iotum has a policy of protecting customer privacy. We believe that you have the right to know what information we collect from you as well as how that information is used, disclosed and protected. We have created this policy statement (the “Privacy Policy” or the “Policy”) to explain our privacy practices and policies. When you use any iotum product or service, you should understand when and how personal information is collected, used, disclosed, and protected.

Iotum Inc. and its subsidiaries (collectively the “Company”) are committed to protecting your privacy and providing you with a positive experience on our websites and while using our products and services (the “Solutions”).  Note: “iotum”, “We”, “Us” and “Our” means the www.iotum.com website (including subdomains and extensions thereof) (the “Websites”) and the Company.

This Policy applies to the Websites and Solutions that link to or reference this Privacy Statement and describes how we handle personal information and the choices available to you regarding collection, use, access, and how to update and correct your personal information. Additional information on our personal information practices may also be provided with other notices provided prior to or at the time of data collection.  Certain Company websites and Solutions may have their own privacy documentation describing how we handle personal information for those websites or Solutions specifically. To the extent a specific notice for a website or Solution differs from this Privacy Statement, the specific notice will take precedent. If there is a difference in translated, non-English versions of this Privacy Statement, the US-English version will take precedent.

What is Personal Information?

“Personal information” is any information that can reasonably be used to identify an individual or that can be directly associated with a specific person or entity, such as name, address, email address, phone number, IP address information, or login information (account number, password).

 Personal information does not include “aggregate” information. Aggregate information is data we collect about a group or category of services or customers from which individual customer identifiers have been removed. In other words, how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data. Aggregate data helps us understand trends and customer needs so that we can better consider new services or tailor existing services to customer desires. An example of aggregate data is our ability to prepare a report that indicates that a certain number of our customers always use our collaboration services at a certain time of day. The report would not contain any personally identifiable information. We may sell aggregated data to, or share aggregate data with, third parties.

Collection & Use of Your Personal Information

Our Websites collect personal information about You so that we can deliver the products or services you request. We may collect data, including personal information, about you as you use our Websites and Solutions and interact with us. This happens automatically when You interact with us, such as when You register or log into the service. We may also buy commercially available marketing and sales information from third parties so we can better serve you.

The types of personal information that we may process depend on the business context and the purposes for which it was collected. We may use Your personal information for the purposes of operating and helping to ensure the security of our business, delivering, improving, and customizing our Websites and Solutions, sending notices, marketing, and other communications, and for other legitimate purposes permitted by applicable law.

Information Collected About You

As both a data controller and a data processor, We collect a variety of personal information about users of Our products or services.  A summary of the personal information that we may collect and process about You is outlined below:

Description of Service:	iotum provides many different group meeting, webcasting, podcasting, online events and webinars, conferencing, and collaboration services, each provided by Iotum Inc. and/or its affiliates.
Subject-matter of Processing:	Iotum processes certain Customer Personal Information on behalf of its Customers in relation to the provision of conferencing and group collaboration. The content of the Customer Personal Information is determined by the products and services used by its Customers; during the provision of such services, Iotum’s platform and network may capture data from Customers’ systems, phones, and/or third party software platforms.
Duration of Processing:	For the duration of the Services to which the Customer uses them or the duration of the subscription for an account to use such Services, whichever is longer.
Nature and Purpose of Processing:	To enable Iotum to provide the Customer with certain Services in relation to conferencing and group collaboration services in accordance with the Terms and Conditions of its services.
Type of Personal Information:	Customer Personal Information relating to Customers and provisioned end users of the Services which is based on data supplied by such Customers or provisioned end-users and/or otherwise collected by or on behalf of the Customer or provisioned end-user as a result of the use of the Services. Iotum also collects information about visitors to its web properties. The collected information may include without limitation, data uploaded or pulled into Iotum, personal contact information, demographic information, location information, profile data, unique IDs, passwords, usage activity, transaction history, and online behaviour and interest data.
Categories of Information Subjects:	iotum Customers (and, if corporate or group in nature, their provisioned users of Services), as well as visitors to Websites.

