- **Through our social media pages and apps including https://www.facebook.com/myireinc/ (collectively, our "Social Media Pages").**
Collectively, we refer to the Websites and our Social Media Pages as the "Services".
**"Personal Information"** is information that identifies you as an individual or relates to an identifiable individual. Personal Information that may be collected through the Services include name, business title, phone number, email address, digital wallet address and encrypted login credentials, business address, social medial friend/follower lists, and other social media profile information you make available to us.
**Collection of Personal Information**
We and our service providers collect Personal Information in a variety of ways, including:
- **Through the Services:** We collect Personal Information through the Services, for example, when you sign up for a newsletter or through your use of the MyIRE Platform.
- **Offline:** We collect Personal Information from you offline, e.g., when you contact us or our customer service representative.
- **From Other Sources:** We receive your Personal Information from other sources, for example:
-- your employer when your employer signs a Membership Agreement or a Master Services Agreement with us for the use of the MyIRE Platform;
-- Identity and background screening services, when they share the information with us,
-- publicly available databases;
-- joint marketing partners, when they share the information with us.
**Use of Personal Information**
We and our service providers use Personal Information for legitimate business purposes including:
- **Providing the functionality of the Services and fulfilling your requests.**
-- To provide the Services' functionality to you, such as providing you with customer service;
-- To respond to your inquiries and fulfill your requests, when you contact us, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services;
-- To complete your transactions, and provide you with related customer service;
-- To send administrative information to you, such as changes to our terms, conditions and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- **Providing you with our newsletter and/or other marketing materials and facilitating social sharing.**
-- To send you marketing related emails, with information about our services, new products and other news about our company;
-- To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or where we have a legitimate interest.
- **Analysis of Personal Information for business reporting and providing personalized services.**
-- To analyze or predict our users' preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services;
-- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
-- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- **Allowing you to participate in sweepstakes, contests or other promotions.**
-- We may offer you the opportunity to participate in a sweepstakes, contest or other promotion;
-- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.
We use this information to manage our contractual relationship with you.
- **Aggregating and/or anonymizing Personal Information:** We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.
We do so to generate other data for our use, which we may use and disclose for any purpose.
- **Accomplishing our business purposes.**
-- For data analysis, for example, to improve the efficiency of our Services;
-- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
-- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
-- For developing new products and services;
-- For enhancing, improving, or modifying our current products and services;
-- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
-- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
-- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users' interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
**Disclosure of Personal Information**
We disclose Personal Information:
- **To our third party service providers, to facilitate services they provide to us:** These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- **By using the Services, you may elect to disclose Personal Information:** On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
**Other Uses and Disclosures**
We also use and disclose your Personal Information as necessary or appropriate:
- **To comply with applicable law and regulations:** This can include laws outside your country of residence.
- **To cooperate with public and government authorities.**
-- To respond to a request or to provide information we believe is important;
-- These can include authorities outside your country of residence.
- **To cooperate with law enforcement:** For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- **For other legal reasons.**
-- To enforce our terms and conditions;
-- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- **In connection with a sale or business transaction.**
-- We may use, disclose, or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
-- Such third parties may include, for example, an acquiring entity and its advisors.
**"Other Information"** is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, including:
- **Browser and device information.**
- **App usage data.**
- **Information collected through cookies, pixel tags and other technologies.**
- **Demographic information and other information provided by you that does not reveal your specific identity.**
- **Information that has been aggregated in a manner such that it no longer reveals your specific identity.**
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
**Collection of Other Information**
We and our service providers may collect Other Information in a variety of ways, including:
- **Through your browser or device:** Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- **Using pixel tags and other similar technologies:** Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- **IP Address:** Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
**Uses and Disclosures of Other Information.**
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the ' '"Contacting Us"' ' section below.
###``CHOICES AND ACCESS``:red
**Your choices regarding our use and disclosure of your Personal Information.**
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- **Receiving electronic communications from us:** If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by using the unsubscribe link within each email, updating your email preferences, or by contacting us as provided below.
- **Our sharing of your Personal Information with third parties for their direct marketing purposes:** If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with third parties (including our affiliates) for their direct marketing purposes, you may opt-out of this sharing by contacting email@example.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
**How you can access, change or delete your Personal Information.**
If you would like to request to review, correct, update, delete, or object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), Personal Information, you may log into your MyIRE account to make certain changes, or contact us by emailing firstname.lastname@example.org.
In your request, please make clear what Personal Information you would like to have changed. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will respond to your request consistent with applicable law.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- **The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);**
- **Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or**
- **Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).**
###``THIRD PARTY SERVICES``:red
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.
###``USE OF SERVICES BY MINORS``:red
The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
###``JURISDICTION AND CROSS-BORDER TRANSFER``:red
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, trade union membership or criminal background) on or through the Services or otherwise to us.
###``THIRD PARTY PAYMENT SERVICE``:red
218 S Jefferson St., Suite 103
CHICAGO, IL 60661
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.