At Iron Horse Interactive we respect the privacy of our users and the importance of the information they entrust to us. For this reason, we have adopted the following policy to advise you of our use of your personal information online and your choices regarding that use. This policy describes what types of information we gather about you, how we use it, under what circumstances we disclose it to third-parties, and your rights to update or correct it. Iron Horse Interactive provides growth and digital marketing services to businesses – our clients. Our services are designed for businesses and are not intended individuals’ personal, family or household use. Accordingly, we treat all personal information covered by this Privacy Policy, including information about any visitors to our website, as pertaining to individuals acting as business representatives, rather than in their personal capacity. To take advantage of our services, our clients share with us information about their customers and sales leads, including contact details. We process that information only at the direction of the client who provided the information, and only on that client’s behalf. We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential customers or job applicants’ resumes.

SCOPE OF POLICY

• the ironhorse.io website, and any other websites, mobile applications, or online services controlled by us and which display this Privacy Policy
• Iron Horse Interactive’s services and applications.

This Policy does not apply to other companies’ or organizations’ web sites to which we link. You should carefully review the privacy policies of those web sites in order to determine how they treat your personal information.

Click on the links below to jump to sections of the Privacy Notice:

• Information We May Collect
  • Information We Collect for Iron Horse Interactive’s Own Business Purposes
  • Information We Collect from or on Behalf of Our Clients
• Cookies and Other Information Collected by Automated Means
• How We May Use Information We Collect
  • Our Use of Personal Information for Iron Horse Interactive’s Own Business Purposes
  • Our Use of Personal Information on Behalf of our Clients
• With Whom We May Share Information We Collect
• Careers
• Privacy Preferences, Rights, And Choices
• Your California Privacy Rights
• International Data Transfers
• Security
• Data Retention
• Changes To Our Privacy Policy
• How To Contact Us

INFORMATION WE MAY COLLECT

Information We Collect for Iron Horse Interactive’s Own Business Purposes

We may collect information about individuals who interact with Iron Horse Interactive when using our website, mobile applications and our services (such as employees of our clients), job applicants, and other individuals.

How we collect the information

We may collect information:

• Directly from individuals
• From third party vendors, data brokers, or business partners
• From recruiters

Types of information we collect

The types of information we collect include personal and business contact information (such as contact name, business name, title, address, telephone number, and email address), and information individuals may provide in responses to survey questions.

Information We Collect from or on Behalf of Our Clients

We may collect information about individuals from our clients, such as through the operation of our services. Our clients determine the scope of the information transferred to us, and the information we receive may vary by client. Typically, we may collect business contact information from our clients when providing growth marketing services on behalf of our clients. Our clients may also request that we supplement data provided by the client with information from third-party vendors, data brokers, or business partners.

COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS

We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites and other mobile applications.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the “Privacy Preferences, Rights and Choices” section below for information about how you may opt-out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.

The information we collect by automated means includes:

• Details about the devices that are used to access our websites and mobile applications (such as the IP address, type of device, operating system and web browser, and language settings)
• Dates and times of visits to, and use of, our websites and mobile applications
• Information about how our websites and mobile applications are used (such as the content that is viewed on our websites and how users navigate between our webpages, or the features of our mobile applications that are used and how users navigate between screens on our mobile applications)
• Details about how individuals interact with our emails (such as whether the email is opened and which links are clicked in the email)
• URLs that refer visitors to our websites
• Search terms used to reach our websites or locate our mobile applications

Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.

HOW WE MAY USE INFORMATION WE COLLECT

Our Use of Personal Information for Iron Horse Interactive’s Own Business Purposes

We may use information to:

• Fulfill your requests for products and services.
• Offer products and services that may be of interest to you.
• Customize the content that you see in our services and applications.
• Contact you for feedback and surveys.
• Send you information about Iron Horse Interactive products and services.
• Provide and facilitate use of our services and applications.
• Analyze use of and improve our applications, products and services (including to develop new products and services).
• Identify and protect against fraudulent transactions and other misuses of our websites and mobile applications.
• Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)
• Invoice and collect payment for our services
• Establish and maintain an individual’s profile on our website
• Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing our Terms of Service.
• Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)
• Process employment applications
• Monitor recruiting statistics, to inform our recruitment activities
• We may also use information about you to target advertising while you are visiting our services or using our applications. For example, we may use geographic or other information we have collected from you to make sure that the ads you see are for goods and services that are actually of interest to you or are available in your area. We or our service providers may use cookie files to assure that you will not be served the same ads repeatedly.