The specific types of personal and other information that we may collect from you are as follows:

• Information You Give Us: We collect the information you give us when you sign up with the Websites or use our services. For example, you may provide us with an e-mail address when signing up for services. You might not have thought about it this way, but the e-mail address you may use when browsing to our website is an example of information you give us and that we collect and use.
• Automatically Collected Information: We automatically receive certain types of information whenever you interact with us. For example, when you visit the Websites, our systems automatically collect your IP address and the type and version of browser you use.
• Information from Other Sources: We may obtain information about you from outside sources and add it to or, subject to your express consent, combine it with our account information. We may use commercially available demographic and marketing information from third parties to help us better serve you or inform you about new products or services that we think will be of interest to you.

You should refer to the rest of this Policy to see how we use, disclose and protect this information, which generally falls into the following categories:

Source of personal data	Types of personal data to be processed	Purpose of processing	Lawful basis	Retention period
Customer (at signup)	User name, email,  selected username, account creation date, password	To provide collaboration applications	* Consent * Required to provide requested collaboration services to customer	Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Customer (at signup)	Source data	Providing efficient collaboration applications and associated marketing and customer support	* Consent * Required to provide requested collaboration services to customer	Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Operating systems (driven by customer activity and use of service)	Call record (CDR) data, log data, call rating data, customer support tickets and data	To provide collaboration applications	* Consent * Required to provide requested collaboration services to customer	Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Operating systems (driven by customer activity and use of service)	Recordings, whiteboards	Application logging	* Consent * Required to provide requested collaboration services to customer	Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Operating systems (driven by customer activity and use of service)	Transcriptions, intelligent call summaries	To provide the associated additional functions and features related to the collaboration application(s)	* Consent * Required to provide requested collaboration services to customer	Longer of duration of customer contract period and any longer period required due to specific regulatory requirements
Customer (only if billing information entered and applicable)	Billing Info details, transaction details	Credit card processing	* Consent * Required to provide requested collaboration services to customer	Longer of duration of customer contract period and any longer period required due to specific regulatory requirements

iotum recognizes that parents often sign up for our products and services for family use, which may include for use by children under the age of 18. Any information collected from such usage will appear to be the personal information of the actual subscriber to the service and will be treated as such under this Policy.

When our customer is a business or other entity purchasing services for employees or other authorized users, this Policy will generally govern the personal information associated with individual employees or authorized users. However, whether the business customer has access to the personal information of employees or other authorized users will be governed by the terms of any service agreement. On that basis, employees or other authorized users should check with the business customer regarding its privacy practices, before using the Services.

How and Why Does iotum Use Personal Information?

We collect personal information for a variety of business reasons, such as:

• Order processing, including billing and payment
• Customer relationship management and administration
• Creating and managing user accounts
• Provisioning websites and Solutions and enabling the use of certain features
• Analyzing, personalizing, improving accuracy, and enhancing user experience, communications, and interactions
• Sending communications to you, including for marketing or customer satisfaction purposes

In general, We use personal information to provide the services or complete the transactions you have requested and to anticipate and resolve problems with your services. The details of such processing are summarized in the previous table. 

If you have expressly subscribed to our email newsletter program or any other form of communication from us (for example, by ticking a consent box on our registration pages), we may also use this information to create and inform you of other products or services from iotum or others that may better meet your needs. All information you provide to us is stored on our secure servers and any payment transactions will be encrypted.

If you choose to provide Us with a third party’s personal information (such as name, email, and phone number), you represent that you have the third party’s permission to do so. Examples may include forwarding reference or marketing material to a friend. Third parties may unsubscribe from any future communication following the link provided in the initial message.

In some instances, We may automatically collect data through cookies, weblogs, web beacons, and other similar applications.  Please read the iotum Use of Cookies section below for more information.

Access to and Accuracy of Your Personal Information and Exercising Your Rights

You can check Your account information for accuracy or ask Us to Delete this information.  We need your help to keep your personal information accurate and up to date. We provide several options to access, correct, or delete your personal information.  Through our Websites, You can change or review Your account information. You also have a right to access the information we hold about you. Where applicable, an access request may be subject to a fee to meet Our costs in providing You with the details of the information we hold about You.

