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PRIVACY POLICY

Your privacy is important to you and to us, and we are committed to protecting
your privacy.  This Privacy Policy discloses the information practices of
InMoment, Inc. and its wholly owned affiliates, MaritzCX Holdings LLC, MaritzCX
Limited, InMoment GmbH, MaritzCX Australia PTY LTD, Empathica Inc., Empathica UK
LTD and InMoment PTY LTD (collectively “InMoment”, “we”, or “us”) relating to
our web sites (collectively the “Sites”).


TABLE OF CONTENTS

COMPLIANCE WITH EUROPEAN UNION REGULATIONS (GDPR) 

COOKIES AND IP ADDRESSES

PRIVACY IN SPECIFIC CIRCUMSTANCES

HOW TO CONTACT US


COMPLIANCE WITH EUROPEAN UNION REGULATIONS (IN PARTICULAR THE GDPR)


WE ADHERE TO EUROPEAN DATA PROTECTION REQUIREMENTS 

InMoment complies with European data protection requirements and we value these
regulations as an important date privacy rights framework.  While the below
terms are required to be offered to data subjects under EU laws and regulations,
we offer these terms to data subjects globally. The controller within the
meaning of data protection laws, in particular the EU General Data Protection
Regulation (GDPR) is InMoment, Inc.:

InMoment, Inc., 10355 South Jordan Gateway, Suite 600, South Jordan, UT 84095
USA.

Email: privacy@inmoment.com


YOUR RIGHTS UNDER THE GDPR

You can exercise the following rights at any time using the contact details
provided below:

• The right of access (Article 15 GDPR) – You have the right to be informed
about your personal data processed by us.

• The right to rectification Article 16 GDPR) – You are entitled to have your
personal data rectified if it is inaccurate or incomplete.

• The right to erasure – Also known as ‘the right to be forgotten’ (Article 17
GDPR) –  you have the right to have your personal data erased. This is, however,
only possible if the data concerning you are no longer necessary, if they have
been unlawfully processed, or a corresponding consent has been withdrawn.

• The right to restrict processing (Article 18 GDPR) – You have the right to
obtain restriction of processing of your personal data.

• The right to data portability (Article 20 GDPR) – you have the right to retain
your personal data in a commonly used, machine-readability format in order to
have them, if required, transferred to another controller.

• The right to object (Article 21 GDPR)  – You are entitled to object to the
processing of your personal data.

• Right to lodge a complaint with a supervisory authority (Article 77 GDPR) –
you can contact a supervisory authority with a complaint at any time. A list of
the national Data Protection Authorities of the EU Member States can be
retrieved here: https://edpb.europa.eu/about-edpb/board/members_en.


COLLECTION OF GENERAL INFORMATION WHEN VISITING OUR WEBSITE

Nature and purpose of the processing:

When you access our website, i.e., when you do not register or otherwise submit
information, information of a general nature is automatically collected. This
information (server log files) includes, for example, the type of web browser,
the operating system used, the domain name of your Internet service provider,
your IP address and the like.

In particular, they are processed for the following purposes:

 * Ensuring a smooth connection setup of the website;
 * Ensuring a smooth use of our website;
 * Evaluation of system security and stability; and
 * Optimizing our website

We do not use your data to draw conclusions about your person. Information of
this kind is statistically evaluated anonymously by us, if necessary, in order
to optimize our Internet presence, confirm the status of our IT security, and
the technology behind it.

Legal basis and legitimate interest:

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on
the basis of our legitimate interest in improving the stability and
functionality of our website.

Recipients:

Recipients of the data may be technical service providers who act as order
processors for the operation and maintenance of our website.

Transfer to a third country:

The collected data may be transferred to the following third countries: United
States of America.

The following data protection guarantees are in place: Please find further
information in section EU-U.S. Privacy Shield  and Swiss-U.S. Privacy Shield
Frameworks

Storage Duration:

The data is deleted as soon as it is no longer required for the purpose for
which it was collected. This is generally the case for data used to provide the
website when the respective session has ended.

