Privacy Notice

This Privacy Notice for IRDB Holdings, Inc. (doing business as IRCODE) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at ircode.com or any website of ours that links to this Privacy Notice
• Download and use our mobile application (IRCODE), or any other application of ours that links to this Privacy Notice
• Use the IRCODE Platform (including the IRCODE App, IRCODE Website, and Embedded Experiences). IRCODE provides a mobile and web-based platform that allows users to interact with digital and broadcast content through image recognition and scanning technology. Depending on the specific content, campaign, or experience, scanning designated content (such as advertisements, products, or media) may direct users to interactive experiences, promotional opportunities, sweepstakes entries, third-party websites, or other destinations determined by the applicable campaign or content owner. IRCODE services may be accessed through our standalone mobile application, our website, or through integrated experiences within third-party applications (such as media or broadcast partner apps) that incorporate IRCODE technology ("Embedded Experiences"). These experiences may be operated by IRCODE, third-party partners, or a combination of both. When users interact with IRCODE through these experiences, we may collect information about user interactions with scanned content, app features, and engagement activities to operate the service, improve functionality, enhance user experience, and support promotional programs.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@ircode.com.

Summary of key points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

When and with whom do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by visiting ircode.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include: names; phone numbers; email addresses; usernames; passwords; contact preferences; contact or authentication data; mailing addresses; date of birth; sweepstakes entry information, including scan activity, survey responses, and engagement data; and social security number or taxpayer identification number (collected from prize winners only for tax reporting purposes).

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process social security numbers or taxpayer identification numbers collected only from verified prize winners for tax reporting purposes.

Social Media Login Data. We may provide you with the option to register using your existing social media account details. If you choose to register this way, we will collect certain profile information about you from the social media provider.

Application Data. If you use our application(s), we may collect geolocation information, mobile device data (such as device ID, model, manufacturer, operating system, and IP address), and may request to send push notifications. This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for internal analytics and reporting.

Information automatically collected

Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services. This includes Log and Usage Data, Device Data, and Location Data. Like many businesses, we also collect information through cookies and similar technologies. Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

We may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and other third parties, for purposes of targeted advertising and event promotion.

2. How do we process your information?

We process your personal information to: facilitate account creation, authentication, and account management; deliver and facilitate delivery of services; respond to user inquiries and offer support; send administrative information; save or protect an individual's vital interest; analyze and enhance our Services (including processing scan data, image recognition inputs, and user interaction data to enable content recognition, sweepstakes participation, and engagement features); and send marketing and promotional communications, subject to your preferences and applicable law. You may opt out at any time.

3. What legal bases do we rely on?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so. If you are located in the EU or UK, we may rely on consent, performance of a contract, legal obligations, and vital interests. If you are located in Canada, we may process your information with your express or implied consent, and in certain exceptional cases as permitted by applicable law.

4. When and with whom do we share your information?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us and require access to such information. Categories include: Cloud Computing Services; AI Platforms; Data Analytics Services; Communication & Collaboration Tools; User Account Registration & Authentication Services; Website Hosting Service Providers; Performance Monitoring Tools; Data Storage Service Providers; Social Networks; and Testing Tools. We may also share information in connection with business transfers and with business partners.

5. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services, for security, functionality, analytics, and advertising. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. Do we offer artificial intelligence-based products?

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies ("AI Products"), designed for image analysis. All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.

7. How do we handle your social logins?

If you choose to register or log in using a third-party social media account, we will receive certain profile information about you from your social media provider, which may include your name, email address, friends list, and profile picture. We do not control, and are not responsible for, other uses of your personal information by your social media provider.

8. Is your information transferred internationally?

Our servers are located in the United States. Your information may be transferred to, stored, and processed by us and our third parties in the United States and other countries. Where required, we use the European Commission's Standard Contractual Clauses and similar safeguards to protect personal information transferred from the EEA or UK.

9. How long do we keep your information?

We keep your personal information only as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.

10. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be 100% secure. Transmission of personal information to and from our Services is at your own risk.

11. Do we collect information from minors?

We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction. If we learn that personal information from such users has been collected, we will deactivate the account and take reasonable measures to promptly delete the data. If you become aware of any such data, please contact us at info@ircode.com.

12. What are your privacy rights?

Depending on your location, you may have rights including the right to request access to and obtain a copy of your personal information, request rectification or erasure, restrict processing, data portability, and not to be subject to automated decision-making. You may withdraw consent at any time. To exercise these rights, contact us using the details below.

13. Controls for Do-Not-Track features

Because there is not yet a uniform technology standard for recognizing and implementing Do-Not-Track ("DNT") signals, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

14. Do United States residents have specific privacy rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and details about the personal information we maintain, correct inaccuracies, get a copy of, or delete your personal information, and to opt out of certain processing. These rights may be limited in some circumstances by applicable law. We have not sold or shared personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

15. Sweepstakes and promotions

If you participate in any of our sweepstakes, contests, or promotions, we may collect personal information such as your name, email address, phone number, and any other information you provide as part of your entry, and use it to administer the promotion. Participation is subject to the applicable official rules.

16. Third-party platforms and integrations

Our services may be made available through or integrated with third-party websites, applications, or platforms that incorporate IRCODE technology. The third-party platform may independently collect, use, and share information in accordance with its own privacy policy. We are not responsible for the privacy practices of such third parties.

17. Mobile application and device data

When you use our mobile application or interact with our scanning features, we may collect certain information from your device, such as device type, operating system, unique device identifiers, and information related to your use of the application. Features that require access to your device camera or similar hardware will request permission in accordance with your device settings.

18. Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date and will be effective as soon as it is accessible. We encourage you to review this Privacy Notice frequently.

19. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at info@ircode.com or contact us by post at: IRDB Holdings, Inc., 6315 FM1488 Rd, Suite B180, Magnolia, TX 77354, United States.

20. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please visit ircode.com.