We at IMGN Software Ltd. (“IMGN“, “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our customers and their end-users. This Privacy Notice describes the types of information we collect from you when you visit and use our film production management solution (“Solution“) and the services provided therein (“Services“) through our website and/or mobile application. This Privacy Notice also explains how we process, transfer, store, and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://imgn.ai/privacy (“Terms“). “You” means any user of the Services.
If you are an individual located in the European Union (“EU Individual“), some additional terms and rights may apply to you, as detailed herein. IMGN is the data controller in respect of the processing of your Personal Data (defined below) outlined in this Privacy Notice. Our registered office is located at 15 Rom Yael St., Petach Tikva, Israel, and our company number is 516370897. In respect of certain processing activities, the applicable Company may serve as a controller and IMGN serves as a processor in such cases. Please see Section 1 below for more information.
When we refer to “Personal Data,” we mean any information that refers to, is related to or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with the provision of the Services.
Privacy Notice Key Points
- Personal Data We Collect as a Processor.
- Personal Data We Collect as a Controller.
- Additional Uses.
- Sharing the Personal Data We Collect.
- International Transfer.
- Security.
- Your Rights – How to Access and Limit Our Use of Certain Personal Data.
- Data Retention.
- Cookies and Similar Technologies.
- Communications.
- Children.
- Changes to the Privacy Notice.
- Comments and Questions.
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- Personal Data We Collect as a Processor. According to the General Data Protection Regulation (“GDPR”), a processor is an entity that processes Personal Data solely on behalf of another entity called a ‘controller’. A controller is an entity that determines the means and purposes for which Personal Data is collected and processed. We collect and process certain types of Personal Data as a processor on behalf of the Company that has registered an account with us. If the Company provides us with content (for example, a screenplay) that contains Personal Data, we process that Personal Data as a processor in accordance with the Company’s instructions. To learn more about the Personal Data we process in this capacity, please contact the applicable Company.
- Personal Data We Collect as a Controller. We collect different types of data from and about you and your use of the Solution as a controller and process (or allow our third-party service providers to process) this data for different purposes, as specified below. You have no legal obligation to provide us with Personal Data, but if you refuse to provide certain Personal Data we may not be able to register you to the Solution and/or provide you with the Services or part thereof.
2.1. Registration Data – In order to use our Solution and/or receive related Services, you will be required to have a registered account. The Company will provide us with your email address, and we will send you initial login credentials. Upon your first login, you will be asked to change your password.
How we use this data: We use your email address (1) to provide you with the Services, to respond to your inquiries and requests, and to contact you regarding your use of the Solution; and (2) to prevent fraud, protect the security of and address any problems with the Solution.
Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered the performance of a contract with you, including responding to your inquiries and requests and providing customer support. (2) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Solution and Services, such processing is based on our legitimate interests to protect the integrity of the Services.
2.2. Contact Information – When you request information from us or contact us for any other reason, we will collect any data you provide, such as your email address and the content of your inquiry.
How we use this data: To respond to your request or inquiry.
Legal Basis. We process this Personal Data based on the performance of a contract with you when we respond to your inquiry.
2.3. Automatically Collected Data – When you visit the Solution, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address, device ID, as well as your browsing history and any information regarding your viewing and use of our Solution. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.
How do we use this data. (1) to review usage and operations, including in an aggregated, non-specific, analytical manner; and (2) to prevent fraud, protect the security of our Solution, and address any problems with the Solution or Services.
Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our products and services, review usage, perform analytics, prevent fraud, for our recordkeeping, and protection of our legal rights.
2.4. Materials You Upload – Any materials you may upload to the Solution, including images, videos, and documents, such as screenplays, will be collected by us.
How we use this data. To provide you and/or the applicable Company with the Services.
Legal Basis. We process this Personal Data for the purpose of performance of a contract with you and/or the Company, as applicable.
2.5. Geo-location – Subject to your consent, when you use the Solution or Services, we collect your (geo)location.
How we use this data: We use this information in order to provide you with location-based Services.