If for any reason you want us to delete the personal information that we hold about you in part or in its entirety, please contact us at privacy@iotum.com or support@iotum.com and We will be happy to assist you. You should understand that to be removed from all mailing lists (including service and conference updates), Your PIN may need to be removed from Our operational systems, which may mean You will no longer be able to use our services.  A user can delete their iotum account, which would include associated personal information at any time through their application account.

When the Company is acting as a “data controller”, You can exercise Your rights of access and request corrections or deactivations under applicable data protection laws directly with the Company as described in the specific Solution documentation or by submitting a request through providing a Privacy Request Form to privacy@iotum.com.  When the Company is acting as a “data processor” and You wish to exercise Your rights of access and request corrections or deactivations, the Company will direct you to the data controller under the applicable data protection laws.

If you need additional assistance or help with accessing, correcting, or deleting Your personal information, please feel free to Contact Us directly.  We will respond to Your request within 30 days. If we are unable to honor Your request or need more time, we will provide you with an explanation.

Your Communication Preferences

We give you the option to receive a variety of information related to our business, programs, websites, and Solutions. You can manage your communication preferences at any time through the following methods:

• By following the instructions included in each promotional email from us to unsubscribe from that mailing.
• By updating your iotum account settings.
• By completing and submitting a Privacy Request Form or by contacting us via mail at: Iotum Inc., 1209 N. Orange St, Wilmington DE 19801-1120 Attn: Privacy. Please be sure to include your name, email address, the communication received, method of delivery (e.g., post, email, phone call, text), and any additional information about the material you no longer wish to receive.
• These choices do not apply to service notifications or other required communications that are considered part of the Websites and Solutions, which you may receive periodically unless you cancel or stop use in accordance with its terms and conditions.

By using Our websites, Solutions, or otherwise engaging or providing personal information to Us, You agree that we may communicate with You regarding security, privacy, and administrative issues relating to your use. For example, if we learn of a security system’s breach, We may attempt to notify You by posting a notice on Our websites, sending an email, or otherwise contacting You.

Sharing and Disclosing Your Personal Information

We may share your personal information with third parties for the purposes of operating our business, delivering, analyzing, improving, securing, and customizing our websites and Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.

We may share personal information in the following ways:

• Within the Company (including subsidiaries) for the purposes of data processing, such as marketing, business operations, compliance, security, Website or Solution functionality, or storage;
• With business partners, service vendors, authorized third-party agents, or contractors to provide a requested Website Solution, service, or transaction. Examples include processing of orders and credit card transactions, hosting Websites, assisting with sales-related efforts or post-sales support, and providing customer support;
• To enforce or apply our customer agreements; to initiate, render, bill, and collect for Services;
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;
• In response to a request for information by a competent authority or third party if we believe disclosure is in accordance with or is otherwise required by, any applicable law, regulation, or legal process;
• With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process, to protect our rights or property, to protect users of Services from fraudulent, abusive, or unlawful use of such services, or as otherwise required by applicable law;
• In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you; and/or
• If we otherwise notify You and You consent to the sharing.

Essentially, we may disclose personal information to third parties to enable us to supply our products and services to you (for example, payment providers) or as part of the terms and conditions for a particular service. We may also disclose personal information to third parties to protect the rights and property of the Company or its subscribers (for example, to the police or to relevant fraud authorities, should the circumstances require it). We will not disclose or sell your personal information to any third party for any other purpose without your express consent. This will usually be given by ticking unchecked boxes on our registration pages as to which forms of third-party communication You consent to receive (such as email, telephone, or text message). However, You may also provide written or verbal consent where applicable. You are not obliged to give Your consent to any particular type of communication or at all. It is entirely Your decision.

Internal Use of Personal Information

In general, we use personal information to serve our customers, to enhance and extend our customer relationship, and to enable our customers can take maximum advantage of our products and services. For example, by understanding how you use our Websites from your computer, we are able to customize and personalize your experience. More specifically, we use personal information to provide services or complete transactions you have requested and to anticipate and resolve problems with your services. Subject to you providing your express consent, iotum may also e-mail to inform you about new products or services we think will interest you or that better meet your needs (unless otherwise stated when you complete your registration as a user of our services).

