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Here at iRely, LLC. (“iRely” “we” and “us”), we understand and respect your concerns about the use of your personal data. This Privacy Policy (the “Policy”) explains what personal date we collect, how we use that information, and your privacy rights.


1.     DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

  • “Data Subject” means an identified or identifiable natural person; 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.
  • “GDPR” refers to the European General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).
  • “EU” (European Union) refers to those countries that are members of the European Union.
  • “EEA” (European Economic Area) refers to those countries that are members of the European Economic Area.
  • “Personal Data” means any information relating to a Data Subject.
  • “Privacy Shield Principles” mean the Privacy Shield Principles enumerated under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.
  • “Third Party” means any person that is not an employee or agent of iRely.


2. PRIVACY      PRIVACY PRINCIPLES

The privacy principles expressed in this Policy are based on the Privacy Shield Principles enumerated under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.


3. COLLECTION      COLLECTION AND USE OF PERSONAL DATA

This Policy applies to all personal data received by iRely in any format including electronic, paper or verbal. iRely collects and processes personal data from current and former employees, as well as applicants for employment, clients, and prospective clients, through its Internet website, its Intranet site, carrier portals, electronic mail, and traditional mail.  All personal data collected by iRely will be used for legitimate business purposes consistent with this Policy.

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  • Our Retention of Personal Data
    • iRely will retain personal data while we have a justifiable business need to do so, unless a longer retention period is required or permitted by law (such as tax, legal, accounting, or other purposes). For example, if you are a customer, we will keep your personal data for the duration of the contractual relationship you or your company has with us and after the end of that relationship for as long as necessary to perform the functions set forth above or to comply with legal obligations. When we have no justifiable business need to process your personal data, we will either delete or anonymize it, or if this is not possible, we will securely store your personal data and isolate it from any further processing until deletion is possible.


4. SECURITY     SECURITY

iRely uses administrative, organizational, technical, and physical safeguards to protect your personal data.  We will take reasonable precautions to protect personal data in our possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. With respect to information given on the Internet, iRely uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures.  We require our partners to use appropriate security measures.


5. USER      USER ACCESS AND CHOICE

  • You are entitled to ask us for a copy of your personal data, to correct it, erase or restrict its processing, or to ask us to transfer (parts of) this data to other organizations. You also have the right to object to certain processing activities, such as the profiling we may perform for the purposes of direct marketing as discussed above in this Policy. Where we have asked for your consent to process your personal data, you have the right to withdraw this consent, for example, by using the opt-out or unsubscribe functionalities in our communications with you.  These rights can be limited where we can demonstrate that we have a legal requirement or legitimate basis to process your personal data, and under such circumstances, we are able to retain your data even if you withdraw your consent.
  • If you wish to make use of any of these rights, please contact our Data Privacy Officer by e-mail or postal mail at the contact information provided below for the Data Privacy Officer or, as applicable, by using opt-out or unsubscribe functionalities in our communications with you. We will respond to your request within 30 days. If you are not satisfied with how we handle such requests or how we otherwise process your personal data, you can seek to have the matter addressed through the dispute resolution program administered by JAMS; for more information on how to initiate a matter with JAMS, please see https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.


6. LINKED      LINKED WEBSITES AND OTHER THIRD PARTIES

This Privacy Policy only addresses the use and disclosure of personal data that we collect from you.  The Website, or services on the Website, may contain links to other websites whose information, security, and privacy practices may be different than ours.  You should consult the other websites' privacy policies and terms of use since we do not control information that is submitted to, or collected by, these third parties or the content of those linked websites. Once you access another website, you are subject to the privacy policy and terms of use of that website.


7. CHILDREN’S      CHILDREN’S PRIVACY

The Website and its services are not directed toward children under the age of 14.  iRely will not knowingly request personally identifiable information from anyone under the age of 14, and if iRely becomes aware that any such information has been collected, iRely will delete it.


8. CHANGES      CHANGES TO THIS POLICY

This Policy was last revised on December 27, 2019.  iRely reserves the right to change, modify, or amend this Policy at any time. When the Policy is changed, modified, and/or amended, the revised Policy will be posted on our website. If required by applicable law, we will notify you of any material changes to the Policy, and we will provide such notification by means of posting a notice on our website prior to the changes becoming effective. Any revised privacy policy will only apply prospectively to personal data collected or modified after the effective date of the revised policy.


9. CONTACT      CONTACT INFORMATION

If you have any questions regarding this Policy, you can write to iRely’s Data Privacy Officer, who may be contacted by telephone at 1-800-433-5724, by e-mail at billing@iRely.com, or by postal mail at:

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