Legal Basis: We process this Personal Data based on your consent. You may withdraw your consent at any point by changing your device settings.
- Additional Uses.
3.1. Statistical Information and Analytics. We and/or our service providers use analytics tools, including “Google Analytics” to collect and analyze information about the use of the Solution, such as how often users visit the Solution, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Solution. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Services, understand trends and customer needs, consider new products and services, and tailor existing products and services to customer desires. The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.
- Sharing the Personal Data We Collect. We share your information, including Personal Data, as follows:
4.1. Companies. We share information, including your Personal Data, with the Company with whom your account is associated, where this is necessary to provide you and the applicable Company with our products and Services.
4.2. Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions. All service providers/subcontractors are signed on confidentiality undertakings and who use such information solely on our behalf in order to: (1) help us provide you with the Services; (2) aid in their understanding of how users are using our Services.
4.3. Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
4.4. Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property, or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
4.5. Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
- International Transfer.
5.1. We use subcontractors and service providers who are located in countries other than your own and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such a third country.
5.2. Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“) and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
5.2.1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. In particular, we transfer data to Israel, which is subject to an ‘adequacy decision’ by the European Commission.
5.2.2. Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
5.3. Please contact us at support@imgn.co if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
- Security. We have implemented and maintained appropriate technical and organizational security measures, policies, and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take includes:
6.1. Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.
6.2. Access Control – We dedicate efforts to proper management of system entries and limit access only to authorized personnel on a need-to-know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
6.3. Internal Policies – We maintain and regularly review and update our privacy-related and information security policies.
6.4. Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
6.5. Encryption – We encrypt specific data in transit.
6.6. Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.
6.7. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
6.8. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
- Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below. To exercise your rights regarding Personal Data we process as a processor, please contact the applicable Company, which serves as the data controller.
7.1. Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal data communicated to you. Subject to applicable law, we may charge you a fee. Please note that we may not be able to provide you with all the information you request, and, in such a case, we will endeavor to explain to you why.
7.2. Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly used, and machine-readable format.
7.3. Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct, or delete inaccurate, incomplete, or outdated Personal Data.
7.4. Deletion of Personal Data (“Right to Be Forgotten”). If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also delete our mobile app from your mobile devices, terminate your account with us, and clear our cookies from any device where you have used our mobile app. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
7.5. Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
7.6. Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data that has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
7.7. Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.
7.8. Right to Lodge a Complaint with Your Local Supervisory Authority. If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
- Data Retention.
8.1. Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. Where we process Personal Data as a processor, we retain Personal Data as instructed by the Company serving as the controller. Where we process Personal Data as a controller, we may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy.
8.2. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, and accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. When we serve as a controller, in order to determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, and the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
8.3. Please contact us at support@imgn.co if you would like details regarding the retention periods for different types of your Personal Data.
- Cookies and Similar Technologies. We use cookies and similar technologies for a number of reasons, including to help personalize your experience. When visiting the Solution, you shall be notified of the use of and placement of cookies and other similar technologies on your device as specified herein.
9.1. What are Cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
9.1.1. A “session cookie” is temporary and will remain on your device until you leave the Solution.
9.1.2. A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
9.1.3. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
9.1.4. We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.
9.2. How We Use Cookies. We use cookies and similar technologies for a number of reasons, as specified below. We will not place any cookies on your browser that are not strictly necessary unless you have first consented to the cookie pop-up.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
Type of Cookie | Why We Use These Cookies |
Necessary | These cookies are necessary in order to allow the Solution to work correctly. They enable you to access the Solution, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled. |
Functionality | These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content. |
Security | These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information. |
Performance | These cookies can help us collect information to help us understand how you use our Solution, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Solution. |
Analytics | These cookies collect information regarding your activity on our Solution to help us learn more about which features are popular with our users and how our Solution can be improved. |
9.3. How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.
- Communications. We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt-out of receiving them. Should you not wish to receive such communications, you may cancel your account.
- Children. We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
- Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Solution or via email.
- Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at support@imgn.co.
Last updated: June 2022