At Iridium, Inc. ("we" or "us"), your ("you" or "your") privacy is of utmost importance to us, and we are dedicated to safeguarding it through adherence to this Privacy Policy. This policy outlines how we gather, utilize, maintain, protect, and disclose information collected from you or provided by you when visiting our website, www.iridiumconsultingcompany.com (the "Site"), or utilizing any of our products, services, and applications made available periodically (collectively, the "Services").

Please carefully review this Privacy Policy to comprehend our policies and practices concerning your information and how we will handle it. By accessing or using the Services, you agree to this Privacy Policy. If you disagree with our policies and practices, your option is to refrain from using the Services.

We continually strive to enhance the Services for your benefit; therefore, this Privacy Policy may be updated periodically. We will modify the "Effective Date" at the top of this page, allowing you to identify any changes since your last visit. We will also notify you of significant changes through a pop-up notice on the Services, via email, or other reasonable means. By continuing to use the Services after any modifications to this Privacy Policy, you agree to be bound by the revised policy. If you disagree with any changes, you will regrettably no longer be able to use the Services.

This policy outlines the personal data we may collect, how we process and safeguard that data, and the legal grounds for such processing. In most instances, the legal basis for processing will be either: (i) necessary for our legitimate business interests, such as growing and improving our Services, as long as they do not outweigh your rights and interests ("Legitimate Interests"), (ii) necessary to fulfill a contract with you ("Contract"), or (iii) required by legal obligation ("Legal Obligation"). When processing is based on your consent ("Consent"), we will identify the processing purposes and provide relevant information to ensure fair and transparent processing.

We collect two types of information from you: personally identifiable information, including your name, phone number, employment information (e.g., work address, employment status, title), and email, as well as any voluntarily provided information like a description of your work-related issues and challenges, and demographic information such as age, gender, and race ("Personal Information"), and non-personally identifiable information (information that cannot be used to identify you) ("Non-Personal Information"). The following sections detail the various methods through which we may collect Personal Information and Non-Personal Information.

Automated Information Collection: Our Services may employ technology such as "pixel tags," "web beacons," and "cookies" to automatically track users' actions. These tracking tools collect Non-Personal Information like browser information, access time to the Services, usage details, website addresses linking you to our Site, websites visited after using our Services, and email opening status. We may also collect information about your mobile device when using our mobile application or accessing the Services from your mobile device, including device identifier, location, operating system, browser type, IP address, and mobile network information. We will not access metadata or other information stored on your mobile device.

Third-Party Analytics: We may utilize third-party analytics, such as Hubspot, Google Analytics, Meta, and other ("Analytics Services"), to collect data through cookies and anonymous identifiers. We do not merge Personal Information with previously collected Non-Personal Information through these Analytics Services. Collected data will be used according to this Privacy Policy and the privacy policies of the third-party service providers.

Third-Party Information Collection: When using our Services, certain third parties such as device manufacturers, platform providers, and advertisers may employ cookies or other automated information collection technologies to gather information, including Personal Information, about you, your online activities over time, across various websites, apps, or other online services, or concerning your device. We have no control over these third parties' tracking technologies or their usage. If you have inquiries about an advertisement or other targeted content, we advise reviewing the privacy policies of the respective service providers or contacting them directly.

Voluntarily Provided Information: If you reach out to us via phone, email, social media, or other methods, we may retain your contact information (including your name, company name, email address, and phone number) along with voice recordings or written correspondence for future reference. Additionally, we may maintain records of any registration forms, surveys, or questionnaires you voluntarily complete on our Site, in person, or through the use of our Services.

Consulting Sessions: Should you participate in a consulting "Helps" session with one of our professionals (a "Consultant") over the phone or communicate with them through text, email, or other means, we may record and transcribe these phone calls and maintain a record of the written exchanges for quality assurance purposes.

Public Posts: If you share information in public areas of the Services (e.g., comments or blogs), this information is visible to and may be collected, stored, and used by others. We advise exercising caution when disclosing Personal Information to others or sharing it in public or online forums. We are not responsible for the actions of any third parties with whom you share Personal Information.

