Updated and effective as of February 7, 2024.
Privacy Policy
Introduction
Welcome to Impact Crew (the “Network”), an online platform that facilitates hiring, information sharing, messaging and professional networking for entertainment industry professionals, that is operated by Impact Creative Systems and/or its affiliates, related entities, divisions, subsidiaries, or parent companies (“Impact,” “we,” “our,” or “us”). In registering to participate in the Network, you are joining a diverse group of different users of the Services, each of whom may participate in the Network in a different way with a different goal. Those who have not registered may still access certain parts of our Services, such as to view public profiles or respond to messages through platform-email gateways. Registered and non-registered users are collectively referred to herein as “Users.”
This Privacy Policy applies to the Impact Crew website (the “Site”), the Impact Crew mobile application (the “App”), and other features, applications, or other services operated by Impact that post a link to this Privacy Policy, all of which are referred to in this Privacy Policy as the “Services.”
As a preliminary matter, it is important to note that if you voluntarily sign up for an account or otherwise use or interact with the Services, you agree to (a) our collection, use, and disclosure of your information as part of the Services, as set forth in this Privacy Policy and (b) our Terms of Service. If you do not agree to the terms of this Privacy Policy or the Terms of Service, do not access or use the Services. If you have questions about this Privacy Policy or the Terms of Service, please contact us at privacy@impact.net.
In this Privacy Policy, we tell you what information we collect, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that information, and how you may opt out of the sharing of that information.
International Data Transfers and Consent to Transfer and Storage in the United States
Information for European Union, European Economic Area, and United Kingdom Residents
Additional Information if You Are Located in Countries Outside the US, EU/EEA, UK, or Canada
1. What Information We Collect
As described more fully below, we collect information from you directly, automatically when you interact with the Services, and from third parties. Some of this information will be publicly available; other information will be seen by other members; other information may be for your own use as described in our Terms of Service. We may combine the information we collect in connection with the Services with information we collect through other services we provide.
Some of the information we collect may be considered “personal information” or “personal data” under various applicable laws. We consider information that identifies you as a specific, identified individual, such as your name, phone number, and email address, to be personal data. We will also treat other information, including IP addresses and cookie identifiers, as personal data where required by applicable law. We may de-identify your personal data so as to make it non-personally identifiable, either by combining it with information about other individuals and/or by hashing the information or otherwise removing characteristics that make the information personally identifiable to you. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.
(a) Information You Provide to Us
In connection with the Services, you may be required to provide and/or you may elect to provide us with certain information, including your first and last name; contact information, including your email address, and/or phone number; government-issued ID or union card (for verification purposes); geographic information such as your city, state, and/or country; current and past employment information, educational background, and/or projects you are or have been involved with; demographic information such as your gender, ethnicity, status, identity, affiliation, interests, or preferences; and information regarding who your agent or other representatives are; and your picture, resume, materials showcasing your work capabilities, scripts, audio-visual content, or other content files. We may combine information we collect in any offline setting with information we collect online.
(b) Information That We Gather from Others
One of the features of our Services are individual profiles (“Profiles”) which facilitate Users’ efforts to make connections within the industry, and to develop and maintain lists of people with whom they have or may like to work. These Profiles may be created by us or by Users, and may pertain to registered or non-registered Users, or non-Users. Some Profiles may available in whole or in part to all Users, while others may be available to only a subset of Users. Some portions of the Profiles may be made available publicly and be visible in Internet search engines. Profiles may be created or supplemented using information obtained from third parties, including other Users and publicly available information. We may combine the information we collect from you with the information obtained from third parties, and will apply this Privacy Policy to the combined information.
(c) Information That Is Automatically Collected
We and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone, or other device (a “Device”) whenever you visit or interact with our Services. Usage Information may include:
Your IP address or another unique identifier;
Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
Referring and exit web pages and URLs;
The areas within our Site or App that you visit and your activities there, including remembering you and your preferences;
Your Device’s geographic location (inferred from IP address), including the city, region or country from which you accessed the Services;
Your Device characteristics; and
Certain other Device data, including the time of day you visit our Site or use our App.
(d) Use of Cookies and Other Tracking Technologies
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Services, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
Cookies and Local Storage. “Cookies” and local storage are pieces of information (data files) transferred to an individual’s browser on their device when the device is used to access the Network. These technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is use to visit the site. These technologies may be used for many purposes by us and our third-party service providers such as automatically collecting Usage Information, enabling features, and remembering your preferences. If you do not want to accept cookies, you may be able to block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org.
