Privacy Policy

Last updated: October 21, 2021

If you have any questions about this privacy policy or anything else, please reach out to dpo@imagerelay.com.

1. Who We Are. Image Relay, Inc. (“Image Relay”, “we”, “our”, or “us”) provides services that help organizations manage their valuable digital assets. Our main service is a Software-as-a-Service (SaaS) platform for digital asset management. We are a certified B-Corporation based in Burlington, VT.When you use the Image Relay website www.imagerelay.com, Image Relay’s associated domains, Image Relay’s application programming interface (API), Image Relay applications on devices, or through third parties (collectively “Services”), this Policy will apply.

2. How This Policy Applies. This Policy describes the Personal Information we collect from you, how we use that Personal Information, how we share your Personal Information, our legal bases for doing so, and your rights regarding the Personal Information you provide to us.“Personal Information”, as we use the term in this Policy, means any information relating to an identified or identifiable natural person.

You are not legally required to provide us with any Personal Information. If you do not wish to provide us with Personal Information, please do not use our Services. By using the Services offered by Image Relay, you’re acknowledging you have read and consent to our Terms of Service and this Privacy Policy.

3. Information We Collect. The types of Personal Information we and/or our service providers collect from you will vary depending on your use of the Services:

• When you sign up for Image Relay, we collect your name, your company name, and your email address.
• When you upload files to our Services we collect information on your files, such as file properties, metadata, and distribution information.
• When you elect to use paid Services our service provider collects your billing information for payment processing.
• When you provide users access to the Services, we collect the users’ names, company names, and email addresses.
• When you interact with our Customer Support team we collect information pertaining to your support needs.
• When you participate in our surveys or take advantage of our promotional offers, we collect this information for research and marketing purposes.

4. Automatic Tracking Technologies and Analytics. In addition to the categories of Personal Information listed in Section 3, when you use our Services we and our service providers use automatic information collection and tracking technologies such as cookies (small text files placed on a device when it is used to access the Services) and pixel tags (sometimes called web beacons) to automatically collect information such as your IP address or other unique device identifier, browser type, device type, operating system, application version, login time, use of the Services’ features, and acceptance of online agreements. More information on the types of cookies we and our service providers use is below:

• Proprietary cookies are sent to your device from a device or domain providing the services you have requested (in this case Image Relay).
  • Third-party cookies are sent to your device from a device or domain which is not managed by Image Relay but is instead managed by another entity that processes the data obtained using cookies.
  • Session cookies collect and store data while you are viewing a website.
  • Persistent cookies store data on your device and can be accessed and processed for a specific period of time by the party responsible for the cookie. This period may last for minutes or years.
  • Technical cookies allow you to navigate around a website and make use of the various options and services.
  • Personalized cookies allow you to access a service with some generally pre-defined characteristics, based on a set of criteria stored in your own device.
  • Analysis cookies allow the entity responsible for the cookie to follow up and analyze the behavior of the user of their website.

Most web browsers automatically accept cookies but, if you prefer, you can modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. 

5. How We Use Your Information. Your Personal Information WILL NOT be sold or shared for the purpose of generating advertising revenues. We and our service providers utilize your Personal Information to:

• authenticate your identity;
• personalize, maintain, and improve our Services for you;
• perform transactions and fulfill requests necessary to meet our Terms of Service agreement;
• inform you of and provide you with feature upgrades, promotions, support needs, and service announcements;
• comply with applicable laws and respond to legal requests;
• perform transactions with trusted third-party software providers with which you have requested our Services integrate (whether via our own API or one of our application partners);
• better understand how our Services are used;
• support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity;
• support our legitimate interests in maintaining and improving our Services, but only to the extent that our legitimate interests are not outweighed by your privacy rights.
• carry out any other purposes described to you at the time that we collect the Personal Information.

If you are in a jurisdiction that requires a specific legal basis for processing your Personal Information, our legal basis for collecting and using the information will depend on the type of Personal Information and the specific context in which we collect it but will fall into one or more of the above categories.

We may also de-identify and aggregate your Personal Information for our own purposes. “De-identified” Information is Personal Information that has been stripped of your identifiers, such as your name, contact information, and other identifying data, such that you cannot reasonably be identified as an individual. “Aggregated” Information is Personal Information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.

6. How We Share Your Information.

• Service Providers. As referenced in Sections 3 through 5 above, we use trusted third-party vendors for necessary hardware, storage, networking, and related technology services in connection with providing you with, promoting, and improving our Services. Third-party providers will only have access to information necessary to fulfill their obligations to Image Relay and for Image Relay to be compliant with our Terms of Service. If you choose to integrate with a third-party application provider or utilize an existing integrated option your Personal Information will be shared as necessary to deliver these Services. To ensure that your data is protected and used securely and appropriately, Image Relay has contracts with its service providers which provide protection for your Personal Information under applicable laws (for example, the EC’s Standard Contractual Clauses for residents in the European Economic Area). Please note, the terms of service and privacy policies of the service providers we use will in such instances apply to you as well, and your acceptance of such terms and policies is required in order to use our website and Services.  Please feel free to contact us for a list of those Image Relay service providers who may have access to your Personal Information.
• Account Owner. If you do not own the Image Relay account, we may share your Personal Information with the customer that owns the account to which you are subscribed as a user (for example, your employer if your employer owns the account).
• Legal Compliance. We may disclose or allow government and law enforcement officials access to your Personal Information in response to a subpoena, search warrant, court order, or similar requirement, or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services.
• Change in Control or Financial Transaction. We may provide access to your Personal Information in order to facilitate due diligence with third parties in connection with a transaction such as a merger, financing, or acquisition of all or a portion of our business or our acquisition of another business. In the event that a merger or acquisition will take place we will promptly notify you prior to any ownership transfer of Personal Information.
• Consent. Image Relay may share your Personal Information in additional manners if you provide us with your explicit approval to do so.

