Privacy Policy

Effective January 1, 2021

 

This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

 

We have divided up the document into sections that are specifically applicable to Basics (Section 1), Group Members (Section 2), Visitors (Section 3) and General Information (Section 4).

  1. The Basics

    1. About Us

      IronUp is a rented fleet management platform (the “Services”) operated by Subscribe Labs Inc, a company headquartered in the State of Georgia in the United States (“we,” “us,” “our,” and “IronUp”).

 

The Services enable our Members to better manage their rented equipment assets. Find out more about our Services here.

  1. Key Terms

    In this privacy policy, these terms have the following meanings:

 

Member” means any person or entity that is registered with us to use the Services.

 

Personal Information” means any information that identifies or can be used to identify a Member or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

 

Service” has the meaning given to it in our Standard Terms of Use.

 

IronUp Site(s)” has the meaning given to it in our Standard Terms of Use.

 

Visitor” means, depending on the context, any person who visits any of our IronUp Sites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.

 

you” and “your” means, depending on the context, either a Member or a Visitor.

  1. Privacy for Members

    This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitors section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Members and potential Members.

    1. Information We Collect

      The Personal Information that we collect depends on the context of your interactions with IronUp, your IronUp account settings, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

      1. Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, or communicate with us in any other way.

        This information may include:

        1. Business contact information (such as your name, job title, organization, location, phone number, email address, and country);

        2. Marketing information (such as your contact preferences);

        3. Account log-in credentials (such as your email address or username and password when you sign up for an account with us);

        4. Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and

        5. Payment information (including your credit card numbers and associated identifiers and billing address).

      2. Information we collect automatically: When you use the Service, we may automatically collect or receive certain information about your device and usage of the Service (collectively “Service Usage Data”). In some (but not all) countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information under applicable data protection laws. We use cookies and other tracking technologies to collect some of this information. For further information, please review the section below and our Cookie Statement available here.

        Service Usage Data may include:

 

  1. Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection.

 

  1. Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.

 

  1. Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Service. This information allows us to improve the content and operation of the Service, and facilitate research and analysis of the Service.

  1. Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.

Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

  1. Use of Personal Information

    We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

    1. To bill and collect money owed to us by you to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.

    2. To send you system alert messages in reliance on our legitimate interests in administering the Service and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.

 

  1. To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service.

  2. To enforce compliance with our Standard Terms of Use and applicable law, and to protect the rights and safety of our Members in reliance on our legitimate interest to protect against misuse or abuse of our Service and to pursue remedies available. This may include developing tools and algorithms that help us prevent violations.

  3. To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

  4. To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

  5. To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws.

  6. To provide insights and analytics to you. This includes custom insights reports that are a predetermined part of an Instance Update, custom insights requested by individual Members. For more information about our use of cookies and other tracking technologies for this purpose, and instructions about how to opt out of having data collected through the use of cookies, please see our Cookie Statement here.

  7. To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features.

  8. For our product development. Our product development efforts may use data from IronUp accounts to provide and improve the Services. If you prefer not to share this data, you can contact us to opt out of product development projects.

  1. Cookies and Tracking Technologies

    We may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we may use your IP address to auto-detect your country and the resulting currency, automating the question of “what is your currency?” and removing that from your data delivery workload. Additionally, many standard product development intelligence tools and web user behavior tools use cookies and similar tracking technologies to function.

    Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement here.

  2. Your Data Protection Rights

    Depending on the country in which you reside, you may have the following data protection rights:

    1. To access; correct; update; port; delete; restrict; or object to our processing of your Personal Information.

    2. You can manage your preferences by contacting us (see Section 4. General Information, C. Your Choices and Opt-Outs below). IronUp takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.

    3. The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and UK are available here and Switzerland are available here.

    4. Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.

  1. Privacy for Visitors

    This section applies to Personal Information that we collect and process when you visit the IronUp Sites, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our office. In this section “you” and “your” refers to Visitors.

    1. Information We Collect

      1. Information you provide to us on the IronUp Sites or otherwise: Our IronUp Sites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with IronUp, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, if you visit our offices (where you will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.

        The Personal Information we collect may include:

 

  1. Business contact information (such as your name, phone number, email address and country);
  2. Professional information (such as your job title, institution or company);
  3. Nature of your communication;
  4. Marketing information (such as your contact preferences); and
  5. Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.

  1. Information we collect automatically through the IronUp Sites: When you visit our IronUp Sites or interact with our emails, we use cookies and similar technologies such as pixels or web beacons, alone or in conjunction with cookies, to collect certain information automatically from your browser or device. In some countries, including countries in the EEA, this information may be considered Personal Information under applicable data protection laws. Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement available here.

