Privacy

To protect your privacy while you use the IPS website and to let you know what types of information we are collecting and how we are using it, we have developed this Privacy Policy. As we update, expand or change our offerings, this Privacy Policy may change from time to time.

Plese review our Terms of Use.

Effective Date of Current Policy: April 10, 2023

Overview

Purpose

IPS–Integrated Project Services, LLC, its wholly-owned subsidiary, Linesight Consulting Private Limited, and any other subsidiaries, and its operating divisions, affiliates and branches (collectively, “IPS,” the “Company,” “we” or “us”) are sensitive to privacy issues, and it is important to us to protect the information provided to us by our Clients and Suppliers. Accordingly, the Company provides this privacy and information practices policy to inform you about our information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”). For residents of California and other states that provide additional rights, more information about the data we collect is available in our Notice at Collection and Supplemental Notice for Residents of Certain Other States, which is found here.

Scope

This Privacy Policy applies to Personal Information that is processed by the Company in the course of our business, including on IPS’ websites located at www.ipsdb.com and www.linesight.com (together with any and all future websites operated by or on behalf of IPS), and any and all future online and offline offerings operated by or on behalf of IPS (collectively, the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of the Company are expected to protect that data by adherence to this Privacy Policy. IPS is the controller for the Personal Information we process, unless otherwise stated. For information on how to contact us, please refer to “Contact Us” below.

This Privacy Policy is designed to satisfy global and local compliance requirements; however, IPS may also maintain additional privacy policies and notices to address or provide additional details regarding certain additional local requirements.

This Privacy Policy does not apply to our collection and processing of personal information about job applicants, employees, or other workers. Please refer to our Applicant and Worker Privacy Policy to learn about privacy practices in those circumstances.

Notice

What Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with IPS and the requirements of applicable law. Some of the ways that IPS may collect Personal Information include:

• Personal Identifiers. We may collect Personal Information when you interact with us, such as name, email address, and telephone number.
• Regulatory Information. We may collect Personal Information where required to comply with regulatory requirements.
• Your Communications with Us. We may collect Personal Information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect Personal Information from you in connection with the survey.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Sweepstakes or Contests. We may collect Personal Information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Conferences, Trade Shows, and Other Events. We may collect Personal Information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect Personal Information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your Personal Information, such as your application, CV, cover letter, and/or any other information you provide to us. Please review our Applicant and Worker Privacy Notice for additional information.

The following sections describe who we collect information from and how we use it.

Clients

IPS collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Clients”). Client data we collect includes information relating to the sale or support of IPS Services, including an individual’s title, name, address, phone number, email address, government identification (driver’s license, passport), as well as financial information related to payments for services or goods.

We acquire, hold, use, and process Personal Information about Clients for a variety of business purposes including to:

• generally manage Client information and accounts and deliver our Services;
• provide IPS International, Inc. Project Management and Construction Claim Services;
• respond to questions and requests;
• provide access to certain areas and features of the IPS’ Services;
• verify Client identity;
• communicate about Client account and activities on IPS’ Sites and systems, and, in IPS’ discretion, changes to any IPS policy;
• tailor content, advertisements, and offers we serve to Clients;
• process payment for products or services purchased;
• allowing you to register for events
• improving, upgrading, or enhancing IPS Services and systems;
• develop new products, processes and services;
• Client worker safety and/or performance using location-based technologies, tools and/or devices;
• detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• carrying out activities that are required to comply with our legal obligations;
• ensuring internal quality control and safety;
• enforcing our agreements and policies;
• process applications and transactions; and
• for purposes disclosed at the time that Clients provide Personal Information or otherwise with consent.

Suppliers

IPS collects Personal Information regarding its current, prospective and former suppliers, distributors, subcontractors and strategic partners (collectively “Suppliers”). Supplier information we collect relates to the management of Suppliers and the receipt of their products and services. It may include an individual’s title, name, address, phone number, email address, government identification (driver’s license, passport), as well as financial information related to payment for goods and services.

We acquire, hold, use and Process Personal Information about Suppliers for a variety of business purposes including to:

• generally, manage Supplier information and accounts;
• provide IPS Project Management and Construction Claim Services;
• respond to questions and requests;
• provide access to certain areas and features of our Sites;
• verify Supplier identity;
• communicate about Supplier account and activities on our Sites and systems, and, in IPS’ discretion, changes to any IPS policy;
• tailor content;
• process payment for products or services purchased by IPS;
• improve our Sites and systems;
• develop new products, processes and services;
• process applications and transactions; and
• for purposes disclosed at the time Suppliers provide personal data or otherwise with consent.

