Last Revised: January 12, 2020
1. Information Collection and Use
Our primary goals in collecting personally identifiable information are to provide you with the product and services made available through the Service, to communicate with you, and to manage your registered user account, if you have one.
Information we collect. We may collect the following categories of personal information about you through the App, including but not limited to:
- Registration information: To use certain features of the Services, you will need to register an account. When you make an account, you will be asked for basic registration information, such as an email address and password.
- Identification information: You may also be asked to provide identification information to confirm your identity, including your first and last name, username, address, and phone number.
- Third party credentials: You may also enter in certain passwords, usernames, account numbers, and other account information for websites, apps, products or services provided by third-party service providers (“Third-Party Services”).
- Information from Third-Party Services: In order to display information to you through the Service, we may collect, on your behalf, your account and other personal information from Third-Party Services that you register under your account via the Service. For example, if you register your Robinhood or TD Ameritrade account with us, we will aggregate your Robinhood or TD Ameritrade information via our Service in order to present it to you. If you choose to access Robinhood’s or TD Ameritrade’s services through our Service, we may store a representation of your account information including but not limited to account holdings and transaction histories from your Robinhood or TD Ameritrade accounts.
- Technical and navigational information: We collect information about your interaction with our App such as computer browser type, pages visited, average time spent on our App, IP address, unique identifier of the device, operating system version and app version.
- Location information: If you choose to use a location enabled Service, we may collect location information from your device and will notify you of this collection. You may control or disable the sharing of location information via your device setting and/or the App.
- Other information: We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service. In such instances, you will be given the opportunity to provide or decline that information.
- Your full user name and your image (if you decide to upload one) are displayed to people in the Iris network to enable you to connect with people on Iris.
- Use of Contact Information. If you contact us by email through the App or the Site, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you. In addition, we may use your contact information to market to you, and provide you with information about, our products and services, including but not limited to our Service. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications.
3. Information Sharing and Disclosure
Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data. In addition, we may use information you provide about Third-Party Services to provide the Service, which may include accessing the Third-Party Services you select on your behalf, so that we can present the requested information to you. With respect to mobile applications or mobile versions of our Sites, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”). Device IDs allow app developers, advertisers, and others to uniquely identify your device for purposes of storing application preferences and other data.
We may use your Device ID for security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Site or App is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user.
Compliance with Laws and Law Enforcement. Iris cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of Iris or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
Business Transfers. Iris may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
In connection with third party services, we may share some of your personal information with the third parties when you are attempting to process the transaction you have requested.
We may share your personal information with third party service providers to enable them to assist in fulfilling the requests you make or the transactions you conduct via the Sites, including the operation of certain App or Site functions and Services. Third parties acting on our behalf that are given access to your personal information are contractually obligated to abide by our privacy practices and are not allowed to use the information for any other purposes.
We reserve the right, in our sole discretion, to share or disclose your personal information with law enforcement, government officials, and other third parties:
- to respond to subpoenas, court orders, or legal process;
- in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites or Services;
- to respond to claims that any posting or other content violates the rights of third parties;
- in an emergency, to protect the health and safety of our Sites’ users or the general public; or
- as otherwise required by any applicable law.
We may share your personal information with other third parties with your consent or instructions to do so.
Ad Serving. We may serve ads on the Service. Such ads may be delivered to you by a web advertising vendor. In order to serve ads to you, we may use information collected during your searches or visits to our websites and information that we specifically acquire from third parties.
Advertising and Cookies. Some of our third party advertising partners may distribute cookies to users in advertisements that are provided to us. Iris has no access to or control over these cookies once we have received the advertisements. Some of these advertisers and services we use to deliver advertising may be engaging in online behavioral advertising as defined by the Digital Advertising Alliance and FTC.
Although Iris does not provide any Personally Identifiable Information to third-party advertising companies, if an advertiser asks Iris to show an advertisement to users with certain characteristics or a segment of that group (for example, men ages 21-30 who have viewed certain categories of content on the Service) and you respond to that advertisement, the third-party advertising company may conclude that you have the characteristics of the audience that they are trying to reach.
5. Third Party Data Collection
Iris is very concerned about safeguarding the confidentiality of your personally identifiable information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access, but we cannot and do not assure that these measures will be sufficient to protect against all efforts to gain unauthorized access to the information.
We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on this App or Site.
7. Links to Other Websites
Our App contains links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
8. Our Policy Towards Children
The App or Site is not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 18. If we become aware that a child under 18 has provided us with personal identifiable Information, we will delete such information from our files.
9. Access and Deletion Rights
You have the right to access, correct or delete Personal Information held about you by Iris. To the extent allowed, any requests to exercise such rights may be subject to a small fee to meet our costs in providing you with details of the Personal Information we hold about you. Should you wish to access the Personal Information held about you, please let us know by contacting us at the contact information provided below.
10. Contact Us
To request access to personal data relating to you which is processed by Iris, and/or if you have any questions about the handling of personal information, please send an email to email@example.com.