Irys Privacy Statement — Last Updated August 19th, 2024

We have prepared this Data Privacy Policy for Irys, Inc. to explain how, why, and when we use your personal data in connection with our services using geolocation data. The following describes our data collection and use practices for the information that we collect and the data we receive from our data partners. This Data Privacy Policy also describes our data privacy practices related to personal information that we collect through our website at https://www.irys.us (the “Site”) and is used to provide information to Website users, customers and business partners about our services.

WHO WE ARE

Irys is a startup data analytics company and data broker founded to help provide analytics, context, and geolocation information to companies that solve unique challenges from marketing to urban development to transportation globally. Our goal is to encourage responsible data use to promote smart solutions that work for everyone in the future. 

To that end, we do not resell your information or our services for certain uses that we do not agree with, including government, law enforcement, military, and religious or political organizations. We review each of our data suppliers for compliance with applicable data privacy laws and each of our customers who we sell our services to in order to ensure that we don’t make available geolocation data to the above organizations. 

OUR DATA SUPPLIERS

We only use data that has been collected with appropriate consent, as required by applicable privacy laws. All of our data suppliers are required to agree by contract to provide data that has only been lawfully collected and shared. We also ensure that we receive consent data in order to ensure the lineage and fair use of our data. 

However, we understand that sometimes you wish to revoke the consents you have been given or that you may not be aware that a data supplier shared your information with us. If we have received your information without your consent or you wish to revoke your consent to use your information, please see the Your Rights section below. 

YOUR INFORMATION

Our geolocation based services are based on data we collect from third parties who supply is with the following information: 

  • Advertising ID (Android Advertising ID or Apple ID for Advertisers)

  • Timestamp

  • Latitude and Longitude coordinates

  • Information about a device such as device type and model and OS type and version;

  • Public facing (external) IP address of device;

  • The direction in which the device is traveling as a degree coordinate and speed of device;

  • Altitude and vertical accuracy;

  • Phone carrier and connection type (e.g., cellular, wifi);

  • Proximity beacon UUID’s or any associated Bluetooth Low Energy(BLE) beacon metadata.

  • Device language;

  • Available or connected WiFi SSID and/or BSSID names;

We also acquire non-personal mapping and location data from third parties. 

When you visit our Site, we may also collect the information from your desktop computer, laptop, mobile phone, tablet, or other device. This information may include anonymous data, such as a unique browser identifier, device type, operating system, settings and system configurations, IP address, other unique device identifiers, and mobile network information and your activity on our website, as well as data about the webpages you access, traffic to and from websites, the dates and times associated with transactions, and web log data. We refer to this as “Site Data.”

OUR USE OF YOUR INFORMATION 

We use your information alone and in combination with non-personal information to derive insights into your movements and how you interact with the world. We do this at an aggregate level to assist in statistical studies, customize and tailor advertisements to you, and make development and infrastructure decisions. For example, we use your information to do the following: 

  • Inferences from Aggregated Data. We often use the information we collect to make inferences about human location and traffic patterns. We curate these insights into data products. We may append other fields such as venue name, category, dwell timed or ticker symbols to an aggregate group of device IDs to build consumer profiles or to make financial based decisions such as trading on the stock market based off our aggregate panel. IDs."

  • Aggregated Traffic Patterns and Research. We also share the information we receive with other marketing and research companies (including advertising platforms), who use the information to provide similar services. This helps these companies to better predict and draw insights about consumer, market or scientific trends related to human movement patterns. This same information may also be licensed to real estate, city planners or smart city companies and augmented with fields to create more specific segments. For example if an aggregate group of devices drive vs walk to determine whether to put a bus stop in an area or not or to understand the flow of traffic overtime to determine whether to purchase or not purchase a piece of real estate.

We do sell your personal information to other parties, both alone as a data feed to fuel their services but also as part of the services we provide to our customers. If you do not want your data to be shared or sold to our customers, please review the Your Rights section below to take action. 

WHO WE SHARE YOUR INFORMATION WITH

In general, we use the following data storage and hosting companies to help manage your personal information: 

  • AWS

  • Snowflake

We share the data and information we compile about someone in an aggregated or anonymized way using advertising IDs or another type of anonymous identifier:

  • to display and optimize advertisements (like improving the relevancy of the advertisements displayed, tailoring them to certain interests, or creating audiences

  • for measurement, statistics, usage reporting, and other data analytics, and

  • for industry analysis, demographic profiling, market research and other such purposes.

The above list isn’t exhaustive and our customers may make additional uses of your information in similar fashion We review each partnership to ensure it doesn’t violate the uses we agree to provide our services and your data for as set forth above. 

We share your information with these types of companies, including customers: 

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in order to provide our clients with a product or service;

  • analytics and search engine providers that assist us in the improvement and optimization of the Service.

We may disclose your personal information to third parties:

  • If we enter into negotiations to buy, sell, or merge with any business or assets, or if we enter into bankruptcy, reorganization, or receivership, in which case we may disclose your personal information to the prospective or eventual seller or buyer of such business or assets; 

  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in the event of an emergency, or in order to enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of Irys, our customers, clients or others; and


  • To any other third party not covered in this policy with your prior consent.