Additional Types of Information We Collect

We endeavor to collect information only relevant for the purposes of Processing. Below are some of the ways we collect information and how we use it.

Social Media and Interest-Based Advertising

Generally, online social media resources are interactive tools that enable you to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards and blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. IPS may collect Personal Information to enable you to use online social media resources. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information those Third Parties share with others. IPS will only comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses.

Information from Third-Party Sources

IPS may collect information about you from Third-Party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to IPS and to enhance our ability to provide you with information about our business, products, and services. IPS’ agreements with these Third-Party sources typically limit how IPS may use this supplemental information.

Direct Mail, Email and Outbound Telemarketing

Clients and Suppliers who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, mailings or phone calls from us with information on our products and services or upcoming special offers/events we believe may be of interest. We offer our Clients and Suppliers the option to decline these communications at no cost to the individual Client or Supplier by following the procedures outlined below.

Research/Survey Solicitations

From time to time, IPS may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us to better serve Clients and Suppliers by learning more about their needs and the quality of the Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns and/or promotional activities. If a Client or Supplier participates in a survey, the information given will be used along with that of other survey participants. We may share anonymous individual and aggregate data for research and analysis purposes.

Cookie Policy and Other Tracking Technologies

IPS may employ cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Cookies

Like many other websites, IPS may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an individual initiates a session on the Company’s websites. A cookie is set in order to identify you and tailor our Services to you. Cookies do not store any of the Personal Information that is provided to the IPS websites; they are simply identifiers. You can delete cookie files from your own hard drive at any time. However, individuals should be advised that cookies may be necessary to provide access to much of the content and many of the features of our Services.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.

Pixel Tags/Web Beacons

IPS may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Services. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened our email.

Social Media Widgets

Our Services include social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing the features.

De-Identified and Aggregated Information

We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

Mobile Computing

IPS may provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of IPS’ Services may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, IPS may enable individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other electronic devices. These tools may transmit Personal Information to IPS to enable you to access user accounts and to enable IPS to track use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. IPS may use Personal Information or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices IPS provides.

Analytics

We may use Technologies and other third-party tools to process analytics information on our Sites. These Technologies allow us to better understand how our Sites are used and to continually improve and personalize our Sites. Some of our analytics partners may include:

• Google Analytics. For more information about how Google uses your Personal Information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
• LinkedIn Analytics. For more information about how LinkedIn uses your Personal Information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.
• Microsoft Clarity. For more information about how Microsoft uses your Personal Information (including for its own purposes, e.g., for advertising), please visit the Microsoft Privacy Statement. To learn more about how to opt out of Microsoft’s use of your information, please click here.
• Hotjar (Session Replay Analytics). From time to time, we may use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Sites. For more information about how Hotjar uses your Personal Information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.

Choice/Modalities to Opt Out

You may have the right to object to and opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

General

Before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by you, IPS will endeavor to obtain your explicit consent (opt-in). Where your consent for the Processing of Personal Information is otherwise required by law or contract, IPS will comply with the law or contract.

Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding the Company and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer, and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our site and some services and functionalities may not work. Please also note that these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

Onward Transfer

Information We Share

IPS does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Policy or as you explicitly consent. IPS may share Personal Information with our service providers, consultants and affiliates for our and our affiliates’ internal business purposes and administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide or to provide you with a product or service that you have requested. Payment Information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. IPS requires our service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which IPS retained them.

We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce IPS policies or contracts; (v) to collect amounts owed to IPS; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; (vii) to provide our Services, (viii) with third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services, (viii) with our affiliates such as to provide Services to you or support and supplement the Services we provide, (ix) with our business partners to provide you with a Service that you have requested, or (x) in the good faith belief that disclosure is otherwise necessary or advisable. In addition, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, IPS will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.

International Data Transfers

You agree that all Personal Information collected via or by IPS may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to IPS, you explicitly consent to the storage of your Personal Information in these locations. We endeavor to safeguard your information consistent with the requirements of applicable laws. If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, some of the safeguards we may use to support such transfer are the UK International Data Transfer Agreement or Addendum or EU Standard Contractual Clauses.