Web Beacons. A web beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Site, to monitor how users navigate the Site, or to count how many particular links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider or business partner, is active only while you are connected to a Site, and is deactivated or deleted thereafter.
We may use Tracking Technologies for a variety of purposes, including:
To allow you to use and access the Services, including for the prevention of fraudulent activity and improved security functionality;
To assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services;
To offer you enhanced functionality when accessing the Services, including identifying you when you sign into our Services or keeping track of your specified preferences; and
To deliver content relevant to your interests on our Services based on how you interact with our content.
We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information about the use of other websites, apps, and online services. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
2. Why We Collect Information
We use information collected from or about you, including personal data and Usage Information, for various purposes, including:
Allowing you to participate in the Services, and any features or activities that we offer;
Providing the Services to others, including allowing other Users to connect with you;
Updating and verifying existing personal data we have in our records;
Identifying your Services elections and preferences, providing personalized content and informing you of new or additional information and content that may be of interest to you;
Verifying identity;
Responding to your requests for information;
Providing updates and information about the Services;
Improving the effectiveness of our Services, our marketing endeavors, and our product and service offerings;
Helping us address problems with and improve our Site, App, and Services, including testing and creating new products, features, and services;
Protecting the security and integrity of the Services, including understanding and resolving any technical and security issues reported on our Services;
Conducting analysis, research, and reports regarding the use of our Services;
For internal business purposes;
Complying with the law and protecting the safety, rights, property or security of Impact, the Services, and the general public; and
For other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
3. How We Share and Disclose Information
We may aggregate, de-identify, and/or anonymize any information collected through Services such that such information is no longer linked to your personal data. We may use and share this aggregated and anonymized information (non-personal data) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties.
We may share the information we have collected about you as disclosed at the time you provide us with information or your consent, and as described in this Privacy Policy, including:
To Other Users/As Part of the Services. We may disclose your information to other registered and non-registered Users in connection with our provision of the Services, which includes in some cases studios and similar businesses who use our Services and work with us to use the CrewChat and similar features of the Services to facilitate communications among the crew and other personnel related to certain productions, using admin-controlled threads. We may also disclose your information in other ways as disclosed at the time you provide your information and as described in this Privacy Policy.
Unaffiliated Third Parties for Direct Marketing Purposes. We do not share your personal data with unaffiliated third parties for their direct marketing purposes without your consent (which may consist of offering you the opportunity to either opt-in or opt-out of such sharing).
To Service Providers. We may use third party service providers to perform certain services on our behalf, or to assist us in providing the Services to you. Examples of such disclosures include using a payment processor, customer service provider, email marketing provider, data analysis provider, and other administrative services.
In Connection with Business Transitions. We may disclose your information in connection with a corporate transition such as a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, including during the course of any due diligence process. By providing your personal data, you agree that we may transfer such information to the acquiring entity without your further consent.
For Administrative and Legal Reasons. We reserve the right to use or disclose any information as needed to satisfy any law, regulation, or legal request; to protect the integrity of the Network or the Services; to fulfill your requests; to cooperate in a law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual property infringement; to protect and defend the legal rights and/or property of Impact and any of our corporate subsidiaries, affiliates, and shareholders, or the Network, it any of its Users, or any other party; or, in an emergency, to protect the health and safety of Users or the general public.
4. Updating Your Information
Registered Users: You may correct or update some of the personal data we have about you through your online account or by contacting the administrator of any admin-controlled thread you may be participating in. You are responsible for maintaining and updating, as applicable, your account and profile information with current, accurate, and complete information. Note that we may retain information that is deleted, updated, or otherwise changed for internal or administrative purposes.
Non-Registered Users: You may claim your profile by registering to participate in the Network. Once your account is established, you may correct or update some of the personal information we have about you through your online account. Note that we may retain information that is deleted, updated, or otherwise changed for internal or administrative purposes.