Third-Party Use of Personal Information

Information about our customers is one of our most important business assets, and therefore we strive to protect it and keep it confidential. Save for any permitted disclosures set out in this section, we will not disclose your personal information to any third party without your express consent. Depending on the service, we may obtain your express consent in a number of ways, including:

• In writing;
• Verbally;
• Online by ticking unchecked boxes on our registration pages as to which forms of third party communication you consent to (such as email, telephone, or text message);
• At the time of service initiation when your consent is part of the required terms and conditions to use the service.

You are not obliged to give your consent to any particular type of communication or at all. In certain circumstances, your consent to disclose personal information can also be implied simply by the nature of your requests, such as when you ask us to deliver an e-mail to another person or when Your return address is disclosed as part of the service and your consent to do so implied by your use of the Solution. To determine how personal information may be disclosed as part of a particular Solution, you should review the terms and conditions of use for that Solution.

We may share personal information with third parties (for example, business partners, suppliers, and subcontractors) as necessary to complete a transaction, perform a service on our behalf, or that you have requested or to enhance our ability to serve you better.  If the third party acts solely on our behalf, iotum will require them to follow our privacy practices. The Company may share your personal information with the operator of a supplier of iotum, to the extent necessary to deliver the Services to you, as further detailed below.

Iotum Inc. does not use personal information for any purposes that are materially different from the purpose(s) for which it was originally collected or subsequently authorized by the applicable individual(s); in the event such a situation arises in the future, Iotum Inc. will provide such individuals the opportunity to choose (i.e., opt out) of such a request.

Subcontracting and Subprocessing

Iotum Inc. may provide the following types of information to the following types of third party processors for the following purpose(s) in order to provide the Services to You:

Type of Subcontracted Subprocessor	Types of personal data to be processed	Purpose of Processing and/or Task(s) to be performed	International transfer (if applicable)
User management SaaS Platform	Customer details, source data details	User base management for marketing and promotional campaigns	US Canada
Secure colocation and webhosting facilities providers and/or cloud-hosting providers	All Data, excluding credit card numbers	Hosting of Iotum collaboration applications	May include (depending on Your location and location of participants): US, Canada, Ireland, Japan, India, Singapore, Hong Kong, UK, Australia, European Union
Software development environments and platforms	All Data, excluding credit card numbers and passwords	Application development; application debugging and logging, internal ticketing, communication, and code repository	US
Customer Management SaaS Platform	Personal information, support tickets, support contact CDR data, customer details, service usage, transaction history	Customer support,  managing sales leads, opportunities, and accounts within CRM	US Canada UK
Telecommunications and communication network providers, including dial-in numbers providers	Conference CDR data	Data transport and dial-in number (“DID”) services; Some DIDs within Iotum’s collaboration applications may be provided by communications and network companies located around the globe (in order to provide access to participants in such locales)	US; associated global jurisdiction
Toll-Free Number Providers	Conference CDR data	Toll-free number services; Some Toll-Free numbers within Iotum’s  collaboration applications are provided by communications and network companies located around the globe (in order to provide access to participants in such locales)	US; associated global jurisdiction
Data Analytics SaaS Provider	All Data, excluding credit card numbers	Reporting and data analytics; marketing and trend analysis	US/Canada
Credit Card Processing Provider	Billing Info details, transaction details	Credit card processing; hosted credit card processing services	US

Where applicable, Iotum relies upon the associated contractual clauses with such third-party processors in each case to ensure that any necessary data privacy processing requirements are met. Where applicable this may include the European Commission Standard Contractual Clauses for international transfers described at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en.

International Transfer, Processing and Storage of Personal Information

We may transfer your personal information to any Company subsidiary worldwide, or to third parties and business partners as described above that are located in various countries around the world. By using our Websites and Solutions or providing any personal information to us, where applicable law permits, you acknowledge and accept the transfer, processing, and storage of such information outside of Your country of residence where data protection standards may be different.

Access To and Accuracy of Your Personal Information

All individuals have the right to request access to, and to request the correction, amendment, or deletion of the information the Company holds about them either online via a request to privacy@callbridge.com or the Company’s Privacy Request Form or by mail to: CallBridge, a service of Iotum Inc., 1209 N. Orange St, Wilmington DE 19801-1120 Attn: Privacy.  The Company does not discriminate against individuals who exercise their privacy rights.    

