Privacy Policy

Privacy Policy

The websites “,” “,” “,” “,” “,” “,” “,” and “” (“Websites” or, individually, “Website”) are operated by The Imagine Group, LLC (“Imagine”), and the terms “Imagine,” “we,” “us,” “our,” and “ours” when used in this Privacy Policy mean The Imagine Group, LLC, and include subsidiaries, divisions, branches, affiliates, or companies under control of The Imagine Group. The terms “you,” “your,” and “yours” when used in this Privacy Policy mean any user of those websites.


Scope of Privacy

We are committed to protecting the privacy and confidentiality of information you provide us. This privacy policy describes our current policies and practices regarding personal data collected by us from you directly and/or through the Website to the extent that such personal data is protected by law. The term “personal data” refers to personally identifiable information about you, such as your name, job description, health related data, birthday, email address or mailing address.

Notification of Changes to this Policy

We are continually improving our methods of communication and adding new functionality and features to the Website and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. We encourage you to check this page frequently to review this policy so that you are aware of any changes, since any changes shall take effect upon posting.

Collection of Personal Data Including E-mail Addresses

You may choose to buy products from us or receive additional information or services from us. When you purchase our products and services or request additional information, we (or a third-party provider) will request personal information about you such as your name, postal address, e-mail address, telephone number and payment details. We may also ask for demographic information to enable us to provide a personalized service to you. The information you provide is either manually or electronically stored in our databases. We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate postal or zip codes are received, we may use third party software to correct them.

Use of Personal Data

We will use your personal data to fulfill your requests and we will ask only for data that is adequate, relevant and not excessive for these purposes. Where we send you information for any purpose, it may be sent by e-mail or regular mail. When we ask you for personal data it may relate to, but is not limited to, the following purposes:

  • We may contact you to inform you of new products and services we will be providing;
  • We may send you regular updates on issues we think are of interest to you;
  • We may send you requested information on our products and services;
  • We may use your personal data for marketing purposes and market research; and
  • We may use your personal data internally to administer the Website and to improve our services.


We hope you will be delighted with our products and services. If you no longer wish to receive electronic mail or regular mail, please reply to the e-mail with the word “remove” in the subject heading, or, by writing to us at: The Imagine Group, LLC., 1000 Valley Park Drive, Shakopee, MN 55379, Attn: Manager – Customer Service

Anonymous Data Collected Through this Website

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our Website. For example, our web server automatically logs which pages of the Website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our Website. The Website contains hyperlinks to other pages on the Website. We may use technology to track how often these links are used and which pages on our Website our visitors choose to view. Again, this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.


To collect the anonymous data described herein, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies should not damage your computer, and you can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it.

We also use your IP address to help with server problem diagnosis and to administer the Website. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from (i.e.,,, etc.) to more accurately gauge our users’ demographics.

We also use Google Analytics, a web analytics service that helps us understand and get insights about our website, such as the sources where you as a visitor are originating, whether you are a new user, how long your visit to our website lasts, where do you navigate in our website. Google Analytics uses a small piece of Javascript tracking code to collect data about your visit and your interactions on our website. The code is executed within your browser when our website is loaded. The code collects information about your session, such as browser and related settings while visiting, and this information would be stored in cookies on your computer. This data is sent to Google’s servers and processed there. The tracking code sends the information by requesting a small file (i.e., a cookie) that is processed and stored on your computer.

We may also use DemandBase, an account-based marketing, advertising, sales intelligence, and data company. Demandbase uses cookies to collect information, and we use this functionality to analyze trends and to support research. Demandbase adheres to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. To learn more about the DAA and the AdChoices Icon and to opt-out of interest-based advertising delivered by participating companies, please visit the DAA webchoices page.

Disclosure of Your Personal Data

We do not share, sell, or distribute your personal data with unrelated third parties, except as otherwise provided for in this privacy policy and under these limited circumstances:

  • To provide you with the information, services or products which you have requested, personal data may occasionally be transferred or shared with other companies within our group of companies, with other companies that you work with and third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented. For example, sometimes a third party may have access to your personal data to support our information technology, process payment or to handle mailings on our behalf.
  • We will keep your contact details on our database and may where you have consented deliver via e-mail or regular mail information about our other products and services. If you do not wish to receive e-mails or mail from us for these purposes, please let us know by following the “unsubscribe” procedure described herein.
  • Where you have consented, we may also share your personal data with other companies within our group of companies or disclose your personal data to other businesses who may contact you on our behalf or about their products or services that may interest you.
  • We may share, transfer or disclose the information in our databases and server logs to comply with a legal requirements, for the administration of justice, to interact with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this Website, to protect us from legal liability, or in the event of our sale, merger, reorganization, dissolution or similar event.

Where appropriate, before disclosing personal data to a third party, we may contractually require a third party to take adequate precautions to protect that data and to comply with applicable law.

