Privacy Policy
Introduction
IMP is a FinTech & RegTech consulting firm serving buy-side investment managers worldwide. Our mission is to improve technical infrastructure, transparency, and margins for buy-side firms. We work with asset managers on their Order Management (OMS), Compliance, Risk, Middle Office & Back Office Systems.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes IMP’s policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
Security Team and Data Protection
IMP is headquartered in Boston, MA in the United States. IMP has appointed an internal security team for you to contact if you have any questions or concerns about IMP’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to info@impconsults.com.
How we collect and use (process) your personal information
IMP only collects personal information about its website visitors and customers when a form is filled out requesting additional information about our services. With a few exceptions, this information is generally limited to:
name
job title
employer name
work address
work email
work phone number
We use this information to provide prospects and customers with services. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services. From time to time, IMP receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third-party website (e.g. LinkedIn).
Use of the IMP Website
As is true of most other websites, IMP’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of IMP’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
IMP has a legitimate interest in understanding how members, customers and potential customers use its website. This assists IMP with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet member and customer needs.
Cookies and tracking technologies
IMP makes available a cookie notice when landing on the website that describes the cookies and tracking technologies used on IMP’s website and provides information on how users can accept or reject them:
This website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. To find out more about the cookies we use, see our Privacy Policy.
If you decline, your information won’t be tracked when you visit this website. A single cookie will be used in your browser to remember your preference not to be tracked.
Sharing information with third parties
The personal information IMP collects from you is stored in one or more databases hosted by third party companies. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, IMP engages third parties to send information to you, including information about our products, services, and events. A list of our third party sub-processors include Microsoft, Squarespace, HubSpot, and MailChimp.
We do not otherwise reveal your personal data to non-IMP persons or businesses for their independent use unless: (1) you request or authorize it; (2) it’s in connection with IMP hosted and IMP co-sponsored conferences as described above; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God; or (6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.
The IMP website may connect with third party services such as LinkedIn, X and others. If you choose to share information from the IMP website through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.
Transferring personal data to the U.S.
IMP has its headquarters in the United States. Information we collect about you will be processed in the United States. By using IMP’s services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Pursuant to Article 46 of the GDPR, IMP is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.
Depending on the circumstance, IMP also collects and transfers to the U.S. personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of IMP in a manner that does not outweigh your rights and freedoms. IMP endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with IMP and the practices described here. IMP also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, IMP has received zero government requests for information.
For more information or if you have any questions, please contact us at info@impconsults.com.
Data Subject rights
The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:
Right to be informed
Right of access
Right to rectification
Right to erasure
Right to restrict processing
Right of data portability
Right to object
Rights related to automated decision making including profiling
This Privacy Policy is intended to provide you with information about what personal data IMP collects about you and how it is used. If you wish to confirm that IMP is processing your personal data, or to have access to the personal data IMP may have about you, please contact us.
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside might have received the data from; what the source of the information was (if you didn’t provide it directly to ); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by if it is inaccurate. You may request that erase that data or cease processing it, subject to certain exceptions. You may also request that cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how processes your personal data. When technically feasible, will—at your request—provide your personal data to you.
Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, will provide you with a date when the information will be provided. If for some reason access is denied, will provide an explanation as to why access has been denied.
For questions or complaints concerning the processing of your personal data, you can email us at info@impconsults.com. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.
Data storage and retention
Your personal data is stored by IMP on its servers and on the servers of the cloud-based database management services that IMP engages. IMP retains service data for the duration of the customer’s business relationship indefinitely to analyze the data for IMP’s own operations, and for historical and archiving purposes associated with IMP’s services. IMP retains prospect data until such time as it no longer has business value and is purged from the systems. All personal data that IMP controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: info@impconsults.com.
Children’s data
We do not knowingly attempt to solicit or receive information from children.
Questions, concerns or complaints
If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
IMP
33 Broad Street, Suite 703
Boston, Massachusetts 02109
t: (617) 314-7415