  1. Use of Personal Information

    We may use the information we collect through our IronUp Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:

    1. To provide, operate, optimize, and maintain the IronUp Sites.
    2. To send you marketing information, product recommendations and non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
    3. For recruitment purposes if you have applied for a role with IronUp.
    4. To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
    5. To manage the IronUp Sites and system administration and security.
    6. To manage event registrations and attendance, including sending related communications to you.
    7. To register visitors to our office for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
    8. To improve the navigation and content of the IronUp Sites.
    9. To identify any server problems or other IT or network issues.
    10. To process transactions and to set up online accounts.
    11. To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
    12. To help us provide, improve and personalize our marketing activities.
    13. To facilitate the security and continued proper functioning of the IronUp Sites.
    14. To carry out research and development to improve our IronUp Sites, products and services.
    15. To conduct marketing research, advertise to you, provide personalized information about us on and off our IronUp Sites, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
    16. To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
    17. To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our IronUp Sites and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.



  1. Public Information and Third Party Websites

    1. Blog. We have public blogs on IronUp Sites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.
    2. Social media platforms and widgets. We maintain presences on social media platforms, including LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
    3. Links to third-party websites. The IronUp Sites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
    4. Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on the IronUp Sites or through social media (collectively, “Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Service. We may share this information with our affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.

  2. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how you can control them, please see our Cookie Statement here.

  1. Other Data Protection Rights

    1. Depending on the country in which you reside, you may have the following data protection rights:

      1. To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by contacting us.
      2. You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
      3. Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences (see Section 4. General Information, C. Your Choices and Opt-Outs below).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

  1. General Information

    1. How We Share Your Information

      We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, “you” and “your” refer to Members and Visitors unless otherwise indicated):

      1. Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

      2. A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on an IronUp Site.

      3. Any other person with your consent.

    2. Legal Basis for Processing Personal Information (EEA Persons Only)

If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

 

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above titled “Use of Personal Information”, but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Service and our IronUp Sites; and supporting our marketing activities.

 

If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

 

Where required by law, we will collect Personal Information only where we have your consent to do so.

 

If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us.

  1. Your Choices and Opt-Outs

Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.

 

Also, all opt-out requests can be made by contacting us. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your IronUp account.

 

  1. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page available here. If you have any questions about the security of your Personal Information, you may contact us.

 

IronUp accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s IronUp account is private, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.

  1. International Transfers

    1. We operate in the United States

      Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.

    2. Members, Contacts and Visitors located in Australia

      If you are a Member or Visitor who accesses our Service in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 (“Australian Privacy Act”). Here are the specific points you should be aware of:

 

  1. Sensitive personal information is not permitted on IronUp’s platform and Members are prohibited from importing or incorporating any sensitive Personal Information into their IronUp accounts or uploading any sensitive Personal Information to IronUp’s servers.
  2. Please note that if you do not provide us with your Personal Information or if you withdraw your consent for us to collect, use and disclose your Personal Information, we may be unable to provide the Service to you.
  3. Where we collect Personal Information of our Visitors, the Personal Information we ask you to provide will be information that is reasonably necessary for, or directly related to, one or more of our functions or activities. 
  4. Where we say we assume an obligation about Personal Information, we will also require our contractors and subcontractors to undertake a similar obligation.
  5. We will not use or disclose Personal Information for the purpose of our direct marketing to you unless:
    1. you have consented to receive direct marketing;
    2. you would reasonably expect us to use your personal details for marketing; or
    3. we believe you may be interested in the material but it is impractical for us to obtain your consent.

You may opt out of any marketing materials we send to you through an unsubscribe mechanism. If you have requested not to receive further direct marketing messages, we may continue to provide you with messages that are not regarded as “direct marketing” under the Australian Privacy Act, including changes to our terms, system alerts, and other information related to your account as permitted under the Australian Privacy Act and the Spam Act 2003 (Cth).

 

Our servers are located in the United States. In addition, we or our subcontractors may use cloud technology to store or process Personal Information, which may result in storage of data outside Australia. It is not practicable for us to specify in advance which country will have jurisdiction over this type of offshore activity. All of our subcontractors, however, are required to comply with the Australian Privacy Act in relation to the transfer or storage of Personal Information overseas.

We may also share your Personal Information outside of Australia to our business operations in other countries. It is not practicable for us to specify in advance each country where your Personal Information may be disclosed.

You may access the Personal Information we hold about you. If you wish to access your Personal Information, please contact us. We will respond to all requests for access within a reasonable time.

If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information upon your request. If you find that the information we have is not up to date or is inaccurate or incomplete, please contact us so we can update our records. We will respond to all requests for correction within a reasonable time.

 

If you are unsatisfied with our response to a privacy matter, you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.


  1. Retention of Data

    We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:

    1. Whether we have a legal or contractual need to retain the data.
    2. Whether the data is necessary to provide our Services.
    3. Whether our Members have the ability to access and delete the data within their IronUp accounts.
    4. Whether our Members would reasonably expect that we would retain the data until they remove it or until their IronUp accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

  1. California Privacy

    The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.

 

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.

  1. Do Not Track

    Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser. IronUp adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

  2. Changes to this Policy

    We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the IronUp Sites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the IronUp Site.

  3. Questions and Concerns

    If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact us to send us a message.