Data Access and Corrections

You may ask us in writing to identify for you the personal data we hold about you, and we are permitted to charge you for the costs of gathering such information. We will also correct, amend, or delete any personal data that you represent to us as inaccurate, and we will notify any third-party recipients of the necessary changes. You may update any information you have given to us by contacting us at Requests to delete personal data are subject to any applicable legal and ethical reporting or document retention obligations imposed on us.

Links to Other Websites

The Website may contain hyperlinks to Websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their operation, data, or privacy practices. We encourage you to review any privacy policy posted on any site you visit before using the site or providing any personal data about yourself.

Transfer of Data Abroad

If you are visiting the Website from a country other than the country in which our servers are located (currently United States of America), the various communications will necessarily result in the transfer of information across international boundaries. By visiting the Website and communicating electronically with us, you consent to the processing and transfer of your data as set out in this privacy policy.

Governing Law

This Privacy Policy forms part of our Website’s Terms of Use and as such shall be governed by and construed in accordance with the laws of the State of Minnesota, United States without regard to any conflict of law provisions.

Contact Us; Mail Unsubscribe

If you no longer wish to receive electronic mail or regular mail, please reply to the e-mail with the word “remove” in the subject heading, or, by writing to us at: The Imagine Group, LLC., 1000 Valley Park Drive, Shakopee, MN 55379, Attn: Manager – Customer Service.


We welcome comments about this privacy policy. If you have any questions about this statement or any part of our service, you may contact us by e-mailing us at

Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Reviewed: February 28, 2023

This Privacy Notice for California Residents (“Notice”) supplements the information contained in our privacy policy. This Notice applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). Imagine adopts this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 1010 (“CPRA”), and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.


  • Personal Information: As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes Sensitive Personal Information.
  • Sensitive Personal Information: As used in this Policy, “Sensitive Personal Information” includes Personal Information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a Consumer’s mail, email, and text messages, unless Imagine is the intended recipient of the communication. Sensitive Personal Information also includes information concerning the Applicant or Employee’s health, sex life, or sexual orientation.
  • Other CCPA Definitions: As used in this Policy, the terms “Collect,” “Processing,” “Service Provider,” “Third Party,” “Sale,” “Share,” “Consumer,” and other terms defined in the CCPA and their conjugates have the meanings afforded to them in the CCPA, whether or not such terms are capitalized herein, unless contrary to the meaning thereof.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific consumer or household (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months.




A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.


B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.


C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).


D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.


E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.


F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.


G. Geolocation data.

Physical location or movements.


H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.


I. Professional or employment-related information.

Current or past job history or performance evaluations.


J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.


K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


L. Sensitive Personal Information

Personal information that reveals:

(A) a consumer's: (i) social security, driver's license, state identification card, or passport number; (ii) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (iii) precise geolocation; (iv) racial or ethnic origin, religious or philosophical beliefs, or union membership; (v) contents of a Consumer’s email and text messages, unless the business is the intended recipient thereof; or (vi) genetic data.

(B) The processing of biometric information for the purpose of uniquely identifying a consumer.

(C) Personal information collected and analyzed concerning a consumer's health, sex life, or sexual orientation.


Personal information does not include the following:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from CCPA’s scope, such as the following:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

Imagine obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete.
  • Indirectly from you. For example, through information we collect in the course of providing services.
  • Directly and indirectly from activity on any of our Websites. For example, from submissions through a website portal or website usage details collected automatically.
  • Directly from third parties, such as your employer, partners and service providers who work with us in relation our services, and publicly available sources, such as public websites, open government databases or other data in the public domain, to help us maintain data accuracy and provide and enhance our services.
  • Applicants and Employees when they complete recruiting and employment forms.
  • Service Providers and Third Parties that help us screen and onboard individuals for hiring purposes and when they share the information with us.
  • Joint marketing partners, public databases, providers of demographic data, publications, professional organizations, educational institutions, social media platforms.

Use of Personal Information

We may use or disclose the personal information for one or more of the following business purposes:

