PRIVACY POLICY

Last Updated: March 18, 2022 with Effective Date March 18, 2022

IRONTECH LIMITED ("we", "us" or "our") respects your privacy. This Privacy Policy ("Privacy Policy") clarifies our privacy practices and describes how we collect, use, disclose and otherwise process different types of information when you access and/or use the Website available at https://irontech.mobi/ (hereinafter, the “Website”), and explains the rights and choices available to you with respect to your personal information.

When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

Our Privacy Policy applies to all users, and others who access the Website ("Users").

PLEASE READ CAREFULLY THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, AND YOUR CHOICES REGARDING YOUR PERSONAL DATA. WHEN YOU USE THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.

For the purposes of the EU General Data Protection Policy (GDPR), we are the data controller, unless otherwise stated.

I. INFORMATION WE PROCESS

Depending on circumstances mentioned below, the following general categories of personal information may be collected and otherwise processed:

PLEASE, NOTE THAT:

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

II. HOW IS YOUR PERSONAL DATA COLLECTED

We obtain the categories of personal information listed above from the following categories of sources:

2.1. Directly from you:

We may collect, store and otherwise process some information about you when you voluntarily provide such information to us using the form available within the “Contact us” section on the Website (hereinafter, “Contact us” form).

In particular, if you decide to make a request via the “Contact us” form, the following categories of information are voluntarily provided by you: your name, email address, the text of your message and/or any files that you optionally choose to attach to your request. We use the services of Advanced Hosters B.V. in order to collect, store and process the information that you provide us via the “Contact us” form. We use the information submitted by you via the “Contact us” form solely for the purpose of considering and responding to your requests (if necessary).

2.2. Indirectly from you (Information collected by automated means):

When you access and/or use the Website, some information about your device and your user behavior may be processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in aggregated form. We process this information on the ground of our legitimate interest in improving our Website and giving our users the best experience. If we do not access such data we may not be able to provide you with all features of the Website.

We use third-party automatic data processing technologies to analyze certain information sent by your device via our Website (analytics or advertising tools). Some of them may launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically when you first time access the Website.

The following are the types of information we may collect indirectly from you:

• Device Information. When you use a device (computer, laptop / tablet / phone) to access our Website, some details about your device are reported, including “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your device, which uniquely identify your device (but not your personality). Device identifier enables generalized reporting or personalized content and ads by the third parties.

The following device information can be processed:

• Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, device memory usage.

• Information about the internet connection: mobile carrier, network provider, network type, Internet Protocol (“IP”) address, timestamp and duration of sessions, speed, browser and version, browser language.

• Location-related information: IP-address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, time zone.

• Device identifiers: advertising identifiers, Identity For Advertisers for iOS devices/ Advertising ID or Android ID for Android devices.

• Cookies and similar technologies. When you access and/or use the Website, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the Website. The text file is then sent back to the server each time you use the Website. This enables us to operate the Website more effectively. For example, we will know how many users access specific areas, content or features within our Website and which links they clicked on. We use this aggregated information to understand and optimize how our Website is used, improve our marketing efforts, and provide content and features that are of interest to you. Third party analytics tools use cookies or similar technologies for the purpose of analyzing the Website traffic.

• Log file information. Log file information is automatically reported each time you make a request to access the Website. When you use our Website, analytics tools automatically record certain log file information, including time and date when you start and stop using the Website, and how you interact with the Website.

Information provided automatically to analytics or advertising tools does not generally come to our control, therefore, we cannot be responsible for processing such information. Please mind that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility.

III. THE PURPOSES OF PROCESSING YOUR DATA

Our mission is to constantly improve our Website and provide you with better user experiences. As part of this mission, we use your information for the following purposes:

1. To improve, test and monitor the effectiveness of our Website. We use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our Website.

2. To communicate with you. We may use information that you voluntarily provide to us via the “Contact us” form available on the Website for the purposes of processing and responding (if necessary) to your requests, receiving your feedback, comments or suggestions about the Website or on other matters.

3. To prevent fraud and spam, to enforce the law. We really want our Website to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks, enforce our Terms of Use and applicable law.

If any new purpose for processing your data arises, we will let you know when we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

IV. INFORMATION SHARING AND DISCLOSURE

We will not rent or sell your personal data to third parties, but we may share your information obtained via tools like cookies, log files, and device identifiers with third-party organizations that provide automatic data processing technologies for the Website. We do not control or influence these third parties’ tracking technologies or how they may be used.

