PRIVACY

Irene Neuwirth Privacy Statement

Irene Neuwirth, Inc., and its subsidiaries, affiliates and parent companies (“Irene Neuwirth”, “we”, “us” or “our”) is committed to protecting your privacy and ensuring you have a positive experience when you visit our webpages, interact with us on social media, or online (the “Services”).

This Statement explains Irene Neuwirth’s practices when we process your “personal data,” which is information that relates to an identified or identifiable individual. To “process” or “processing” means any use of personal data including, transferring, collecting, recording, storing, using, analyzing, combining, disclosing or deleting it.

This Statement may be updated periodically. If we plan to make any material changes to the way we handle personal data as described here, we will notify you by posting an updated version of this Statement on our website. We may supplement this Statement with “just-in-time” notices, or other disclosures contained within or in connection with the provision of the Services, which may describe in more detail our data collection, use and sharing practices. Unless we say otherwise, such supplemental privacy statements will govern how we may process the information in the context of the specific product or service.

 What this Statement Covers

This Statement applies to the personal data we process as a data controller, that is, as the party that determines what data to collect and why. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with the Services. The data we collect depends on the context of your interactions with Irene Neuwirth and the choices you make, including the products and features you use. We also obtain data about you from third parties.

Personal Data We Process & How We Use It

The table below describes Irene Neuwirth’s processing of personal data as a data controller. The table does not cover customer content, including any personal data about you that may be contained in customer content because the customer (the Irene Neuwirth account holder), rather than Irene Neuwirth, controls how customer content is processed. Any questions about the processing of customer content should be addressed to the customer directly.

Personal Data Processing

Types of Personal Data	How We Get It	What We Do With It	Legal Basis [Applies only in the EEA, and only within the meaning of the EU’s General Data Protection Regulation (GDPR)]
Account User Data Information we collect when you register for a free Irene Neuwirth Account, such as: Date of birth (for age-verification purposes only, Irene Neuwirth does not retain or use this information for any other purpose) First Name Last Name Phone (optional) Email User IDs and Password (if Single Sign On is not used)	From the free Irene Neuwirth account registrant	Enroll you in the Services Display your user avatar to meeting participants. Provide you with support Send marketing communications, where permitted Provide announcements related to software updates, upgrades, and system enhancements Provide you with Irene Neuwirth event information and offers from us or Irene Neuwirth event co-sponsors	Contract Legitimate Interests
Operation Data Technical information from Irene Neuwirth’s software or systems hosting the Services, and from the systems, applications and devices that are used to access the Services, such as: Configuration Data: information about the deployment of Irene Neuwirth Services and related environment information. Feature Usage Data: information about if and how Service features were used. Performance Data: metrics related to how the Services perform. Service Logs: information on system events and states.	Automatically through use of the Services	Facilitate the delivery and optimization of the Services Monitor performance of our data centers and networks Provide Account dashboards and reports Provide support Maintain the security of our infrastructure and Services Administer our disaster recovery plans and policies Detect, investigate and stop fraudulent, harmful, unauthorized or illegal activity (“fraud and abuse detection”) Confirm compliance with contractual obligations Comply with legal obligations Create anonymized and/or aggregated data to improve our products and for other lawful business purposes	Contract Legitimate interests Protect vital interests Legal compliance
Support and Feedback Data, such as: Support Data: information that has been provided by a customer to Irene Neuwirth or is otherwise processed in connection with support activities such as support chats or calls and Service support tickets.	Directly from an Irene Neuwirth user	Respond to requests for support Conduct anonymized, aggregated analytics to improve performance	Contract Legitimate interests
Approximate Location (e.g., nearest city or town)	Automatically through your use of the Services	Connect you to the nearest data center Comply with privacy and other laws – for example, so we can provide you with the right notices for your area Suggest choices such as language preferences Monitor performance of our data centers and networks Route support requests	Contract Legitimate interests Legal obligation
Persistent Identifiers on Marketing Pages Data collected through the use of cookies and pixels from tools (such as Google Analytics and Google Ads), such as: Internet protocol (IP) addresses, Browser type, Internet service provider (ISP), Referrer URL, Exit pages, the files viewed on our marketing sites (e.g., HTML pages, graphics, etc.), Operating system, and Date/time stamp Approximate location (e.g., nearest city or town)	We may collect automatically from our Marketing Pages and other online services	Analyze how our website is used so we can improve your experience Complete orders and remember your settings Identifying language preferences Evaluate the success of our Marketing campaigns Marketing, including facilitating tailoring of advertising you see when you are on other online services	Consent Legitimate Interests
Persistent Identifiers on Product Pages These are third-party cookies that are necessary for technical support and to deliver the service.	Automatically when you use the Services from your web browser	Provide the Service Provide Technical Support	Contract Legitimate Interests
Marketing Data Data enrichment services (only in connection with Marketing Pages) Email marketing lists (where permitted under applicable law)	From Third Parties and public sources	Marketing activities Sending marketing communications Providing tailored information about our Services	Legitimate Interests

Customer Content

Customer content is the “in-session” information you give us directly through your use of the Services, such as files, chat logs, and transcripts, and any other information uploaded while using the Services. Irene Neuwirth uses customer content only in connection with providing the Services – we do not monitor, sell or use customer content for any other purposes.

