Privacy Policy

1. Description
Imperium, LLC ("Imperium," "we" or "us") is in the business of providing services in connection with Imperium's technology, including, without limitation, its Real Answer, RelevantID, Verity and ChildGuardOnline services. Imperium's headquarters and principal place of business is located at 1720 Post Road East Suite 221 Westport, Connecticut 06880.

2. Privacy Commitment
" This Privacy Policy (this "Privacy Policy") applies to all Personal Information submitted or disclosed by individuals (hereinafter referred to as "You" or "Your") either: (a) through Imperium's general company website (the "Imperium Website") via the "contact" feature located within the Imperium Website; (b) directly to Imperium in writing or via email or (c) submitted through or in connection with one of Imperium's services (as described in more detail below). For the purpose of this Privacy Policy, the term "Personal Information" includes, without limitation, first and last name; job title and company name; home or company street address; city, state and zip code; home or company telephone number; date of birth; and social security number. Imperium will only use the Personal Information for the purpose(s) for which such Personal Information is submitted or disclosed to Imperium and for no other purpose(s). Please do not submit or disclose any bank account, financial or credit card information through or in connection with the Imperium Website. Imperium will not sell your Personal Information to any third party or third parties for any marketing or advertising purpose(s).

3. Collection and Use of Information in General
Except as part of one of Imperium's services described in more detail below, Imperium does not actively initiate any collection of any Personal Information. Imperium may passively collect information, through information that is automatically sent to Imperium by your web browser and the use of internet cookies. This information typically includes your domain name (the site after the "@" in your e-mail address). In connection with the RelevantID service, Imperium uses cookies to prevent survey respondents from taking the same survey multiple times. Imperium does not actively seek to identify visitors to the Imperium Website; except in connection with an investigation of a security breach or in cooperation with any law enforcement agencies or departments. Imperium uses the information automatically received from your web browser to see which web pages you visit within the Imperium Website; which website you visited before coming to the Imperium Website; and where you go after you leave the Imperium Website. This allows Imperium to understand how the Imperium Website is being used by its visitors. Imperium does not use or share any of this information with any marketers or advertisers.

4. Our Privacy Practices with Respect to the Real Answer Service
What is Real Answer? Real Answer is a web-based market research service. Imperium's technology enables our customers ("Users") to analyze open ended responses from survey respondents for data quality and fraud prevention. Survey respondents may be clients, employees, panelists, suppliers, customers etc. of our Users. Information that survey respondents provide to Users resides on our servers in a secure environment. Information Collected in Connection with Real Answer: Real Answer does not collect Personal Information (as defined herein). All responses to survey questions are stored against an anonymous ID number, provided by the Users.

5. Our Privacy Practices with Respect to the Relevant ID Service
What is RelevantID? RelevantID is a technology utilized by Imperium that works through a combination of watermarking and digital fingerprint technology to enable Imperium to improve the quality and integrity of survey results or other interactions requiring fraud prevention for its Users. Digital fingerprinting is the process of collecting data points from the web browser of a respondent's computer to create a unique identifier. RelevantID does not download any software onto a respondent's computer. RelevantID does not track the online activities of a respondent. RelevantID obtains the Collected Information (as defined herein) from a respondent's computer when the respondent joins a survey panel, starts a survey or participates in a marketing campaign. Information Collected In Connection with RelevantID: RelevantID does not collect any personally-identifiable information ("PII") concerning the owner or user of a computer (though we do collect the publicly available IP address, which may be considered PII in some non-US jurisdictions). RelevantID collects publicly available information from within the web browser of a respondent computer. This publicly available information may include, without limitation, the operating system version, the browser version, screen resolution, and display information (the "Collected Information"). How is the Collected Information Used and Disclosed? Collected Information is processed through RelevantID's proprietary algorithm to create a digital fingerprint that is assigned to a respondent's computer. Collected Information is used solely to confirm the unique presence of a respondent's computer. Collected Information is used only in connection with RelevantID and is not used, transferred, sold or distributed for any other purpose(s). Generally, RelevantID is used by our Users for de-duping purposes, to perform respondent quality assessments, and redirect detection and prevention services. In the event that a User provides Imperium with a respondent ID, Imperium can match the respondent ID to the RelevantID. After matching the respondent ID and RelevantID, Imperium will provide the matched IDs to the User, either in a database or some other form or format as requested by the User. At no time does Imperium receive or have access to any PII connected to the respondent IDs. The RelevantID and the Collected Information are disclosed only to the User and its authorized employees and/or agents.

6. Our Privacy Practices with Respect to our Verity Service
What is Verity? Verity is a data validation service that Imperium provides to its Users to verify the accuracy of individual names, addresses and other demographic data supplied by the Users. Verity verifies certain information against databases specializing in the validation of consumer demographics. The Verity services can be performed either in real time or in batch. How is Information Collected and Used in Connection with the Verity Service? Personal Information is collected and used in connection with the Verity service as follows: A User submits certain Personal Information (i.e. first and last name, address, data of birth, etc.) either via batch or web service call. Imperium will transfer or disclose such Personal Information to a third party database vendor, who will match the Personal Information against its database(s). The database vendor will return the Personal Information to Imperium, together with normalized data and indications of accuracy. Imperium will provide its client with the normalized data and proprietary Verity scoring. Upon completion of the services, Imperium will delete or remove all Personal Information supplied or provided by clients in connection the Verity service.