Please note that while we partner solely with third parties that gave us assurance of application of necessary technical and organizational measures to protect your data, we cannot guarantee the security of any information transmitted from the Website directly to such third parties. We are not responsible for any accidental loss or unauthorized access to your data through a fault of third parties.

We may engage the following categories of recipients for a variety of business purposes and only in the ways and contexts that are described in this Privacy Policy:

Third-party service providers.

We may engage the following third-party service providers in order to provide us with necessary infrastructure for delivery and improvement of our Website:

Please note that all third-party service providers that are engaged in processing user data are service providers that use such information on the basis of agreement and pursuant to business purpose.

As it is indicated above we use such services as Google Analytics that track and report the Website traffic. This service uses different types of cookies to analyze user activity. If you want to learn more about the categories of data collected and processed by Google Analytics please consult the corresponding website of Google Analytics as well as its privacy policiy and other documents concerning data protection. Note that we are not responsible for any usage of your data by the abovementioned third-party service providers in violation of our instructions.

If you don’t want Google Analytics to use cookies you can block data collection following the instructions provided in Section XI of the present Privacy policy.

Our Website may contain links to third party sites/services. You also may visit the Website following a link from a third party site. We are not responsible for the privacy practices of these third-party sites or services linked, including for the information or content contained within them (unless we are the providers of those sites and/or services).

We may disclose your personal information if needed for objective reasons, due to public interest or in other unforeseen circumstances:

- as required by law;

- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;

- in some cases, we may share your information with our affiliates, subsidiaries, contractors, business partners or other third parties who perform services on our behalf.

V. INTERNATIONAL DATA TRANSFERS

We work in the cross-border area and provide our Website to Users around the world.

We and third-party organizations that provide automatic data processing technologies for the Website or our third-party partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that may not have the same data protection laws as in your home jurisdiction. We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information.

By using the Website, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.

VI. HOW DO WE STORE YOUR DATA

For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data – if possible – before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check.

In particular, we recourse to the services of Advanced Hosters B.V. that have adopted technical and organizational measures to protect your personal data against unauthorized/unlawful processing and accidental loss, destruction or other damage.

VII. HOW LONG WE USE YOUR PERSONAL DATA

We will generally keep your personal information for as long as we need it for a lawful purpose: to perform the contract between you and us (enforce our Terms of Use) and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase it.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) with a purpose of compliance with certain legal obligations (such as taxation, accounting, audit), maintenance of safety and data backup settings or prevention of fraud or other malicious acts.

VIII. SECURITY

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our Website, you can contact us at privacy@irontech.mobi.

IX. CHILDREN’S PRIVACY

Our Website is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under the age of 18 may provide any personal information to the Website. If you are under 18, do not use or provide any information on this Website or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under the age of 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

X. YOUR RIGHTS AND CHOICES

If you are a resident of the European Economic Area, your rights to access, edit and delete your information can be found in clause 10.1. of this section.

If you are a California resident, your rights to access, edit and delete can be found in clause 10.2. of this section.

If you are not a resident of the EEA or California, depending on your location, you may be able make requests to access, correct and/or delete certain personal information that you provide to us. For your protection, we may require proof and verification of identity and jurisdiction of residency before we can answer the above requests. If you wish to make such a request, you may contact us at privacy@irontech.mobi. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with some of the features and functionality of the Website. Once we have verified you, we will honor such requests at our discretion and in accordance with applicable law.

10.1. Information for Individuals in the European Economic Area (EEA)

If you reside in the European Economic Area ("EEA"), then applicable privacy laws (in particular GDPR) give you certain rights regarding your personal data.

According to GDPR you have the following options in relation to your personal data that was collected:

• Data Access and Portability. You can request copies of your personal information.

• Change or Correct Data. You have the right to ask us to correct, change, update or rectify your data.

• Data Retention and Deletion. Specific retention times can vary based on context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.

• Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which your personal information is used.

To exercise any of the rights described above, you can contact us at privacy @irontech.mobi. Please bear in mind that we ensure the above-mentioned rights only with respect to the information that we physically access and store.

When your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the recipients listed in the Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.