In the case of storage of data in log files, deletion takes place after 14 days
at the latest. Storage beyond this period is possible. In this case, the IP
addresses of the users are anonymized, so that an assignment of the calling
client is no longer possible.

Provision prescribed or required:

The provision of the aforementioned personal data is neither legally nor
contractually required. However, without the IP address, the service and
functionality of our website is not guaranteed. In addition, individual services
and services may not be available or may be limited.

Right to object

You have the right to object to the processing of your data. Information on how
to object is provided here. 


NEWSLETTER

Nature and purpose of the processing:

For the delivery of our newsletter, we collect personal data that is transmitted
to us via a relevant web form on the Sites.

For an effective registration we need a valid e-mail address. In order to verify
that a registration is actually made by the owner of an email address, we use
the “double opt-in” procedure. For this purpose, we log the registration for the
newsletter, the sending of a confirmation email and the receipt of the response
requested herewith. We track whether a newsletter has been opened by the
recipient and when the recipient has clicked on a link within the newsletter.
Further data is not collected.

Legal basis:

Based on your explicit consent (Art. 6 para. 1 lit. a GDPR), we will regularly
send you our newsletter or similar information by e-mail to your specified email
address.

Withdrawal of consent:

You can revoke your consent to the storage of your personal data and its use for
the newsletter dispatch at any time with effect for the future. You will find a
corresponding link in each newsletter. In addition, you can also unsubscribe
directly on this website
(https://mkt.inmoment.com/hs/manage-preferences/unsubscribe-simple) at any time
or inform us of your revocation using the contact option provided at the end of
this privacy policy.

Recipients:

If applicable, recipients of the data are processors.

Transfer to a third country:

The collected data may be transferred to the following third countries: United
States of America.

The following data protection guarantees are in place: Please find further
information in section EU-U.S. Privacy Shield  and Swiss-U.S. Privacy Shield
Frameworks.

Storage Duration:

Your data will only be processed as long as the corresponding consent is given.
Afterwards they will be deleted.

Provision prescribed or required:

The provision of your personal data is voluntary, based solely on your consent.
Without existing consent, we can unfortunately not send you our newsletter.


CONTACT FORM

Nature and purpose of the processing:

The data you enter will be stored for the purpose of individual communication
with you. For this purpose, it is necessary to provide a valid e-mail address,
phone number and your name. This serves the assignment of the request and the
subsequent response to the same. The specification of further personal data is
optional.

Legal basis:

The processing of the data entered in the contact form is based on a legitimate
interest (Art. 6 para. 1 lit. f GDPR).

By providing the contact form, we would like to enable you to contact us easily.
The information you provide will be stored for the purpose of processing the
request and for possible follow-up questions.

If you contact us to request a quote, the data entered in the contact form will
be processed to carry out pre-contractual measures (Art. 6 para. 1 lit. b GDPR).

Recipients:

If applicable, recipients of the data are processors.

Transfer to a third country:

The collected data may be transferred to the following third countries: United
States of America.

The following data protection guarantees are in place: Please find further
information in section EU-U.S. Privacy Shield  and Swiss-U.S. Privacy Shield
Frameworks.

Storage Duration:

Your data will be deleted no later than 6 months after processing the request
unless there are other legal retention periods.

Provision prescribed or required:

The provision of your personal data is voluntary. However, we can only process
your request if you provide us with your name, phone number and e-mail address.

Right to object:

You have the right to object to the processing of your data. Information on how
to object is provided here. 


INFORMATION ABOUT YOUR RIGHT TO OBJECT ACCORDING TO ART. 21 GDPR

Right to object on a case-by-case basis:

You have the right to object at any time, on grounds relating to your particular
situation, to the processing of your personal data which is carried out on the
basis of Art. 6 para. 1 lit. f GDPR (data processing on the basis of a balance
of interests); this also applies to profiling based on this provision within the
meaning of Art. 4 para. 4 GDPR.