Privacy Rights

In accordance with applicable law, you may have the right to:

• Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes, including (i) the right to opt-out of the sharing of personal information, (ii) object to or restrict our use of or your sensitive personal information, including the right to opt-out of the sharing of sensitive personal information, and (iii) opt out of the processing of your personal information for purposes of (a) targeted advertising, and (b) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; and
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you are a resident of Brazil, you may have the right to:

• Access to and portability of Personal Information about you, including: (i) confirming whether we are Processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information;
• Request correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your Personal Information;
• Request deletion, anonymization or blocking of your Personal Information when Processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
• Request restriction of or object to our Processing of your Personal Information when Processing is noncompliant;
• Withdraw your consent to our Processing of your Personal Information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of Processing before the withdrawal. If you refrain from providing Personal Information or withdraw your consent to Processing, some features of our Sites or Services may not be available;
• Request data portability and receive an electronic copy of Personal Information that you have provided to us;
• Be informed about third parties with which your Personal Information has been shared; and
• Request the review of decisions taken exclusively based on automated processing if these decisions could affect your data subject rights.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below or as otherwise instructed in the additional privacy notices provided at the time we collect your Personal Information. We will process such requests in accordance with applicable laws.

Data Retention

IPS retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with all applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data.

Security of Your Information

The security of all Personal Information provided to IPS is important to us, and IPS takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Sites. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Sites or sending an e-mail to you. You may have a legal right to receive this notice in writing.

Other Rights and Important Information

Information Regarding Children

Due to the nature of IPS’ business, Services and Sites are not marketed to minors. IPS does not knowingly solicit or collect Personal Information from children under the age of 13 (or other age as required by local law). If you learn that your child has provided us with Personal Information without your consent, you may alert us at DPO@ipsdb.com. If we learn that we have collected Personal Information from a child under the age of 13 (or other age as required by local law), we will promptly delete that information.

Links to Third-Party Websites

Please note that our Services may contain links to other websites for your convenience and information. IPS does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. IPS does not endorse or make any representations about Third-Party websites. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy. IPS encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with IPS; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

Notice at Collection and Supplemental Notice for Residents of California and Certain U.S. States

This Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Utah, and Virginia (collectively, “Applicable State Laws”).

Personal Information We Collect Under the CCPA and Other Applicable State Laws

We collect personal data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

• Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.
  • Protected Classification Characteristics Under California or Federal Law
    E.g., Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex genetic information (including familial genetic information).
• Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or Other Electronic Network Activity Information. Browsing history, search history, and information regarding a consumer's interaction with a website, application, or advertisement.
• Geolocation. Physical location or movements.
• Professional, Education, and Employment-Related Information.
• Inferences Drawn from Other Personal Data. Inferences drawn from the information identified above to create a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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

• You and your devices;
• Your business partners and employees
• Our business partners or their agents;
• Our website, applications, devices and services;
• Consumer data resellers;
• Public records;
• From third parties that interact with us in connection with our Services.

Further information can be found under the “What Personal Information We Collect and How We Use It” section.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Performing services, including maintaining or servicing accounts, providing customer products or services, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
• For business related activities such as contact options, planning, and marketing preferences;
• As described to you when your personal data is collected, as directed by you or as otherwise permitted under applicable law;
• When you have provided your consent/authorization, to support benefit resolution and prescription fulfillment; and/or
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

Disclosure of Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. In the past 12 months, IPS may have disclosed the following categories of Personal Information about consumers for a business purpose:

Category of Personal Information Collected by Company	Category of Third Parties to which Information is Disclosed
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number or other similar identifiers.	Data analytics service providers Internet service providers Government entities IPS affiliates Insurance providers Advertising Networks Government entities Social networks
Sensitive personal information A social security, driver’s license, state identification card, or passport number, an account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication, or genetic information.	IPS affiliates Government entities
Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	IPS affiliates Government entities
Commercial Information	IPS affiliates Advertising Networks Internet service providers Data analytics service providers Government entities Social networks
Geolocation data Physical location or movements (of Company-owned vehicles, tools or other devices)	IPS affiliates Advertising Networks Internet service providers Data analytics service providers
Biometric information Biological characteristics that can be used to establish individual identity, or imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template such as a faceprint, a minutiae template, or a voiceprint, can be extracted.
Network Activity	IPS affiliates Advertising Networks Internet service providers Data analytics service providers Government entities Social networks
Professional or employment-related information Current or past job history or performance evaluations.	IPS affiliates Government entities
Inferences Drawn	IPS affiliates Advertising Networks Government entities