Security of Your Personal Information

We take reasonable and appropriate steps to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. The Company implements physical, technical, and organizational safeguards designed to protect Your personal information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.  Where applicable, We also contractually require that Our suppliers protect such information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. For example, we use accepted tools and techniques to protect against unauthorized access to our systems. Also, we restrict access to personal information about you to those employees who need to know that information to provide products or services to you. You should be aware that iotum has no control over the security of other websites on the Internet you might visit, interact with, or from which you buy products or services.

An important part of protecting the security of personal information is your efforts to protect against unauthorized access to your user name and password and to your computer. Also, be sure to sign off when finished using a shared computer and always log out of any site when viewing personal account information.

Retention and Disposal of Personal Information

We will retain your personal information as needed to fulfill the purposes for which it was collected. This is further detailed in the earlier section titled “Information Collected About You”. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements. 

We will not retain personal information in identifiable form when the purpose(s) for which the personal information was collected have been achieved and, there is no legal or business need to retain such personally identifiable information. Thereafter, the data will either be destroyed, deleted, anonymized, and/or removed from our systems.

Updating this Policy

Callbridge will revise or update this Policy if our practices change, as we change existing or add new services or as we develop better ways to inform you of products we think will be of interest. You should refer back to this page often for the latest information and the effective date of any changes.

iotum Use of “Cookies”

Like many websites and web-based Solutions, iotum uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to us (e.g., Internet Protocol (IP) address).  Cookies are small text files placed on your hard drive by a website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the website, the website knows who you are and can personalize your visit. For example, cookies enable a website function so that you only have to log in once.

In general, we use cookies to personalize the Websites and make recommendations based on selections you have made in the past as well as to improve each Website’ experience; to improve your browsing experience online, and to complete transactions you have requested.  These tools help make your visit to our website and Solutions easier, more efficient and personalized. We also use the information to improve our website and Solutions and provide greater service and value.

Advertisers that serve ads on our Websites may also use their own cookies. Such outside cookies are governed by the privacy policies of the entities placing the ads, and are not subject to this Policy. We may also provide links to other third-party websites and services that are outside Company control and not covered by this Privacy Policy. We encourage you to review the privacy statements posted on the websites you visit.

As technology advances and cookies provide more functionality, we expect to use them in different offerings in different ways. As we do so, this Policy will be updated to provide you with more information.

Children’s Online Privacy Protection

iotum does not knowingly, directly or passively, collect information from children under the age of 18. If we create offers and products that make it appropriate to collect information from children under the age of 18, we will notify you of the change in this Policy. We also will ask a parent to confirm his/her consent in advance of any collection, use or disclosure of that information. You should be aware, however, that web browsers and conferencing services set up for family use may be used by minors without the knowledge of iotum. If that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.

DATA PRIVACY FRAMEWORK AND PRINCIPALS

Iotum Inc. complies with the EU-U.S. Data Privacy Framework (the “EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Iotum Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (the “EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Iotum Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (the “Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/. Iotum Inc. and its US subsidiary Iotum Global Holdings Inc. are adhering to the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles as applicable.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Iotum Inc. commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Iotum at c/o Iotum Inc., attention: Privacy Officer, 1209 N. Orange St, Wilmington DE 19801-1120 and/or privacy@iotum.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Iotum Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you. Where an individual has invoked binding arbitration by delivering notice to us, pursuant to and subject to the conditions set forth in Annex I of Principles, Iotum Inc. will arbitrate claims and follow the terms as set forth in Annex I of the applicable DPF Principles and follow the procedures therein.

The Company is committed to the DPF Principles and to protecting all personal information received from European Union (EU) member countries, the UK, and Switzerland (see above Information Collected About You for examples of the personal information the Company processes when you use our Websites and Solutions and interact with us), in accordance with applicable Principles and to ensure personal information collected from individuals in the EU is accessible to them as part of their individual rights when the Company is the Controller of the personal information.

iotum is responsible for the processing of personal data it receives under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, and subsequently transfers to a third party acting as an agent on its behalf. Iotum complies with the DPF Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Iotum is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Iotum may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

iotum Placement of Banner Ads on other Web Sites

iotum may use third-party advertising companies to place advertisements about our products and services on other websites. These third-party companies may use other technology such as web beacons or tagging, to measure the effectiveness of our ads. To measure advertising effectiveness and offer selective ad content, they may use anonymous information about your visits to our and other websites. But in all cases, they use an anonymous number to identify you, and do NOT use your name, address, phone number, e-mail address, or anything that personally identifies you. The use of such cookies is subject to the third party’s privacy policy, not the policy of iotum.

