PRIVACY POLICY
At ILRAA, we take your privacy serious. The purpose of this Privacy Policy (this “Policy”) is to inform you about the personal data that we collect, how we process it, and for what purposes. If you have any questions about this Policy, please contact us as set forth in the final section of this Policy under the heading “CONTACT US”.
WHO WE ARE
“ILRAA”, “we”, “us”, and “our” refer to ILRAA, LLC., a Wisconsin business providing data-analytics tools and services, located in Franklin, WI 53132. (Within the meaning of the European Union’s General Data Protection Regulation, ILRAA is the “controller” of the personal data that it collects.
DEFINITIONS
The term “ILRAA products and services” refers to our data-analytics tools and services as well as to our websites, social-media sites, and event-registration systems.
The term “personal data” means any information relating to an identified or identifiable natural person.
The term “identifiable natural person” means a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The term “controller” means the person or entity which determines the purposes and means of the processing of personal data.
HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you that you supply in the following ways:
- by direct interaction when we communicate with you by telephone, email, mail, and other means of communication
- by forms that you fill out when you inquire about, order, use, or provide feedback about our products and services
- by forms that you fill out when you register for our webinars, events, newsletters, or notices
- by work orders or purchase orders that you submit for our products or services
We also collect data about you automatically in log files stored on our servers that record your activity when you inquire about, order, use, or provide feedback about our products and services.
ILRAA products and services are not intended for children. We do not knowingly collect data from or about children.
WHAT PERSONAL DATA WE COLLECT
We may solicit the following data from you:
- first name
- last name
- job title
- company name
- email address
- telephone number
- mailing address
- credit-card information
- feedback about our products and services
- messaging preferences
If you decline to provide personal data that we need to perform a contract with you, we may not be able to perform the contract. If data that you have supplied to us changes during our relationship, please let us know so we can update our records.
We may collect the following data about you automatically:
- links you click to get to our website
- pages you view on our website
- links you click to leave our website
- device IP address
- browser type and version
- browser plug-in types and versions
- device time-zone
- device operating system
- device hardware
- device configuration
- metrics about your usage of our products and services
- details about your purchases of our products and services
- details about your payments for our products and services
PURPOSES FOR WHICH WE COLLECT PERSONAL DATA
We may use your personal data as follows:
- to supply information that you have requested
- to form contracts with you (such as service agreements, statements of work, or purchase orders)
- to perform contracts that we have entered into with you
- to track your use of our products and services
- to manage our relationship with you, including charges, fees, and payments
- to collect payments from you
- to notify you about changes to our terms of service or privacy policy
- to solicit feedback from you regarding our products and services
- to troubleshoot and support our products and services
- to perform market-trend analysis to improve our products and services
- to form an opinion about what ILRAA products and services may be of interest to you
- to send you marketing messages about ILRAA and about ILRAA products or services that we believe may be of interest to you
We may also anonymize your personal data and combine it with the anonymized personal data of others to generate broader statistics and reports regarding our products and services.
You have the right to withdraw your consent to our use of your personal data any time. You may do so by contacting us as set forth below. If you withdraw consent, we will stop using your personal data to the extent that your consent is the sole legal basis for our use. However, if we have other legal bases for using your personal data (for example, to communicate with you about accrued charges, fees, and payments), then we may continue to use your personal data for any purpose justified by other legal bases. More specifically:
- You may opt out or change your messaging preferences via a link in the footer of any marketing email message. You may also opt out or change your messaging preferences when you sign up for our email lists or by emailing us at contact@ilraa.com. You many report any unsolicited ILRAA marketing messages by emailing us at contact@ilraa.com.
- Certain transactional messages (for example, project notices or billing statements) may be necessary to perform contracts that we have entered into with you. You may unsubscribe from some of these transactional messages by canceling your ILRAA service agreement. To request cancellation of your service agreement, please email us at contact@ilraa.com (Cancellation is subject to the terms and conditions of the applicable service agreement.)
DISCLOSURES OF PERSONAL DATA
We do not process or disclose personal data other than as set forth in this Policy. In particular, we never sell, license, or otherwise disclose your contact information to third parties for their promotional use. However, we may disclose your personal data under the following circumstances:
- To comply with court orders or other legal requirements.
- If we sell our business or any portion of it, we may disclose your personal data to the purchaser. We may also disclose your personal data to a prospective purchaser during a due-diligence period preceding sale, subject to a nondisclosure agreement that protects your personal data from misuse. Likewise, if we acquire another business, we may disclose your personal data to the acquired business. In the event of such sale or acquisition, the new owners or affiliates may use your personal data in the same ways as described in this Policy.