If you object, we will no longer process your personal data unless we can
demonstrate compelling legitimate grounds for the processing which override your
interests, rights and freedoms, or the processing serves the purpose of
asserting, exercising or defending legal claims.

Recipient of an objection:

• By Email: privacy@inmoment.com

• By postal mail:  InMoment, Attn: Privacy Team/Legal, 10355 South Jordan
Gateway, Suite 600, South Jordan, UT 84095 USA.  


ACCESS TO YOUR INFORMATION: CORRECTION, DELETION, PORTABILITY AND OTHER ACTIONS.

We want to make sure that your questions are answered and that your personal
information is accurate and up to date. You may ask questions, request a copy of
the information that we hold about you, request correction or deletion of the
same or pursue any of the other above listed rights by submitting a request at
https://inmoment.com/pii-request/.


EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS 

InMoment is aware that the European Court of Justice declared the EU-U.S.
Privacy Shield as invalid in its ruling from 16 July 2020. Consequently, the
EU-U.S. Privacy Shield Framework is no longer a valid mechanism for the transfer
of personal data from European Economic Area (EEA) to the Unites States of
America. InMoment is also aware that the Swiss Federal Data Protection and
Information Commissioner on 08 September 2020 declared that the Swiss-U-S-
Privacy Shield does not provide an adequate level of protection for the transfer
of personal data from Switzerland to the US. 

However, in accordance with the relevant advice and request by the US Federal
Trade Commission (FTC), InMoment continues to      comply with the EU-U.S.
Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of
personal information transferred from the      EEA and Switzerland to the United
States.  InMoment has certified to the Department of Commerce that it adheres to
the Privacy Shield Principles.  To learn more about the Privacy Shield program,
and to view our certification, please visit https://www.privacyshield.gov/.

InMoment would oppose and aggressively defend against government law enforcement
requests to disclose any personal data collected on this website. To the extent
possible, InMoment will without undue delay inform the affected data subject
about such government law enforcement requests and support the data subject in
defending its rights under the GDPR.  InMoment concludes Standard Data
Protection Clauses (also known as Standard Contractual Clauses) with all data
processors outside the EU/EEA. To ensure that the level of data protection is
maintained, InMoment maintains safeguards in its systems and processes to ensure
an adequate level of data protection.

Your rights under the Privacy Shield Framework:

• InMoment is subject to the investigatory and enforcement powers of the Federal
Trade Commission (FTC) in regards to your data privacy.

• InMoment may have liability in cases of onward transfers of you data to third
parties.

• Under certain conditions there is the possibility for you to invoke binding
arbitration (see Privacy Policy FAQs).

For additional details about the Privacy Shield program, our certification
therein and the suitable safeguards we use to protect your data visit:
https://inmoment.com/wp-content/uploads/2021/07/Privacy-Shield-Statement-180925.pdf.


3RD PARTY DISPUTE RESOLUTION

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.


AUSTRALIAN PRIVACY ACT

InMoment complies with the Australian Privacy Act 1988 (Privacy Act) and the
Office of the Australian Information Commissioner’s (OAIC) APP guidelines. For
information about the APP and the text of the act, you may visit this link.
https://www.oaic.gov.au/privacy-law/privacy-act/.

If you have any complaints, send them to us at the contact information contained
in “How to Contact Us” section below.


COOKIES AND IP ADDRESSES

Cookies are text files placed on your computer to collect standard internet log
information and visitor behavior information. This information is used to track
visitor use of the website and to compile statistical reports on website
activity.

For further generalized information about cookies visit www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you
how to remove cookies from your browser. However, in a few cases some of our
website features may not function as a result.