We may employ the information we collect about you or receive from you, including Personal Information, to gauge the usage of our Services, analyze their effectiveness, enhance their functionality, tailor the Services to your preferences, develop new products and services, provide support for our Services, respond to inquiries and requests, send you notifications through email, text, or other communication methods (such as updates or alterations to our Services), and promote the Services via marketing emails.

Occasionally, we may aggregate some of your Personal Information for data analysis, reports, or other interpretations of investment trends for both internal and external purposes.

If we plan to use any Personal Information in a manner inconsistent with this Privacy Policy, we will inform you of such anticipated use before or during the collection of your Personal Information.

We take privacy very seriously and will not sell, rent, or trade your Personal Information to any third parties. We will only disclose your Personal Information to service providers, such as vendors, technical agents, subcontractors, and consultants, as needed to provide the Services described. These providers help enable the Services and our offerings to be available and functional (e.g., website hosting, maintenance, user experience improvements, email delivery services, and texting and other communication services). We contractually require these third-party service providers to maintain the confidentiality of the information we share with them and not to use your information for any purpose other than providing services on our behalf.

Generally, we will not grant your employers access to your information. However, we reserve the right to disclose your information if we, at our sole discretion, deem it ethically necessary to prevent harm to you or a third party. In such limited cases, we will only disclose the portion of information that we determine is absolutely required to prevent any harm.

We will not disclose your information to a government body or any other third party unless legally mandated by a valid court order, another legal order, or a criminal or civil subpoena.

In addition to the disclosures for the purposes mentioned above, we may share your Personal Information and Non-Personal Information with a buyer or successor in cases of a merger, acquisition, change of control, or other similar business transfers, or with your explicit prior written consent.

We may share aggregated user statistics and other data with our clients (which may include your employer), affiliates, agents, and current or prospective business partners while always striving to protect your privacy and ensuring that this aggregate information does not personally identify you.

We aim to offer you choices about our collection, use, and disclosure of the information you share with us. The mechanisms listed below are designed to give you control over these processes:

Marketing Communication: If you prefer not to receive marketing or promotional communications, you can opt out by following the unsubscribe link in any such promotional email. Note that we cannot remove your information from the databases of third parties with whom you have previously authorized us to share your information. Be aware that we may still send you important administrative messages.

Voice and Text Communications: To stop receiving phone calls or text messages, please email us at info@iridiumconsultingcompany.com.

Cookies: You can accept or disable cookies at any time through your browser settings. You can refuse to accept browser cookies by activating the appropriate setting on your browser or activating the corresponding settings in your smartphone. Flash cookies are managed differently from browser cookies. For details on managing your privacy and security settings for Flash cookies, visit http://kb2.adobe.com/cps/526/52697ee8.html. Disabling cookies may result in a limited user experience.

Google Analytics: Opt-out of tracking by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.

Do Not Track Signals: Third parties may monitor your browsing activities across different websites. Some web browsers allow users to enable a "Do Not Track" signal, but we currently do not respond to such signals or similar mechanisms.

Notice to California Residents: California's "Shine The Light" law (California Civil Code Section 1798.83) allows users who are California residents to request and receive, free of charge and once a year, information about categories of personal information (if any) that we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties we shared personal information with in the previous calendar year. If you are a California resident and would like to make such a request, please submit it in writing using the contact information provided below.

For any other changes or information about our collection, use, or disclosure of your information, please email us at info@iridiumconsultingcompany.com.

To access, update, correct, or delete any Personal Information in our possession that you have previously submitted via the Services, please contact us at hello@workbravely.com.

Keep in mind that we are not responsible for storing any information or content you provide to us or a Consultant or any content or information we or a Consultant provide to you. You are solely responsible for retaining backup files of any information and content you provide or receive in connection with the Services.

This Privacy Policy applies solely to the Services. The Services may contain links to other websites that are not operated or controlled by us. The policies and procedures outlined in this Privacy Policy do not apply to those third-party sites, even if you access them via the Services. The links from the Services do not imply our endorsement or review of the third-party sites. We recommend that you carefully review the privacy policies of any third-party sites you visit to understand how they collect, use, and share your information.