All registered Users have the right to request the removal of certain content they have publicly posted within the Network. You may be able to remove the content through your online account. Otherwise, you may request that Impact remove the content by contacting us using the information listed in the “Contact Us” section below. In some circumstances, we may maintain the content but remove any reference to you so that the posts are anonymized. When submitting a request, please be sure to include your full name, email address, and information sufficient to permit us to locate the content you are requesting us to remove. You may also request deletion of your account by emailing help@impact.net. We will make such requested changes in our active databases as soon as reasonably practicable. Note that any removal of public postings in accordance with these procedures does not ensure complete or comprehensive removal of the content or information you posted, which may persist in archival records or may have been copied by third parties while publicly accessible, and that deleting your account may not result in the removal of the public postings.
5. Your Choices About the Information We Collect
You may unsubscribe from any marketing email we may send you through the opt-out mechanism included in each such email. If you opt-in to receive updates from our system about other Users, these are not marketing emails, but you may still opt-out of receiving such updates in the future by changing your settings in your online account. We reserve the right to send you certain communications relating to your use of our Services, service announcements, notices of changes to this Privacy Policy, or other terms, or similar administrative or transactional messages, and such messages will be unaffected by any choice to opt out of marketing communications.
6. Children’s Privacy
Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from children under the age of 18.
7. Do Not Track Disclosures
Do Not Track (“DNT”) signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we may not alter our practices when our systems receive a “Do Not Track” signal from a visitor’s browser, unless specifically required by law. You can learn more about Do Not Track at www.allaboutdnt.com.
8. International Data Transfers and Consent to Transfer and Storage in the United States
Impact is a United States company. Please be aware that your connection will be through and to servers located in the U.S. and other countries. By using the Services or providing us with any information, you fully understand and unambiguously consent to this transfer to, and processing, usage, sharing and storage of your information in the United States and in other jurisdictions, for which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to the laws in those jurisdictions. Your information will also be disclosed to third parties as described in the “How We Share and Disclose Information” section above.
9. Links
For your convenience, the Site and this Privacy Policy may contain links to other websites. Impact is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Impact endorses or has any affiliation with the links. Please see our Terms of Service.
10. Security
We incorporate commercially reasonable safeguards to help protect and secure your personal data. However, no system can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Services, or guarantee that it will be free from unauthorized access by third parties. You provide us with information at your own initiative and risk.
11. Questions / Changes in Privacy Policy
If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@impact.net or at:
Impact Creative Systems, Inc.
150 El Camino Drive, Suite 100
Beverly Hills, CA 90212
To the extent permitted by applicable law, we reserve the right to change or amend our Privacy Policy in our discretion at any time. We will notify you of material changes by posting the changed or modified Privacy Policy on our Site and in our App. We may also provide notice to you in other ways, such as through the contact information you provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy, unless otherwise specified. Your continued use of the Network after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will, to the fullest extent permitted by applicable law, constitute your consent to those changes. However, we will provide notice and/or obtain your consent (opt-in or opt-out) if required by law. Note that you may need to consent to our new policies in order to continue participating in the Network.
12. Information for European Union, European Economic Area, and United Kingdom Residents
Legal Basis for Processing
We will collect, store, or otherwise process Personal Data (as that term is defined by the General Data Protection Regulation (GDPR) or UK GDPR, as applicable) collected from you in the EU/EEA or the UK only in the following situations:
When we have your consent to do so. For example, if you register for an account with us or provide us with information to share with other users of the Services. You can withdraw your consent at any time as described below.
When we need to use your Personal Data to perform our responsibilities under our contract with you, including to provide the Services you have requested.
When we or a third party have a legitimate interest in processing your Personal Data. For example, we may process your Personal Data to communicate with you about our Services, to provide, secure, and improve our Services, and, in certain circumstances, to deliver advertising to you. You have the right to object to our processing of your Personal Data that is based on our legitimate interests.
When we are required by law to process the Personal Data.
EU/UK Data Subject Rights
The GDPR (EU General Data Protection Regulation) provides certain rights for EU/EEA residents. Residents of the United Kingdom have similar rights under the UK GDPR and Data Privacy Act. You can access information about you and update or correct it. In some cases, you can also ask us to erase it, restrict or stop processing, or provide data in a “portable” form, if feasible. You may withdraw consent (“opt-out”) if you have previously consented to any particular use of your information, such as receiving emails or text messages. For all requests, contact privacy@impact.net. You may also decline to share certain Personal Data with us, in which case we may not be able to provide some or all of the features and functionality of our Site, App, or Services.