If you don’t want us to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described below >>

10.2. Information for Residents of California: Your California Privacy Rights

The California Consumer Privacy Act of 2018 (CCPA) provides those who reside in the State of California with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

The CCPA provides consumers (California residents) with the following rights regarding their personal information:

• Right to Access. You have the right to request that we disclose, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

• The categories of personal information we have collected about you.

• The categories of sources for the personal information we have collected about you.

• The business or commercial purpose for our collecting or selling your personal information.

• The categories of third parties to whom we share your personal information.

• The specific pieces of personal information we have collected about you.

• Whether we have sold or disclosed your Personal Information for a business purpose, and if so, two separate lists disclosing:

• sales, identifying the categories of personal information that we have sold about you in the prior 12 months as well as the categories of third parties to whom we sold that personal information, by category or categories of personal information for each category of third parties to whom your personal information was sold; and

• disclosures for a business purpose, identifying the categories personal information that we have disclosed about you in the prior 12 months as well as the categories of third parties to whom we disclosed your personal information, by category or categories of personal information for each category of third parties to whom your personal information was disclosed.

Once we receive and confirm your verifiable consumer request, data outlined in this section above (Right to Access) will be disclosed to you.

• Deletion rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions outlined in the CCPA. 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.

• Right to Opt-Out (“Do Not Sell”). You have the right to tell us not to disclose or transfer your personal information to a third party in exchange for something of value. The CCPA refers to this as your right to say “Do Not Sell” my personal information.

We do not sell personal information, as noted herein. If we decide to sell personal information in the future, we will post an appropriate notice and opt-out method, and we will not sell any personal information previously collected.

However, if you don’t want us to process your personal information any more, please contact us at privacy @ irontech.mobi. Note that if you decide to opt out of data collection and processing this can affect some Website functions and you may not be able to use all features of the Website to the fullest extent possible.

If you don’t want us to share device identifiers and geolocation data with third-party service providers, please check your device settings as described below >>

• Non-discrimination. You are entitled to exercise the rights described in this section free from discrimination. This means that we will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

Unless permitted by the CCPA, we will not:

• 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 or quality of goods or services.

Now, when you aware of your California privacy rights, please note, the following:

• All the categories of personal information listed in Section I of this Privacy Policy "I. INFORMATION WE PROCESS" has been collected by us from Users within the last twelve (12) months.

• In the preceding twelve (12) months, we have disclosed your personal information included in each of categories of personal information A, B, C and D from listed in Section I of this Privacy Policy "I. INFORMATION WE PROCESS" for each business purpose described above depending on your use of the Website described herein.

• We are not in the business of selling information about you to anybody, which indicates that no personal information of yours has been sold ever.

How to Exercise Your California Privacy Rights

To request access to your personal information or request deletion, please submit a verifiable consumer request to us by the following e-mail: privacy@irontech.mobi

Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. 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 also make a verifiable consumer request on behalf of your minor child.

Please, include the wording “Consumer rights to maintain confidentiality in the state of California” in the text of your request.

Any request you submit to us is subject to an identification and residency verification process, so when submitting a verifiable request, you should be ready to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state, and zip code and email address. We may use this information to surface a series of security questions to you to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not be able to respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; or (ii) confirm the personal information relates to you. We may ask you for additional information or documents to verify your identity. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scum request.

We ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. We will keep it for the adequate term reasonably needed for the purpose described above and delete after the purpose is fulfilled.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Please note that we are only required to respond to two requests per customer each year.

XI. HOW TO OPT OUT

You may prevent and/or manage the collection and processing of data related to your use of the Website following the instructions provided below.

Google Analytics. If you want to opt-out of being tracked by Google Analytics you can install and enable Google Analytics Opt-out Browser Add-on. Additionally, you can manage cookies and/or delete cookies already set by Google Analytics through your browser settings. Further information on Google Analytics’ data practices and relevant instructions can be found at https://support.google.com/analytics/answer/6004245 (see section ‘Information for Visitors of Sites and Apps Using Google Analytics’).

Bear in mind that if you choose to disable all cookies, this can affect the Website functions, some of the features that make the Website more efficient may not function.

XII. CHANGES TO THE PRIVACY POLICY

In case we change our Policy, we will post the changes on this page. Please check our Website regularly for any changes.

XIII. HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us by sending your message at privacy@irontech.mobi

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