We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

Our Use of Personal Information

We use personal information we collect from or on behalf of our clients to provide services to our clients at their direction. We do not use this information for Iron Horse Interactive’s own purposes. We use personal information only as directed or authorized by our client. Typically, we are directed or authorized to use personal information collected on behalf of the client to:

• Fulfill your requests for products and services. Offer products and services that may be of interest to you.
• Customize the advertising and content that you see in our services and applications.
• Send promotions and coupons based on your interests.
• Contact you for feedback and surveys.
• Send you other information about Iron Horse Interactive products and services.
• Facilitate use of our services and applications.
• Analyze use of and improve our applications, products and services.
• Identify and protect against fraudulent transactions and other misuses of our applications.
• Enforce our Terms of Service.

WITH WHOM WE MAY SHARE INFORMATION WE COLLECT

We will not share your personal information with others except as indicated below, or except when we inform you in advance and give you the opportunity to opt-out. We may share personal information with:

• Service providers performing services on our behalf, such as customer success and tech support providers, and technology providers (such as credit-card payment processors, and web hosting and email service providers and demand gen service providers)
• Iron Horse Interactive affiliates and subsidiaries
• Advertising and marketing partners
• Analytics organizations

UUnless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.

In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.

CAREERS

If you submit your information in connection with job opportunities with us, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use and disclose this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, monitoring recruitment statistics, and contacting you and/or your references and former employers. We also retain statistical information about applicants to help inform our recruitment activities. We will process this information based on our legitimate interest of evaluating job candidates or, when you provide us with sensitive information, based on your consent. We may also use and disclose the information we collect as necessary to comply with legal requirements, judicial process, and our company policies.

PRIVACY PREFERENCES, RIGHTS AND CHOICES

Individuals have certain rights and choices regarding Iron Horse Interactive’s processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.

Individuals whose personal information Iron Horse Interactive processes on behalf of a client should contact that client to exercise the rights and choices described in this section.

We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.

General Objections to the Processing of Personal Information

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Iron Horse Interactive’s use or disclosure of your personal information will mean that Iron Horse Interactive will not be able to provide products or services to you or to otherwise engage with you.

Access to Personal Information

You may request access to the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Portability of Personal Information

You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Deletion of Personal Information

You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Marketing Emails

You may unsubscribe from receiving marketing or other commercial emails from Iron Horse Interactive by following the instructions included in the email. However, even if you opt-out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).

Online Behavioral Advertising

Some of the business partners that collect information about users’ activities on our websites or in our mobile applications may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. For example, users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Mobile application users may opt out of receiving targeted advertising in mobile applications through members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices.

Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, in addition to the rights set forth above, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes. California law gives you the right to send us a request at a designated address to receive the following information:

The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year

The names and addresses of the third parties that received that information

If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed

We may provide this information in a standardized format that is not specific to you. The designated email address for these requests is info@ironhorse.io.

INTERNATIONAL DATA TRANSFERS

We may transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where Iron Horse Interactive is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.

SECURITY

We take appropriate physical, electronic, and other security measures to help safeguard personal information from accidental, unlawful, or unauthorized access, alteration, disclosure, use, loss, or destruction.

DATA RETENTION

We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.

CHANGES TO OUR PRIVACY POLICY

Iron Horse Interactive reserves the right to change this Privacy Policy at any time. When we update this Privacy Policy, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Policy and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Policy in other ways, such as via email or other contact information you have provided.

HOW TO CONTACT US

If you have any questions, comments, or complaints about this Privacy Policy or our information practices, please contact us by email or postal mail below:

Email:

info@ironhorse.io

Address:

6111 Bollinger Canyon Road, Suite 555, San Ramon CA 94583

If you are a resident within the European Economic Area, you also have the right to file a complaint with the supervisory authority of your member state.