MOBILE APPLICATION PRIVACY POLICY

Last modified: May 30, 2019

Introduction

IA9 Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

·      The types of information we may collect or that you may provide when you download, install, register with, access, or use the IA9 app (the “App”).

·      Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

·      We collect offline or on any other Company apps or websites, including websites you may access through this App.

·      You provide to or is collected by any third party.

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Minor Under the Age of 18

The App is not designed for minors under 18. Only persons 18 years of age or older may use the App. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete the personal information to the extent required by the Children's Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy. If you believe we might have any information from or about a minor under 18, please contact our customer service department at 1-844-9response or 1-844-4Schedule.

California residents under 16 years of age may have additional rights regarding the collection of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App:

·      Directly from you when you provide it to us.

·      Automatically when you use the App.

Information You Provide to Us 

When you download, register with, or use this App, we may ask you provide information:

·      The information you provide directly to us may concern you or others and may include, but is not limited to: (a) name; (b) zip code; (c) email address; (d) home or business telephone number; (e) home, business or mailing address; (f) demographic information (e.g., gender, age, political preference, education, race or ethnic origin, and other information relevant to user surveys and/or offers); (g) date of birth; (h) insurance information; (i) photographs; (j) information about your project, request or need; (k) video or audio files; (l) in certain circumstances, payment and/or identity verification information; and/or (m) any other content you include in communications with other users through the App or communications with us. It may also include information specific to services you are requesting or offering through the App, such as a business name, service description, qualifications and credentials. You are not required to provide us with such information, but certain features of the App may not be accessible or available, absent the provision of the requested information. (“personal information”).

This information includes:

·      Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our service, and requesting further services. We may also ask you for information if/when you enter a contest or promotion sponsored by us, and when you report a problem with the App.

·      Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

·      Your responses to surveys that we might ask you to complete for research purposes.

·      Your search queries on the App.

You may also provide information for publication or display (“Posted”) on public areas of the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking  

When you download, access, and use the App, it may use technology to automatically collect:

·      Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including location data, logs, and other communication data and the resources that you access and use on or through the App.

·      Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

·      Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

·      Location Information. This App collects real-time information about the location of your device. This data is used to provide the user with an improved experience.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). If you do not want us to collect this information do not download the App or delete it from your device.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

·      Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.

·      Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

·      Professional members of IA9 Inc.

·      Advertisers, ad networks, and ad servers.

·      Analytics companies.

·      Your mobile device manufacturer.

·      Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

·      Provide you with the App and its contents, and any other information, products or services that you request from us.

·      To enable you to use the services available through the App, including registering you for our services and verifying your identity and authority to use our services.

·      Fulfill any other purpose for which you provide it.

·      Give you notices about your account/subscription, including expiration and renewal notices.

·      Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

·      Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

·      Estimate our audience size and usage patterns.

·      Store information about your preferences, allowing us to customize our App according to your individual interests.

·      Speed up your searches.

·      Recognize you when you use the App.

·      For customer support and to respond to your inquiries.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please do not download the App or delete it from your device.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may display information related to your business, including your name or your business’s name, publicly on your profile, except to the extent we tell you we will not display such information. If the information you provide us upon signing up for an account differs from the information you provide us as part of the verification data we collect, we have sole discretion in determining which information will be displayed publicly on your profile.

We may combine information that we collect from you through the App with information that we obtain from affiliated and nonaffiliated third parties, and information derived from any other products or services we provide.

We may aggregate and/or de-identify information collected through the App. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

We may, either directly or through third parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the App or as otherwise described in this Policy for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, we may scan and analyze messages to prevent fraud or improper actions. We may also scan, review or analyze messages for research and product development purposes, as well as to debug, improve and expand product offerings. By using the App or engaging in off-App communications tracked by the Company, you consent that the Company, in its sole discretion, may, either directly or through third parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

·      To our subsidiaries and affiliates.

·      To contractors, service providers, and other third parties we use to support our business.

·      To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of IA9 Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by IA9 Inc. about our App users is among the assets transferred.

·      To fulfill the purpose for which you provide it.

·      For any other purpose disclosed by us when you provide the information.

·      With your consent.

·      To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·      To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.

·      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of IA9 Inc., our customers or others.

We invite you to post content on or through our App, including, but not limited to, your comments, pictures, service member profile, and any other information. However, please be careful and responsible whenever you are online. If you choose to post User Contributions on or through the App, such as through Member-to-Member messaging or through our review boards, forums, blogs, or other postings, that information: (a) may be or may become publicly available; (b) may be collected and used by third parties with or without our knowledge; and (c) may be used in a manner that may violate this Policy, the law, or your personal privacy.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

·      Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. . If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

·      Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly.

·      [Promotion by the Company. If you do not want us to use your [email address/[CONTACT INFORMATION]] to promote our own or third parties’ products or services, you can opt-out by [OPT-OUT METHOD]. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE].]

·      [Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by [OPT-OUT METHOD]). You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE].]

·      [Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by [OPT-OUT METHOD]. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE].]

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@ia9inc.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page and notify you by email and/or text message to the email address and/or phone number specified in your account.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact our customer service department at 1-844-9response or 1-844-4Schedule.