You may make changes to the Personal Data collected by our account registration pages as described in the “Accessing and Updating Your Personal Data and Your Choices” section, above. We will reply to your data subject request within 30 days. We may verify your identity and/or request. If we cannot fulfill your request within 30 days, we will inform you when we will be able to do so. We will also provide an explanation if we do not fully comply with your request. When technically feasible, at your request, we will provide your Personal Data to you or transmit it directly to another controller.
Retention of Information
We retain your Personal Data while you have an account with us and while you continue to use or visit any of the Services. We will retain your Personal Data for as long as it is reasonably necessary for the purposes set out in this Privacy Policy, considering the time period reasonably necessary to: provide the Services to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the Services; and comply with legal and regulatory requirements.
Inquiries and Complaints
Please first contact us as set forth below. EU/EEA and UK residents have the right to make a complaint to your national data protection supervisory authority if you do not believe we have resolved your concern.
Contact Us
For all EU/EEA and UK Data Subject Rights requests, please put the statement "Your EU/UK Data Subject Rights" in the subject field of your request. Please provide your contact information in your request and clearly indicate that you are requesting information with respect to the Impact Network.
Email Address: privacy@impact.net
Postal Address:
Impact Creative Systems, Inc.
150 S. El Camino Drive, Suite 100
Beverly Hills, CA 90212
European/UK residents also may learn more about interest-based advertisements from participating third parties at the European Interactive Digital Advertising Alliance page at www.youronlinechoices.eu.
13. Information for Canadian Residents
We make reasonable efforts to notify you of the purposes for which personal data will be used or disclosed and if the initial purpose changes. Please note, you may withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice). Subject to certain limits set out in the applicable laws, Canadian residents also have the right to request access to the personal data that we collect and to update or correct personal data if it is inaccurate.
If you are a Canadian resident and would like to submit a request to access your personal data or to withdraw consent to the processing of your personal data, you must submit your request by sending an email to privacy@impact.net. You may also use this contact to submit any requests for information on our privacy practices or to submit a complaint regarding our practices.
Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding this request.
We cannot properly process requests or complaints that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. Once your request is processed, absent exemptions, we will provide you with details regarding what personal data we have, how it is used, and with which third parties it is shared.
Canadian residents may have additional rights under Canadian law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and successor legislation. Please see the website of the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) for further information.
Canadian residents also may learn more about interest-based advertisements from participating third parties in Canada at the Canadian DAA choice page at http://youradchoices.ca/choices.
You and we confirm that it is our wish that this Privacy Policy, the Terms of Service, and all other related policies be drawn up in English. Vous reconnaissent avoir exigé la rédaction en anglais du présent document ainsi que tous les documents qui s'y rattachent.
14. Additional Information if You Are Located in Countries Outside the US, EU/EEA, UK, or Canada
In certain jurisdictions with relevant data protection laws, including (without limitation) Australia, Brazil, China, Hong Kong, India, Japan, and Mexico, we may require your consent or authorization to use or share your personal data for the purposes described in this Privacy Policy. By providing your personal data to us, you expressly provide such consent or authorization to the extent it is required.
In addition, you may have additional privacy rights under the law of your country of residence, typically including the rights to access, correct, delete, or object to further processing of your personal data. We handle requests to exercise such rights similarly to requests from EU residents under the EU GDPR, as described above.
15. California Privacy Rights
Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information relating to third parties to which the company has disclosed certain categories of personal data during the preceding year for the third parties’ direct marketing purposes. Alternatively, the law provides that a company may comply, as Impact does, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing personal data with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated in this Privacy Policy, Impact provides you choice prior to sharing your personal data with third parties for their direct marketing purposes. If you do not opt-in or if you opt-out at the time we offer that choice, we do not share your information with that identified third party for its direct marketing purposes.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please email us at privacy@impact.net or write to us at the following mailing address: Impact Creative Systems, Inc., 150 S. El Camino Drive, Suite 100, Beverly Hills, CA 90212. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
16. Nevada Privacy Rights
Pursuant to Nevada law, you have the right to opt-out of the sale of certain covered personally identifiable information we have collected about you through our websites and online services, as those terms are defined under applicable Nevada law. We not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may still submit an opt-out request and we will honor that request as required by Nevada law if we were to ever engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of future sales of your covered information, please submit your request to privacy@impact.net. Your request must include your full name, street address, city, state, zip code, and an email address so that we can contact if needed regarding this request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request.