We aim to retain your information only as long as necessary for legitimate business purposes and in compliance with applicable legal requirements. If you close your account, we will keep certain data for analytical purposes, recordkeeping integrity, fraud prevention, enforcement of our Terms of Use, protection of the Services' integrity or our users, or other actions permitted by law. Additionally, if specific information has already been shared with third parties as described in this Privacy Policy, the retention of that information will be subject to those third parties' policies.

Our Services are designed for users who are 18 years of age or older. If you are under 13, you are not allowed to submit any Personal Information to us. If you think we might have any information from or about a child under 13, please contact us at info@iridiumconsultingcompany.com.

The Company complies with the EU-U.S. Privacy Shield Framework set by the U.S. Department of Commerce, which pertains to the collection, use, and retention of personal information from Individual Customers in European Union member countries. The Company has certified its adherence to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement, and liability. As part of Privacy Shield compliance, the Company falls under the investigatory and enforcement powers of the Federal Trade Commission (FTC). The Company also commits to cooperating with European Union data protection authorities and complying with advice given by such authorities regarding human resources data transferred from the European Union in the context of employment relationships. In cases of conflict between this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall prevail. To learn more about the Privacy Shield program and view our certification page, visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, the Company is committed to resolving complaints about our collection or use of your personal information. If you have inquiries or complaints regarding our Privacy Shield policy, please contact us at info@iridiumconsultingcompany.com.

The Company has pledged to refer unresolved Privacy Shield complaints to ICDR/AAA, an alternative dispute resolution provider based in the United States. Under certain conditions, you may be permitted to invoke binding arbitration. If you do not receive a timely acknowledgment of your complaint from us, or if we have not addressed your complaint satisfactorily, please contact or visit https://www.adr.org/aaawebfile for more information or to file a complaint. ICDR/AAA's services are provided at no cost to you.

In cases of onward transfer, we are responsible for the processing of personal information we receive under the Privacy Shield and subsequently transfer to a third party acting as our agent. The Company remains liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the event causing the damage.

Personal Information collected through the Services may be stored and processed in the United States or any other country where Iridium, its subsidiaries, affiliates, or service providers maintain facilities. If you are located in the European Union or other jurisdictions with data collection laws differing from U.S. law, you acknowledge that we may transfer Personal Information to a country or jurisdiction with different data protection laws than your country of residence. You expressly consent to the transfer of information, including Personal Information, to the United States or any other country where Iridium or its subsidiaries, affiliates, or service providers maintain facilities.

We take reasonable measures to protect the Personal Information provided to us from loss, misuse, unauthorized access, disclosure, alteration, or destruction, and the Personal Information we collect is secured behind a firewall. However, no Internet or email transmission is completely secure or error-free. In particular, email sent to or from the Services may not be secure. Therefore, exercise caution when deciding what information you send to us via email. Keep this in mind when disclosing any Personal Information to us via the Internet.

We use Hubspot, RingCentral, and Zoom to make and receive phone calls, text messages, and video calls and record these communications. For additional information on how Hubspot secures your personal information, please refer to Hubspot’s privacy policy located here. For additional information on how RingCentral secures your personal information, please refer to RingCentral’s privacy policy located here. For additional information on how Zoom secures your personal information, please refer to Zoom’s privacy policy located here.

The General Data Protection Regulation (GDPR) grants certain rights to individuals in the European Union concerning their personal data. As available and except as limited under applicable law, individuals' rights include:

• Right of Access – the right to be informed of and request access to the personal data we process about you;
• Right to Rectification – the right to request that we amend or update your personal data if it is inaccurate or incomplete;
• Right to Erasure – the right to request that we delete your personal data;
• Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to Object:
  • The right to object to us processing your personal data on grounds relating to your particular situation at any time;
  • The right to object to your personal data being processed for direct marketing purposes;
• Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to Automated Decision-making – the right not to be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

To exercise any of the above rights, please contact us at info@iridiumconsultingcompany.com.

If you have any questions about this Privacy Policy, please contact us at info@iridiumconsultingcompany.com.