We do not control the actions of anyone with whom you or any other Service user may choose to share information. Therefore, we cannot and do not guarantee that any customer content you or any user provides to the Services will not be viewed by unauthorized persons. Please be aware that no security measures are perfect or impenetrable and that we are not responsible for circumvention of any security measures contained on the Services. You should be cautious about the access you provide to others when using the Services, and the information you choose to share when using the Services.

Irene Neuwirth’s Product and Marketing Pages

Irene Neuwirth generally processes personal data in two different manners using its websites. First, Irene Neuwirth processes personal data it obtains from the webpages that Irene Neuwirth uses to provide its Services, Irene Neuwirth processes personal data obtained from its webpages that are accessible without logging in to a Irene Neuwirth account.

Like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies on our Marketing Pages. This is called interest-based advertising.

 How We Share Personal Data

We only share personal data with companies, organizations or individuals outside of Irene Neuwirth when one of the following circumstances applies:

With consent

We may share personal data with companies, organizations, individuals outside of Irene Neuwirth and others when we have consent from an individual (as applicable).

With Irene Neuwirth Partners

If Irene Neuwirth received your personal data from a third-party partner and you become a Customer, Irene Neuwirth may disclose select personal data to that partner or their designee for the purpose of the partnership agreement; for example, to reward a referral partner from a co-sponsored event. Irene Neuwirth’s partners have contractually agreed to comply with appropriate privacy and security obligations.

For corporate transactions

We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Irene Neuwirth’s business or assets, including in connection with bankruptcy or similar proceedings.

For business purposes

We provide personal data to vendors and services providers to help us provide the Services and for Irene Neuwirth’s business purposes. Examples include public cloud storage vendors, carriers, payment processor, and service provider for managing customer support tickets. Irene Neuwirth contractually prohibits such vendors from using the personal data for any reason other than to provide the contracted-for services and Irene Neuwirth contractually requires its vendors to comply with all appropriate privacy and security requirements.

For legal reasons

We share personal data with companies, organizations or individuals outside of Irene Neuwirth if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:

• meet any applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• enforce applicable Terms of Service, including investigation of potential violations.
• detect, prevent, or otherwise address fraud, security or technical issues.
• protect against harm to the rights, property or safety of Irene Neuwirth, our users or the public as required or permitted by law, including to help prevent the loss of life or serious injury of anyone.

 Data Subject Privacy Rights and Choices

Right to Correct or Update Your Information

If you would like to correct or update information that you have provided to us, please log on to www.Irene Neuwirth.com and update your profile.

Marketing Communication

You may receive marketing email communications from us where permissible. If you would like to stop receiving these communications, you can update your preferences by using the “Unsubscribe” link found in those emails.

European Privacy Rights

If you reside in the European Economic Area, you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.

1. Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
2. Right of access and/or portability. You may have the right to access the personal data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
3. Right of erasure. In certain circumstances, you may have the right to the erasure of personal data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
4. Right to object to processing. You may have the right to request that Irene Neuwirth stop processing your personal data and/or to stop sending you marketing communications.
5. Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal information.
6. Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
7. Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to complain to a data protection authority about our collection and use of your personal data.

How to Exercise Your Rights

To exercise any of the rights above, email us at hello@ireneneuwirth.com. You may also submit a request to the following address:

Irene Neuwirth, Inc.
8458 Melrose Place
West Hollywood, CA 90069

Please identify yourself and specify your request. If you have a password protected Irene Neuwirth account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

We use commercially reasonable efforts to delete your personal data as required but retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.

 International Transfers

Irene Neuwirth operates globally, which means personal data may be stored and processed (for example stored in a data center) in any country where we or our service providers have facilities or hold events. By using Irene Neuwirth or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States or in other countries around the world. Such countries may have data protection rules that are different and less protective than those of your country.

If you are a resident of the European Economic Area (EEA), and your personal data is transferred outside of the EEA, we will:

• Process it in a territory which the European Commission has determined provides an adequate level of protection for personal information; or
• Implement appropriate safeguards to protect your personal information, including transferring it in accordance with applicable transfer mechanism, including the European Commission's standard contractual clauses.

Retention

We will retain personal data for as long as required to do what we say we will in this Statement, unless a longer retention period is required by applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you have an account with us or keep using our services);
• Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 Security

Irene Neuwirth is committed to protecting your personal data. We use reasonable and appropriate technical and organizational measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data. If you have any questions about the security of your data, please contact our security team at hello@ireneneuwirth.com.

How to Contact Us

If you have any privacy-related questions or comments related to this Statement, please send an email to hello@ireneneuwirth.com. You can also contact us by writing to this address:

Irene Neuwirth, Inc.
8458 Melrose Place
West Hollywood, CA 90069