This Privacy Notice (“Privacy Notice”) describes and governs the information collection, use, and sharing practices of IRONMARKETS/ACBM, LLC, located at 201 N Main Street, Fort Atkinson, WI 53538 (“IRONMARKETS,” “we,” “us,” and “our”), with respect to your use of the IRONMARKETS website at www.iron.markets and the websites of our brands (collectively, the “Sites”) and the services we provide (collectively, the Sites and these services are the “Services”). For individuals in the European Economic Area (“EEA”), IRONMARKETS is the “controller” of your personal data.
Before you use or submit any information through or in connection with the Services, please carefully review this Privacy Notice. By using any part of the Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Notice. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, PLEASE DO NOT USE THE SERVICES.
We collect information in multiple ways, including when you provide information directly to us; when we passively collect information from you, such as from your browser or device; and from third parties. We may combine all of the information we collect about you from these various sources.
Information You Provide Directly to Us
We will collect any information that you provide to us. For example, if you contact us through our Sites, create an account with us, register for a magazine subscription, or register for an event or webinar, we will collect certain information, such as your name, email address, phone number, mailing address, and information about your company. If you contact us through our Sites, we will collect your name, email address, and the subject and contents of any message you send.
In addition to the above, if you submit content (such as comments) to our Sites, we will collect such content and the name under which you would like to post such content. Please note that any content (including the name under which you post it) that you post to our Sites may be publicly available and we cannot prevent third parties from using your content in ways not covered by this Privacy Notice. We encourage you to be mindful of the information that you make available through our Sites.
You do not have a statutory or contractual obligation to provide us with your information; however, certain information may be required in order to use the Services.
Information that Is Automatically Collected
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, location information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Tracking Technologies
We also collect data about your use of the Services through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (a) recognize your computer; (b) store your preferences and settings; (c) understand the web pages of the Services you have visited; (d), enhance your user experience by delivering content and advertisements specific to your inferred interests; (e) perform searches and analytics; and (f) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. We also may include Web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we adopt additional technologies, we may also gather additional information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Information from Third Parties
We may also collect information about you or others through non-affiliated third parties. For example, to the extent permitted by law, we may, in our sole discretion, collect information from third parties, including public sources and marketing and market research firms. Depending on the source, this information collected from third parties could include name, contact information, demographic information, information about an individual’s employer, information to verify identity or trustworthiness, and information for other fraud or safety protection purposes. We may combine information that we collect from you through the Services with information that we obtain from such third parties and information derived from any other products or services we provide.
We may use the information we collect from and about you for the following purposes:
– For the purposes for which you provided it;
– To provide and improve the Services, including to develop new features or services, provide you with tailored content, and for technical and customer support;
– To send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed;
– For marketing and advertising purposes, including to contact you, and to enable third parties to contact you, with information or surveys that we believe may be of interest to you both regarding our products and Services and those of third parties, and to place ads on the Services and third-party sites;
– To process and respond to your inquiries or to request your feedback;
– For internal analytics, research, and reporting; and
– To comply with the law and protect the safety, rights, property, or security of IRONMARKETS, the Services, our customers, and the general public;
– To enforce the legal terms that govern your use of the Services.
Please note that we may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Notice.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and/or others.
We may disclose and/or share your information under the following circumstances:
– Service Providers. We may disclose your information with third parties who perform services on our behalf, including without limitation marketing, market research, customer support, data storage, data analysis and processing, and legal services.
– Legal Compliance and Protection of IRONMARKETS and Others. We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Notice or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; (d) to respond to your requests for customer service; and/or (e) to protect the rights, property, or personal safety of IRONMARKETS, our agents and affiliates, our customers, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
– Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of IRONMARKETS’ assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
– Affiliated Companies. We may disclose your information with current or future affiliated companies.
– Other Unaffiliated Third Parties. We may disclose your information with unaffiliated third parties other than those described above, including for those third parties’ own marketing activities, in accordance with applicable legal requirements.
– Consent. We may disclose your information to any third parties based on your consent to do so.
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing your personal data are as follows:
– To Honor Our Contractual Commitments to You. Much of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ request in anticipation of entering into a contract with them.
– Legitimate Interests. In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
~ Customer service
~ Marketing and advertising
~ Protecting our customers, personnel, and property
~ Analyzing and improving our business
~ Managing legal issues
~ We may also process personal data for the same legitimate interests of our clients and business partners.
– Legal Compliance. We need to use and disclose personal data in certain ways to comply with our legal obligations.
– Consent. Where required by law, and in some other cases where legally permissible, we handle personal data on the basis of consent. Where we handle your personal data on the basis of consent, you have the right to withdraw your consent.
If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on our Services or third-party services you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be tailored to you based on your current activity or your activity over time and across our Services and other third-party services. We allow third parties (e.g., ad networks and ad servers such as DoubleClick and others) to serve tailored ads to you our Services and other sites and applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective.
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about Do Not Track here.
All customers can review and update certain customer information by emailing us at [email@example.com]. You can unsubscribe from marketing emails by clicking the “unsubscribe” link they contain. If you have registered for an account with us through the Sites, you can also update certain information and your email communications options by logging into your account and updating your account information and communications settings.
Individuals in the European Economic Area and other jurisdictions have certain legal rights (subject to applicable exceptions and limitations) to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. You may also have rights to object to our handling of your personal data, restrict our processing of your personal data, and to withdraw any consent you have provided. To exercise these rights, please email us at [firstname.lastname@example.org] with the nature of your request. While we strongly encourage you to first raise any questions or concerns about your personal data with us, you also have a right to contact the relevant supervisory authority.
Our computer systems are currently based in the United States, and your personal data will be processed in the United States, which may not offer the same level of protection as the privacy laws of your jurisdiction.
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Notice or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.
The Services may contain links to or “frame” third-party websites, applications, and other services. Please be aware that we are not responsible for the privacy practices of such other sites and services. If you choose to use such third-party links and services, we encourage you to read the privacy statements of each and every site you visit.
Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of personal information to third parties for the third parties’ direct marketing purposes, if any.
To submit a request, or designate an authorized agent to make a request under the CCPA on your behalf, please contact us at email@example.com or 1-800-538-5544. To verify your identity when you submit a request, we will match the identifying information you provide us to the personal information we have about you. If you have an account with us, we will also verify your identity through our existing authentication practices for your account.
If you are a California resident, pursuant to the California Consumer Protection Act (CCPA), you also have the right to request not having your personal information disclosed or sold to third parties. In order to make this request complete the online web form, or reach out to firstname.lastname@example.org.
We will continue to evaluate this Privacy Notice as we update and expand the Sites and our Services, and we may make changes to the Privacy Notice accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Privacy Notice, we will provide you with notice as required by law.