similar laws to our affiliates or service
providers in Germany and elsewhere outside the U.S., we rely on approved data
transfer mechanisms, including standard contractual clauses approved by the
European Commission and the Privacy Shield, as described below. You may request
a copy of the standard contractual clauses relevant to your Personal
Information, if any, using the contact information below.
9. LINKS TO
OTHER SITES
Our Service contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
10. PUBLIC
PROFILE
The profile you create on our Site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal.
12.
COMPLIANCE WITH THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT AND GDPR
REGULATIONS RELATING TO CHILDREN
Only persons age 18 or older are authorized to create an account. We do not knowingly collect Personal Information from anyone under the age of 18. If a parent or guardian becomes aware that his or her child (a) under the age of 16 in applicable EU Member Countries, or (b) under the age of 13 in the U.S. and applicable EU Member Countries, has provided us with Personal Data without their consent, he or she should contact info@impactmaker.co. We will delete such Personal Information from our files within a commercially reasonable time, but no later than required under the applicable law relating the child’s country of residence.
13. CHANGES
TO THIS POLICY
We may change this Privacy Policy. If we make
material changes, we will provide notice.
Impact Maker may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will display a notice through the Services prior to the change becoming effective. We may also notify you by email, in our discretion. However, we will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. Express consent to collection and use practices will be obtained when required by applicable law.
14.
CONTACTING US
If you have any questions about this Privacy
Policy, please contact us at info@impactmaker.co or by mail addressed to Impact Maker, Lutherstrasse
33, 69120 Heidelberg.
GDPR NOTICE
Effective January 01, 2023
The General Data Protection Regulation (GDPR) is a
change that gives EU residents more clarity and control over how their Personal
Information is used. Personal Information is anything that can directly or
indirectly identify a person, such as a photo, name, bank details, medical
information, computer IP address, and so on. This European-wide law replaces
the 1995 Data Protection Directive 95/46/EC.
Data Controller: The information that we collect, process and/or
use to provide the Services is controlled by Impact Maker, Lutherstrasse
33, 69120 Heidelberg. Users may
contact us at any time by emailing us atinfo@impactmaker.co.
Data Processor:Impact Maker is the processor of all
Freelancer data input by Client and its authorized users, in connection with
Client’s use of the Impact Maker Services.
We will only collect and process Personal
Information where we have lawful bases. Lawful bases include consent (where you
have given consent), contract (where processing is necessary for the
performance of a contract with you to provide the Services), and "legitimate
interests.” Where we rely on your consent to process Personal Information, you
have the right to withdraw or decline your consent at any time and where we
rely on legitimate interests, you have the right to object. If you have any
questions about the lawful bases upon which we collect and use your Personal
Information, please contact us atinfo@impactmaker.co.
Where we rely on your consent to collect Personal
Information you may withdraw your consent either through the opt-out links
provided in this Privacy Policy or through the contact information contained
within this Section.
For all GDPR-based requests made pursuant to this section, Impact Maker will (a) respond as required under applicable law, (b) provide a copy of any requested Personal Information in a structured, commonly used and machine-readable format, and (c) transmit such Personal Information to another service provider without restriction in accordance with applicable law.