Your California Privacy Rights

 This section is only applicable to California residents.

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

For business purposes in the last twelve months, the Company may have collected, used, and shared personal information about you as described in this Privacy Policy.  Each category of data that may be used by the Company or shared with third parties is categorically outlined in this Privacy Policy.

California consumers have the right to (1) request access, correction, or deletion of their personal information (2) opt-out of the sale of their personal information; and (3) nor be discriminated against for exercising one of their California privacy rights. 

All individuals have the right to request access to or deletion of the information the Company holds about them either online via the Company’s Privacy Request Form or by mail to: iotum, a service of Iotum Inc., 1209 N. Orange St, Wilmington DE 19801-1120 Attn: Privacy.  In addition, California residents may also submit a request to privacy@iotum.com. The Company does not discriminate against individuals who exercise their privacy rights.

Do Not Sell My Personal Information

The Company does not sell (as “sell” is traditionally defined) your personal information.  That is, we don’t provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money.  However,  under California law, sharing information for advertising purposes may be considered a “sale” of “personal information.” If you’ve visited our digital properties within the past 12 months and you’ve seen ads, under California law personal information about you may have been “sold” to our advertising partners for their own use. California residents have the right to opt-out of the “sale” of personal information, and we’ve made it easy for anyone to stop the information transfers that might be considered such a “sale” from our website or mobile app.

How to Opt-Out of the Sale of Your Information

For our Websites, click on the “Do Not Sell My Personal Information” link at the bottom of the home page. For our mobile apps, we do not currently offer in-app hird party advertising and hence there is nothing to opt-out of in this regard.   After you click the “Do Not Sell My Personal Information” link on one of our Websites, You will be able to manage your cookie preferences for the Website, which will create an opt-out cookie to be stored on your browser, preventing personal information from being made available from this Website to advertising partners for their own use, independent of the Company (this opt-out cookie will only apply to the browser you were using and only for the device you were using at the time you made the selection. If you access the Websites from other browsers or devices, you will also need to make this selection on each browser and device). It’s also possible that portions of the Website service may not function as intended.  You should be aware that if you delete or clear cookies, that will delete our opt-out cookie and you will need to opt-out again.

We have taken this approach rather than taking your name and contact information because:

• We don’t ask for your personally identifiable information because we don’t need it to honor your Do Not Sell request. A general rule of privacy is to not collect personally identifiable information when you don’t need to—so we’ve set up this method instead.
• We may not know the information we share with advertising partners is related to you. For example, we may capture and share an identifier or IP address of a device you are using to visit our website, but not have tied that information to you. With this method, we are better at ensuring that we honor the intent of your Do Not Sell request, versus just taking your name and address.

California Shine the Light

Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

The Company has a comprehensive Privacy Policy and provides you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes.  Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time.  For example, iotum will revise or update this Policy if our practices change, as we change existing or add new services or as we develop better ways to inform you of products we think will be of interest. You should refer back to this page often for the latest information and the effective date of any changes. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. If we make material changes to our Privacy Statement, we may also notify you by other means, such as by posting a notice on our Websites or sending you a notification. By continuing to use our Websites after such revisions are in effect, you accept and agree to the revisions and abide by them. 

The iotum Privacy Policy was revised and effective as of April 8, 2024.

How to Contact Us

iotum is committed to the policies set forth in this Policy. If you have any questions, comments or concerns about this Policy, please contact support@iotum.com. Or you can post to: Iotum Inc., 1209 N. Orange St, Wilmington DE 19801-1120 Attn: Privacy.

Opt-Out: If you wish to opt-out from all future correspondence from us, please contact privacy@iotum.com or support@iotum.com