7. Where Your Information is Stored and How Long It’s Retained.  Your Personal Information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place regarding the security of your data and other Personal Information.

We will retain your Personal Information as long as your account is active, as necessary to provide you with the Services, or as otherwise set forth in this Policy. We will also retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Information for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you.

8. How We Protect Your Information. We secure your Personal Information using industry-standard physical, procedural, and technical measures designed to prevent unauthorized or unlawful access, disclosure, or destruction of information. For more information please review our Security Policy at https://www.imagerelay.com/security.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us, and you use the Services and provide us with your Personal Information at your own risk. If you have reason to believe that your Personal Information is no longer secure (for example, your Image Relay account password may have been compromised), please immediately email us at dpo@imagerelay.com.

9. Your Rights to Your to Information. You control the Personal Information that you provide to us in connection with the Services; however, certain information is required in order for us to provide you with our Services. You may at any time update, correct, or delete Personal Information that you have provided to us by logging into your account on Image Relay and clicking on the “Account” button in the upper right-hand corner of the webpage. You can also request an activity log report by contacting dpo@imagerelay.com. If you have any questions on accessing, updating, or removing your Personal Information please contact us at dpo@imagerelay.com.

10. U.S. State Privacy Rights. Certain U.S. states (including, but not limited to, California, Colorado, and Virginia) provide their state residents with additional legal rights concerning their Personal Information.  If you are a resident of one of these states and are using our Services, you have the right to: (i) have Image Relay disclose further details on the categories and pieces of Personal Information that we have collected about you; (ii) have Image Relay disclose Personal Information on what Personal Information we plan on collecting about you before we collect it; (iii) opt out of our marketing and/or analytics activities; (iv) have Image Relay delete any Personal Information which we have collected about you; (v) ensure that Image Relay not sell your Personal Information; and (vi) ensure that Image Relay provides you with equal services without discrimination.  Image Relay will honor all data privacy laws in the state (or nation) in which you reside.

Image Relay does not sell Personal Information, and Image Relay does not discriminate against any user in providing access to its Services.

Please note that we do not alter our data collection and use practices when we see a Do Not Track signal from your browser.

If you would like to make a state law-related request, please email us at dpo@imagerelay.com. Please note that we may ask you to verify your identity before responding to the request, and that we have 30 days to respond to you.

11. Your Rights Under General Data Protection Regulation (GDPR). If you are a resident of the European Economic Area (EEA), you have certain additional data protection rights, including the right to:

• access, update, or delete the Personal Information we have collected on you;
• have your Personal Information rectified if that information is inaccurate or incomplete;
  object to our processing of your Personal Information;
• request that we restrict the processing of your Personal Information;
• be provided with a copy of your Personal Information in a structured, machine-readable, and commonly used (i.e., data-portable) format;
• withdraw your consent at any time where Image Relay relied on your consent to process your Personal Information;
• complain to a data protection authority about our collection and use of your Personal Information. For more information on how to lodge such a complete, please contact your local data protection authority in your EEA Member State.

If you would like to make a GDPR-related request, please email us at dpo@imagerelay.com. Please note that we may ask you to verify your identity before responding to the request, and that we have one month to respond to you.

12. Contacting Us; Privacy Complaints. If you have any questions, concerns, or complaints about this Privacy Policy or the way we process your Personal Information, or if you want to exercise your rights as described above, please contact our Data Protection Officer by email at dpo@imagerelay.com, or by mail to: Data Protection Officer / Image Relay, Inc. / 50 Lakeside Ave, Suite 831 / Burlington, VT 05401 / USA. Additionally, you also have the right to lodge a complaint with your state or national data protection enforcement agency.

13. Use of Services by Minors. We do not knowingly collect Personal Information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children, we will take steps to remove that information from our servers.

14. Links to Other Sites. Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

15. Updates to the Privacy Policy.  We may update and amend this Privacy Policy from time to time. Updates will be posted publicly at this site and be effective immediately as of the date of posting. If we make substantive changes to this Policy, we will update you by email or in-app notice.  If you use the Services following a change in this Privacy Policy, your use will constitute your acceptance of the updated Privacy Policy. Accordingly, we encourage you to review this Privacy Policy periodically for any changes. If your Personal Information is to be used for a purpose that is materially different from that for which the Personal Information was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Image Relay will provide you with an opportunity to choose whether to have your Personal Information so used or disclosed. Requests to opt out of such uses or disclosures should be sent to dpo@imagerelay.com.