We use your IP address obtained through cookies to help diagnose problems with
our servers and to administer the Sites. Your IP address is also used to gather
broad demographic information. Our Sites may use cookies to make sure you don’t
access the same survey repeatedly and to determine the browser the visitor uses
so the Sites can be designed to work properly with the most common versions of
different browsers. If used, these cookies are not linked to any Personal
Information. If you reject cookies, you may still use the Sites; however, you
may not be able to access all areas or features.


PRIVACY IN SPECIFIC CIRCUMSTANCES

• Children’s Information

InMoment does not knowingly collect or solicit Personal information from anyone
under the age of 16 or knowingly allow such persons to participate in any
survey, contest or other offering from us. If you are under 16, please do not
send us your Personal Information. In the event that we learn that we have
collected personal information from a child under 16 without verification of
parental consent, we will delete that information as quickly as possible.
However, we have no obligation to search for, confirm, or identify such
information. If you believe that we might have any information from or about a
child under the age of 16 please contact us by email at privacy@inmoment.com and
provide particulars of the situation.

• Using and Sharing Personal Information

The following paragraphs describe in more detail how InMoment may use your
personal information in specific circumstances. Depending on the specific
interaction you have with InMoment, one or more of the following may apply.

• Assistance to Complete a Survey

In certain circumstances you may require assistance from InMoment to complete a
survey. If the survey is being administered by telephone, you may be required to
leave a voice message. If the survey is being administered online or by other
text media, you may be asked to post a message to InMoment using an e-form or
e-mail. Personal Information may be required. In this case, the Personal
Information will only be used to contact you for the intent of resolving their
difficulty in accessing and completing a Survey.

• Promotional and Incentive Contests

InMoment or its clients may offer various promotions, incentives, or sweepstakes
from time to time. When entering a promotional contest, we, our client, or our
client’s fulfillment vendor may ask for your name, date of birth, address
(e-mail and/or residential), financial information (such as income level), or
phone number so that we may communicate with you in the event you are a winner.

• Telephone ANI Visibility

When you dial a toll-free number in the United States, the party you are calling
pays for the call. The called party is able to identify your telephone number
using a telephone network technology called Automatic Number Identification
(ANI). FCC rules limit parties that own toll-free numbers from distributing the
telephone numbers identified through ANI and require telephone companies to
inform customers that their telephone numbers are being transmitted to toll-free
numbers in this way. If you take a InMoment telephone survey, both InMoment and
its clients may have access to your ANI, but, per FCC rules, will not distribute
that telephone number further.

• Opt-In

For certain surveys and other opt-in services, InMoment may collect profile
(e.g. personal interests) and demographic information (e.g. household income,
etc). This information will be used to communicate specific information to you
based on the profile and demographic information you provide. Some surveys and
opt-in services offer visitors the option of participating in additional surveys
or receiving information from InMoment or from a InMoment client or business
partner. Visitors must opt-in if they wish to participate or receive such
information, and if they do, their Personal Information may be used by InMoment
and/or shared with a client of InMoment or business partner for that purpose.

• Fulfilling Your Transaction Request

If you request something from a InMoment web site, for example, a product or
service, a whitepaper, a callback, or specific marketing materials, we will use
the information you provide to fulfill your request. To help us do this, we may
share information, with others, for instance, other parts of InMoment and
business partners involved in the fulfillment. If you request information about
our products or services, we may follow up with you in the future with
additional information that we think may be of interest to you. You will always
have an opportunity to opt out of receiving such communications. In connection
with a transaction, we may also contact you for market research purposes.

• When You Contact Us

Our Sites’ contact forms may request your name and contact information,
potentially including telephone numbers. An email address is required to post a
message to InMoment using an e-form.

• Public Forums

The Sites may make chat rooms, forums, message boards and/or news groups
available to its visitors. Please remember that any information that is
disclosed in these areas becomes public information and you should exercise
caution when deciding to disclose your personal information.

• Subscription Registration

If you register for a subscription (e.g. to a newsletter or other communication)
we will use the registration information that you submit to process your
request. We will keep this information in a database. In addition, we may
contact you about future publications and InMoment services that may be of
interest to you. You will always have an opportunity to opt out of receiving
such communications.