ADVERTISING COMPLIANCE

You can stop receiving marketing or other commercial messages from us by checking certain boxes on the forms we use to collect your information or by clicking "unsubscribe" on the emails you receive. You can also exercise this right at any time by contacting us at privacy@irys.us.

DO NOT TRACK

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether you intend for these signals to be transmitted, or whether you even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.

CHILDREN

We do not knowingly collect or use the information of minors under the age of 18. If you are a parent of a minor whose information we have inadvertently collected or had shared with us and you wish to remove their information from our systems and services, please contact us using the contact information below. 

SECURITY

We implement commercially reasonable technical and administrative controls and measures to ensure the safety of your information. When we receive or share your information, all transfers are encrypted and secured. While we have implemented a security program to protect your information, no system is completely secure and we cannot fully guarantee the security of your information. 

YOUR RIGHTS

Depending on where you live, you have the following rights: 

  • To Access Your Information

  • To Download a Copy of Your Information

  • To Delete Your Information

  • To Correct Your Information 

  • To Restrict the Processing of Your Information

  • To Opt out of the Sale of Your Information 

  • To Opt out of the Sharing of Your Information

  • To Appeal and Lodge a Complaint with the authorities

To exercise any of the above rights, please contact us using the following contact information: 

  • Send an email to: privacy@irys.us 

  • Send a letter to: Irys, Inc., Attn: Privacy, 244 5th Ave, Suite 238, New York, NY 10001 

Additionally, to exercise your right to opt out of the sale of your information you may use the link titled “Do Not Sell My Personal Information” in the footer of any page on this site. You may also use these opt out mechanisms to opt out of the sale or sharing of your personal information. 

All requests for Access, Download, Deletion, and Correction must be verified to ensure we don’t share your information with an unauthorized individual. When you contact us, we will ask you for additional information to verify your identity and, if necessary, your authority to act on behalf of another. In order to verify your identity, we will ask you to provide us the following: 

  • Your device’s advertising identifier (To find your AAID, click here. To find your IDFA, click here.)

  • A utility bill or similar documentation showing your address (we use this to confirm your identity by correlating it to our location data)

You may use an authorized agent. We reserve the right to require evidence of authorization, such as a power of attorney. 

We will never discriminate against you or charge you for exercising your rights. If you exercise the right to delete your information, we may retain some information to help us comply with the law and ensure we continue to respect your rights with by removing you from any data we receive from data suppliers in the future. 

If you have any other request you wish to submit to us, you may submit a general information request here.

STORAGE AND TRANSFER OF INFORMATION

We operate the Services in and from a number of different jurisdictions, but the Site is primarily operated from the United States, which is where your information will likely be stored and processed. Your information may be disclosed in response to inquiries or requests from government authorities or to respond to legal process in the countries in which we operate and/or store your information. We will make all reasonable efforts to require a warrant, subpoena, or similar legal documentation for disclosing data and will inform you of the request prior to the request if we are able to do so. 

DATA RETENTION

We generally retain  mobile advertising IDs on the following schedule:  (a) we render mobile advertising IDs inactive for interest-based advertising purposes within 120 days, (b) we continue to use mobile advertising IDs for analytics purposes and other purposes unrelated to interest-based advertising and reporting for up to 24 months provided that we may retain them if we have a legal or significant operational or legal need to do so, such as for auditing, corporate record-keeping, compliance, record-keeping, accounting or security and bug-prevention purposes. We do retain an archive of your information for 5 years. We may use archival information for long term studies and statistics but we will respect your privacy rights by filtering you out of those studies and statistics, including any sale or sharing of your information to third parties if we use that archival information.  

ADDITIONAL EU DISCLOSURES

Our lawful basis for processing your information is: 

  • Consent, which we obtain as detailed above from our data suppliers;

  • Our Legitimate Interest, for example when we process your information to ensure the safety and security of our processes and systems; 

  • Vital interests if we sell or share our services and/or your information to certain customers for certain studies (e.g. urban planning, Covid-19, etc.); or 

  • To comply with our legal obligations and resolve disputes. 

You may revoke your consent at any time by reaching out to using the contact information in Your Rights above. 

If you have any questions about Irys’s data practices in the context of the GDPR, you may contact our Data Protection Officer at Privacy@irys.us.

We do transfer your data outside of the EEA. In some cases, we have already received your information from one of our data suppliers. We enter into the European Standard Contractual Clauses with all of our customers, vendors, and other service providers for your information to ensure we are complying with the GDPR. 

When we receive your information directly from you, from our Sites, or from a data supplier, Irys operates as a controller and/or business (as defined by applicable laws). When Irys receives your information from a customer who asks us to perform certain analytics services on that information, Irys acts as a data processor and/or service provider (also as defined by applicable laws). 

CHANGES TO PRIVACY POLICY

If we make material changes to this Privacy Policy that may impact you, we will prominently post notice of the change on our website for a period of at least 30 days prior to the change becoming effective. We recommend that you check the Privacy Policy frequently so that you are informed of any changes.

CONTACT IRYS

If you have any questions regarding our Privacy Policy or our privacy practices, or about Irys generally, you can contact us by email at privacy@Irys.us or via regular mail at the following address:

Irys, Inc.,
Attn: Privacy
244 5th Ave, Suite 238
New York, NY 10001