  • Fulfill or meet the reason for which the information has been provided.
  • Provide you with information, products, or services that you request from us.
  • Provide you with email alerts and other notices concerning our products or services, or events or news that may be of interest to you.
  • Carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collections.
  • Improve our website and present its contents to you.
  • Testing, research, analysis, and product development, including to develop and improve our Website, product, and services.
  • As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
  • Respond to law enforcement requests and as required for compliance with applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • Engage in corporate transactions requiring review of employee records, such as evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • Recruit and evaluate job applicants and candidates for employment.
  • Conduct background checks.
  • Manage your employment relationship with us, including for these items:
    • Onboarding processes.
    • Timekeeping, payroll, and expense-report administration.
    • Employee benefits administration.
    • Employee training and development requirements.
    • The creation, maintenance, and security of your online employee accounts.
    • Reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill.
    • Worker’s compensation claims management.
    • Employee job performance, including goals and performance reviews, promotions, discipline, and termination.
    • Other human resources purposes.
  • Manage and monitor employee access to company facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Investigate and enforce compliance with and potential breaches of Imagine policies and procedures.
  • Maintain commercial insurance policies and coverages, including for workers' compensation and other liability insurance.
  • Perform workforce analytics, data analytics, and benchmarking.
  • Administer and maintain Imagine’s operations, including for safety purposes.
  • For client marketing purposes.
  • Exercise or defend the legal rights of Imagine and its employees, affiliates, customers, contractors, and agents.
  • Operate, manage, and maintain our business.
  • Perform accounting, audit, and other internal functions, such as internal investigations.
  • Exercise and defend legal claims.
  • Otherwise accomplish our business purposes and objectives.

In addition to the purposes identified above, Imagine may use and disclose any and all Employee Personal Information that we Collect as necessary or appropriate to perform any of the following:

  • Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws.
  • Monitor, investigate, and enforce compliance with and potential breaches of Imagine policies and procedures and legal and regulatory requirements;
  • Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
  • Exercise or defend the legal rights of Imagine and its employees, affiliates, customers, contractors, and agents.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Imagine may disclose your personal information to a third party for a business purpose, such as these:

  • Applicant selection and related hiring services.
  • Benefits and wellness services.
  • Legal services

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers
  • Our affiliates
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
    • We may disclose your Personal Information to any Third Party with your consent or at your direction.
    • We may disclose your Personal Information to a Third party for a business purpose.
    • We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

In the preceding twelve (12) months, Imagine has disclosed the following categories of personal information for business purposes:

  • Category A: Identifiers
  • Category B: California Customer Records personal information categories
  • Category C: Protected classification characteristics under California or federal law
  • Category I: Professional or employment-related information

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumer (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Imagine disclose specific information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, a separate list identifying the personal information categories that each category of recipient obtained.

Right to Receive Information on Privacy Practices

You have the right to receive the following information at or before the point of Collection:

  • The categories of Personal Information to be Collected.
  • The purposes for which the categories of Personal Information are Collected or used.
  • Whether or not that Personal Information is Sold or Shared.
  • If the business Collects Sensitive Personal Information, the categories of Sensitive Personal Information to be Collected, the purposes for which it is Collected or used, and whether that information is Sold or Shared.
  • The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.

Right to Receive Information About Onward Disclosures

You may request that we disclose to you the following:

  • The categories of Personal Information that we have Collected about you;
  • The categories of Personal Information that we have Sold or Shared about you and the categories of Third Parties to whom the Personal Information was Sold or Shared; and
  • The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Deletion Request Rights

You have the right to request that Imagine delete any of your personal information that we collected from you and retained, subject to specific exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to perform the following:

  • Complete the transaction for which we collected the personal information, provide a good or service that you request, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Comply with a legal obligation
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Correction

You may request that we correct any inaccurate Personal Information we maintain about you.

Exercising Your Data Subject Rights Available to You

To exercise the access, data portability, right to receive information, deletion and correction rights described above, please submit a verifiable consumer request to us by either of these methods:

  • Calling us: 818-295-6100 (you may hear reference to “Midnight Oil” in the greeting, as “Midnight Oil” is a California-based subsidiary of The Imagine Group)
  • Visiting

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.

You may make a verifiable consumer request for access or data portability only twice within a 12-month period. The verifiable consumer request must contain the following:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information, if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verifiable when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forth-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures that we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We do not Sell or Share Personal Information. Further, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA. Relatedly, we do not have actual knowledge that we Sell or Share Personal Information of California Consumers under 16 years of age. For purposes of the CCPA, a “Sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “Share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether for monetary or other valuable consideration.


You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising any of your data subject rights. For example, we will not make hiring, firing, promotion, or disciplinary decisions based on or in consideration of your exercise of your data subject rights. Unless permitted by the CCPA, we will not perform the following:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

Under California law, we do not provide financial incentives to California Consumers who allow us to Collect, retain, Sell, or Share their Personal Information. We will describe such programs to you if and when we offer them to you.

Retention of Personal Information

We retain each of the above-listed categories of Personal Information for the duration of your relationship with us, as applicable, and longer as may be required by applicable laws or necessary for our legitimate business purposes.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please contact us:

Phone: 818-295-6100 (you may hear reference to “Midnight Oil” in the greeting, as “Midnight Oil” is a California-based subsidiary of The Imagine Group)


If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact or 818-295-6100 (you may hear reference to “Midnight Oil” in the greeting, as “Midnight Oil” is a California-based subsidiary of The Imagine Group).

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