Your Personal Information is not (i) “sold” or (ii) “shared” (for purposes of targeted advertising) by us, nor do we have actual knowledge of any such activity involving the personal information of minors under 16 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising. To the extent that such sharing is considered a “sale” or “sharing” or disclosing for targeted advertising under California or other Applicable State Law, you may limit such sharing by following the instructions found above in the section titled, Your Privacy Choices and Rights, by clicking on the “Do Not Sell or Share My Information” link found here or by contacting us as set forth in “Contact Us” below, and by:

• Modifying Your Cookie Preferences. When you first visit our website, you will be presented with a banner which offers you a choice about whether to accept or reject our use of cookies and similar tracking technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law. If you wish to amend your choices, you can do by clicking here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your cookie management choices.
• Global Privacy Control. You may exercise your opt-out right by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request.

Opt-out of “Sales” for Nevada, California, and Virginia Residents. If you are a resident of Nevada, California, or Virginia, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. In addition to what is described in the preceding section, you can exercise this right, if applicable, by contacting us at DPO@ipsdb.com with the subject line “[Nevada, California, or Virginia] Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us by contacting us as set forth in “Contact Us” below.

Additional Privacy Rights for Residents of Certain States

Non-Discrimination. Residents of certain states have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by applicable law.

Authorized Agent. Only you, or someone legally authorized 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. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you would like to exercise any of these rights, please log into your account, writing to us or emailing us at DPO@ipsdb.com or calling 888-366-7660. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

Supplemental Notice for China Residents

This Supplemental Notice for China only applies to our processing of Personal Information that is subject to the applicable data protection laws of China, including the Personal Information Protection Law (“PIPL”).

Your Privacy Rights. In addition to the applicable rights listed above, you have the following additional data subject rights: the right to request an explanation on how your Personal Information is handled, the right to file a lawsuit, and the right to allow your next of kin to exercise any of your rights unless other arrangements have been made before your death. For purposes of the PIPL, IPS’ Data Protection Officer is your data handler, and data subject requests may be directed to the contact information provided above.

International Transfers. When transferring Personal Information which originates in China internationally, we will comply with the applicable requirements governing the transfer and processing of such data. Providing IPS information through the website, or otherwise constitutes your consent for our international transfer of your data.

List of Entrusted Persons. If permitted under applicable law, you may request a copy of our service providers (entrusted persons).

Supervisory Authority

If your Personal Information is subject to the applicable data protection laws of Brazil, the European Economic Area, Switzerland, the United Kingdom, or Virginia, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

• Autoridade Nacionalde Proteçãode Dados (ANPD)
• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)
• Virginia Attorney General

Changes to the Privacy Policy

IPS may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Privacy Policy, IPS will notify you by email or as otherwise required by applicable law. IPS encourages you to review this Privacy Policy periodically to be informed regarding how IPS is using and protecting your information and to be aware of any policy changes. Your continued relationship with IPS after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by IPS.

Compliance

This Privacy Policy shall be implemented by IPS and all its operating divisions, subsidiaries and affiliates.

Definitions

The following capitalized terms shall have the meanings herein as set forth below.

“Agent” means any Third Party that processes Personal Information pursuant to the instructions of, and solely for, IPS or to which IPS discloses Personal Information for use on its behalf.

“Personal Information” is any information relating to an identified or identifiable natural person (“you”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, access, recording, organization, enrichment, structuring, storage, adaptation or alteration, retrieval, consultation, use, transfer, disclosure by transmission, de-identification, anonymization, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any natural or legal person, public authority, agency or body other than the Data Subject, IPS or IPS’ agents.

Contact Us

If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority please contact us at:

IPS Attn: Data Protection Officer
721 Arbor Way, Suite 100
Blue Bell, PA 19422
USA
DPO@ipsdb.com
888-366-7660
610-828-4090

IPS will address your concerns and attempt to resolve any privacy issues in a timely manner.