- From time to time, we may engage service providers to assist in managing or operating our business (for example, to provide customer service). We may disclose your personal data to such service providers as needed to accomplish our purposes, as described above. We require our service providers to maintain the confidentiality of your personal data and to treat it in accordance with the law. We do not permit our service providers to use your personal data for their own purposes or to process your personal data other than in accordance with our instructions.
- From time to time, a ILRAA business partner or supplier may give us information about you so that we can contact you to provide information you have requested. We comply with all terms and conditions under which such information is disclosed to us. We may disclose certain information concerning the status of such information requests to those partners or suppliers who introduced you to us.
OUR LEGAL BASES FOR PROCESSING PERSONAL DATA
Our legal bases for processing your personal data as set forth above include:
- to perform a contract with you
- to protect our legitimate interests, namely, to operate our business, to keep our records up-to-date, to administer our IT systems, to maintain security, to prevent fraud, and to collect amounts owed to us
- to comply with legal requirements
- your consent
For more information about our legal bases for processing your personal data, please contact us as set forth below.
INTERNATIONAL DATA TRANSFERS
We and some of our service providers are based outside of the European Union (“EU”). If you are located within the EU, our processing may involve a transfer of your personal data outside of the EU. If you are a natural person located in the EU, we will ensure a degree of protection for your personal data similar to that afforded in the EU by at least one of the following means:
- a model contract approved by the European Commission that requires the same protections for your personal data as under EU law
- the use of service providers that are certified under the EU-US Privacy Shield
If you are a natural person located in the EU and want further information on the specific means of protection used by us when transferring your personal data outside of the EU, please contact us as set forth below.
RETENTION
We will retain your personal data only for so long as needed to fulfil the purposes for which we collected it and to satisfy any legal, accounting, or reporting requirements. You may request details about our retention periods for each element of your personal data by contacting us as set forth below. If you are a natural person located in EU, or if applicable law otherwise so requires, you may request that we erase your personal data by contacting us as set forth below.
SECURITY
We maintain appropriate security measures designed to protect your personal data from loss as well as from being accessed, altered, used, or disclosed without authorization. When we collect sensitive payment information such as credit-card numbers, we protect the transmission by industry-standard forms of encryption. We limit access to your personal data to those of our employees, agents, representatives, and service providers who have a need to know in order to accomplish the purposes for which we use your personal data. We require that such persons process your personal data solely in accordance with our instructions and not for other purposes.
We maintain appropriate procedures to deal with any actual or suspected data breach. We will notify you and any regulators having jurisdiction over such a breach whenever we are required by law to do so.
ILRAA products and services may contain links or references to resources controlled by third parties with whom we do not have a relationship. We do not control such third parties and are not responsible for them. When you access resources controlled by third parties, you should exercise caution and familiarize yourself with the controller’s data-privacy practices.
YOUR LEGAL RIGHTS
If you are located in the EU or in another jurisdiction that confers similar protections, you may have the following rights in relation to your personal data:
- to request access
- to request correction of any incomplete or inaccurate personal data
- to request erasure when there is no legal basis for our processing or retention or when local law so requires
- to object to processing when you feel it adversely impacts you
- to request restriction of processing to verify the accuracy of your personal data
- to request restriction of processing pending an objection or other legal proceeding
- to request transfer to a third party
- to withdraw your consent to our retention or processing
If you wish to exercise any of the rights described above, please contact us as set forth below. We may need specific information from you to help us confirm your identity. (This is a security measure to ensure that your personal data is not disclosed to unauthorized persons.)
In general, you will not have to pay any fee to access your personal data or to exercise any other right accorded to you by law. However, if your request is clearly unfounded, repetitive, or excessive, we may charge you a reasonable fee or we may refuse to comply with your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is complex or if you make numerous requests. In such case, we will notify you and keep you updated.
MODIFICATIONS
We reserve the right to modify this Policy at any time. If we make material changes to this Policy, we will notify you here, by email, or by posting a notice on our website home page.
CONTACT US
If you have questions about this Policy or your personal data, please contact our privacy coordinator by email at contact@ilraa.com.
If you reside in the European Union, you have the right to file a complaint regarding our handling of your personal data with the Information Commissioner’s Office in the country where you reside. However, we would appreciate the opportunity to resolve your concerns directly, so please contact us first.