7. Our Privacy Practices with Respect to the ChildGuardOnline Service
What is ChildGuardOnline? ChildGuardOnline is a parental consent validation and verification service that Imperium provides to its customers so that they can comply with the Children's Online Privacy Protection Act (COPPA). ChildGuardOnline verifies the accuracy of Personal Information (e.g., individual names and social security numbers) provided by parents and guardians ("Users") against a variety of databases. How is Information Collected and Used in Connection with ChildGuardOnline? Personal information is collected and used in connection with the ChildGuardOnline service as follows: A User submits certain Personal Information (i.e. first and last name, address, phone, date of birth, and last digits of their social security number). Imperium will transfer or disclose such Personal Information to a third-party database vendor, who will match the Personal Information against its database(s). The database vendor will return the Personal Information to Imperium. Imperium will notify parent or guardian if they have been validated. Upon completion of the services, Imperium will delete or remove all Personal Information supplied or provided by Users in connection with the ChildGuardOnline service. Imperium will never disclose or use Personal Information for any other purpose.

8. Security
Imperium is committed to protecting the security and integrity of Personal Information. Imperium maintains commercially reasonable technical, administrative and physical safeguards to protect and secure Personal Information from unauthorized disclosure to, and/or use and/or access by, any third party or third parties. Imperium uses commercially reasonable efforts to ensure that its all of its services are safe, secure and do not cause undue privacy or data security risks. Imperium is aware of your privacy concerns and strives to collect only as much data as is required to make your experience as efficient and satisfying as possible, in the most unobtrusive manner as possible. Imperium will only maintain Personal Information for as long as necessary to fulfill the purpose for which such information was collected. In the event that Imperium discovers or learns of any unethical conduct in connection with the use of its any of its services or that the any of its services are being used in a manner inconsistent with this Privacy Policy; and/or (i) any applicable international, Federal, state and/or local laws, codes, regulations, rules and/or requirements and/or (ii) codes and regulations of the trade and/or professional association(s) and/or organization(s) with whom Imperium is a member, including without limitation the Council of American Survey Research Organizations, Imperium will use its best efforts to correct, rectify, and prohibit such unethical conduct and to ensure the proper administration of its services.

9. Onward Transfer of Information
Imperium will not sell your personal information to any third party or third parties for any marketing or advertising purpose(s). Imperium may disclose your information to companies or persons we engage to perform services for us. In such cases, the third party will be given access to the information on the understanding that it will be used solely to render the services we require. Imperium may also share your information with our corporate affiliates and with any third party that purchases substantially all of our assets or business; provided, however, that such third party has agreed to use and protect your personal information in accordance with this Privacy Policy. We will also share information we have collected with third parties as required by law, regulation, legal process or governmental inquiry. 10. Third Party Links For your convenience, the Imperium Website may contain certain hyperlinks to websites owned and/or operated by a third party or third parties ("Third Party Websites). Please be advised that Imperium does not endorse any of the Third Party Websites accessible via any hyperlink contained within the Imperium Website. Imperium makes no representations, warranties or covenants about the Third Party Websites; any products and/or services available on or through the Third Party Websites; or the privacy and data security practices of the owners and/or operators of the Third Party Websites. Please review the Third Party Websites and their respective policies carefully.

11. Disclaimer
Imperium hereby disclaims any and all liability and/or responsibility for the privacy practices of Users. Imperium strongly recommends that respondents refer to the User and/or the User's website(s) for information on the privacy practices applicable to the appropriate User. Imperium does not review, comment upon, or monitor its Users' compliance with their respective privacy policies.

12. Amendments to this Privacy Policy
Imperium hereby reserves the right to make changes to this Privacy Policy, from time to time, and Imperium will post any such changes on the Imperium Website for your review. Your continued use of, and interaction with, the Imperium Website, after Imperium revises this Privacy Policy constitutes your acceptance of this Privacy Policy, as amended.

13. Limitation of Liability
In no event will Imperium be liable for any damages arising out of the use, inability to use, or the results of use of the Imperium site, any web site(s) linked to the Imperium site, or the materials or information or services contained at the Imperium site or any third party sites. You specifically acknowledge and agree that Imperium will not be held liable for any defamatory, offensive or illegal conduct on the part of our clients or of any other Web site(s) to which Imperium is linked. If you are dissatisfied with any Imperium material, or with any of Imperium's terms and conditions, your sole and exclusive remedy is to discontinue using Imperium.

14. Applicable Laws
This Privacy Policy will be governed by and construed in accordance with the laws of the State of Connecticut USA, without giving effect to any principles of conflict of laws.

15. Privacy Policy Issues/Concerns/Complaints/Information
In the event that you have any issues, concerns, or complaints, or would like additional information about Imperium's privacy practices, please contact Imperium by:
Sending an e-mail to Regular mail, postage pre-paid to:
Imperium, LLC
1720 Post Road East Suite 221
Westport, Connecticut
Attn: Marshall Harrison

Last Updated: February 1st, 2017