• Disclosure of Aggregate Information

InMoment reserves the right to use non-personal customer and/or employee data in
aggregate for the purposes of generating “norms” and industry benchmarks, etc.

• Job Applications

If you submit a job application to InMoment, we may use the Personal Information
that you supply, such as your email address and phone number, to contact you
about possible job openings. We may also contact previous employers and
references, unless you instruct us not to.

• Disclosures Required by Law

Be aware that in certain circumstances, it is possible that Personal Information
may be subject to disclosure pursuant to judicial or other government subpoenas,
warrants, or orders. This includes the investigation of network abuse or a
violation of our terms of use or other published guidelines, or as a part of any
actual or threatened legal proceedings or alternative dispute resolution
proceedings either initiated by or against us.

• New Use of Personal Information

Should InMoment wish to use your Personal Information for a purpose not
contemplated at the time of initial collection, such as additional services,
products, or promotional offers that may be of interest to you, we will use your
contact information, including your email address, to ask for your consent to
use your Personal Information for the new purpose.

• Links to Third-Party Sites

The Sites contain links to third-party sites. Neither InMoment nor any of its
affiliates are responsible for the privacy practices or the content of such
third-party Web sites. InMoment co-branded sites and content partner sites have
privacy policies independent of InMoment. We do not control the privacy
practices of those sites and therefore strongly encourage users to familiarize
themselves with the privacy practices and customs of any web site controlled by
a third party before disclosing any Personal Information on that site. InMoment
may share aggregate information with co-branded and other related sites, however
this aggregated information does not contain personally identifiable
information. This Privacy Policy extends only to data collected on pages hosted
on the InMoment servers.

• Security, Storage, and Retention of Information

The Sites (including, but not limited to: websites, surveys, reporting
applications, and data transfer applications), have commercially reasonable
security measures consistent with industry standards in place to protect against
the loss, misuse and interception of information by third parties. InMoment
holds its physical hosting facilities to these same standards. Nevertheless,
InMoment assumes no liability for interception, alteration or misuse of
information transmitted over the Internet. InMoment imposes strict internal
controls over employees with access to Customer Information. Such access is
granted only on a need-to-know basis. InMoment will retain Personal Information
only for as long as necessary to fulfill the purpose(s) for which it was
collected and to comply with applicable laws, and your consent to such
purposes(s) will remain valid after termination of our interaction with you.

• Our Worldwide Practices

InMoment conducts business globally, with people, processes, and systems that
cross borders. Our privacy practices are designed to provide protection for your
Personal Information, all over the world.

• Changes to this Privacy Policy

This Privacy Policy may be amended at any time, without prior notification.


HOW TO CONTACT US

Please contact us if you have any complaints, questions about the Privacy
Policy, or for access to the information we hold about you:

• By Email: privacy@inmoment.com

• Or write us at:  InMoment, Inc., Attn: Privacy Team/Legal, 10355 South Jordan
Gateway, Suite 600, South Jordan, UT 84095 USA.

Version: This Privacy Policy has been updated on 7 July 2021



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PRIVACY PREFERENCE CENTER




 * YOUR PRIVACY


 * STRICTLY NECESSARY COOKIES


 * PERFORMANCE COOKIES


 * FUNCTIONAL COOKIES


 * TARGETING COOKIES

YOUR PRIVACY

When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
and the services we are able to offer.
More information

STRICTLY NECESSARY COOKIES

Always Active

These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms.    You can set your browser to
block or alert you about these cookies, but some parts of the site will not then
work. These cookies do not store any personally identifiable information.

PERFORMANCE COOKIES

Performance Cookies


These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site.    All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

FUNCTIONAL COOKIES

Functional Cookies


These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages.    If you do not allow these cookies then
some or all of these services may not function properly.

TARGETING COOKIES

Targeting Cookies


These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites.    They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.

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