Privacy Policy

Effective Date of Current Policy: October 17, 2019

The iGAM marketplace, an operation of NRTC Alabama, Inc., (referred to herein as “iGAM” “we” or “us”) provides this Privacy Policy to let you know our policies and procedures regarding the collection, use and disclosure of information through www.iGAM.com (the “Site”) as well as any information we collect offline in connection with the Site. This Privacy Policy applies to information collected from the effective date forward; information collected while a previous Privacy Policy was in effect remains subject to the terms of that former policy.

We may change this Privacy Policy at any time by posting the revised Privacy Policy on this website and indicating its effective date. Please check back frequently. We may also notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your iGAM account or by placing a prominent notice via the iGAM.com web site.

By accessing or using the Site, you consent to the information collection, disclosure and use practices described in this Privacy Policy.

Types of Personal Information We Collect and How We Use It

The types of personal information we may collect and how we collect and use it depends on the nature of the relationship you have with iGAM and the requirements of applicable law. iGAM collects personal information from its current, prospective, and former clients, customers, users, visitors, and guests (collectively “you”, “your” or “Individuals”).

Information You Provide Directly to Us

We collect personal information when you use our services, enter into an agreement to buy or sell items, create a new iGAM account, request logistics services, provide us with information via a web form, add or update information in your iGAM account, request information about our services and products, fill out surveys, feedback forms, participate in online discussions or public forums or communities, or otherwise interact with us. We collect your information when you use our Site by way of:

cookies, web beacons, unique identifiers and similar technologies to collect information about the pages you view, links you click, and other actions you take when using our services or within our advertising or email content (see more information about how we use cookies and similar technologies below)
web server logs and other means to record connection information (such as statistics on your page views, traffic to and from sites, referral URLs, IP addresses, web log information, device information and where your setting permit, location information)

Examples of personal information include name, email address, postal address, shipping address, phone number, and activity history on our Site. If you use the Site to make purchases, we may also collect certain payment information, such as payment card, PayPal or other financial account information, and billing address. A third-party payment processor collects that information; we do not store your credit card information.

We also may collect other information, such as ZIP codes, and other information regarding your use of the Site (“Non-Identifying Information”) or from you in response to surveys. Certain Non-Identifying Information would be considered a part of your personal information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). We may combine your personal information with Non-Identifying Information, but iGAM will treat the combined information as personal information.

Information Received from Third Parties

We also may receive information about you from third parties. For example, we may supplement the information we collect with outside records, or third parties may provide information in connection with a co-marketing agreement or at your request. If we combine the information we receive from others with personal information we collect through the Site, we will treat the combined information as personal information as described in this Privacy Policy.

How iGAM uses Your Information and the Basis for Use

We acquire, hold, use and process personal information about Individuals for a variety of business purposes. Depending on the preferences you’ve communicated to us, we may communicate with you by email, phone or regular mail. These purposes include the following which are necessary to provide you services, take steps at your request, to comply with our legal obligations, protect vital interests, or as may be required in the public interest. Specific activities include to:

Collect and pay fees or money owed, or otherwise process payments
Provide customer service
Provide the services requested or contracted for by you
Process applications for services
Approve and monitor applicable limits, detect, suppress or take other actions regarding suspected illegal activities, identity verification, suspected fraud, or a violation of our account terms and conditions, our policies or agreements
Provide you log-in access to our websites and mobile apps
Work with third party partners to provide you with value-added services requested
Enforce our contracts, terms and conditions, User Privacy Notice and other rules and policies.
Enable the delivery of purchased items by logistics/shipping service providers including notifications in connection with the delivery (such as tracking information), the latter to the extent permitted by applicable law without your consent.
Process general location data (such as IP address or postal code) in order to provide you with location-based services (such as radius search and other content that is personalized on the basis of your general location data)
Prevent, detect, mitigate and investigate unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

These purposes also include pursuing our legitimate interest (or our common legitimate interests with a third party) where your rights and freedoms do not outweigh these interests. This includes (subject to your communication preferences in your iGAM account where applicable):

Deliver relevant content and advertising and tailored user experience and content on the website based on the actions you take
Advertisements by mail or email
To the extent permitted by applicable law without your consent, communications with you via electronic mail (e.g. email) or telephone to offer you special offers, conduct opinion polls and surveys and otherwise inform you of our services
Notifications regarding promotions and information about our services after logging into your account
Improve our services and website
Understand the market and develop new products, services or features
Monitor and improve the security of our sites and apps
Analysis of telephone conversations with our customer service that we recorded with your consent when required by law
Evaluation of the quality and success of our email marketing campaigns (e.g. through analysis of opening and click rates)
Assessment of the service status on the basis of tracking or other information
Offering of partner and bonus programs
Provision of shared content and services with NRTC Alabama, Inc. corporate family members
Monitoring and improvement of the information security of our services, unless there is a statutory obligation to this effect.
Performance of identity checks, creditworthiness and other financial standing checks, evaluation of applications and comparison of information for accuracy and verification purposes.
Automatic filtering and, where necessary, manual review of messages sent through our messaging tools to prevent fraudulent or suspicious activity or violations of our contract, terms and conditions or other rules or policies
Improve our services
Understand the market and develop new products, services or features
Contact you for feedback or to fill out occasional surveys to help us monitor our performance and improve our service offering (if you provide us with the feedback, we can use your remarks, suggestions, writings or comments from surveys or other feedback mechanisms as we so determine without your further consent and without compensation or any other interests or rights, however we won’t identify you in association with feedback without your prior permission)
Monitor and improve the security of our website

Certain purposes are with your consent. These include to:

Keep you informed about sales events and other offers by email or regular mail
Provide you with marketing about the iGAM services
Use your precise geo-location in our apps to provide location-based services
Share certain limited information with unaffiliated third parties to provide you with value-added services or information about products and services you request

In pursuit of our common interests we share personal information among members of the NRTC Alabama, Inc. corporate family for purposes consistent with this User Privacy Notice. Where permitted by law, you may receive promotional and other communications from these related family members.

We in our legitimate interest, and in certain cases, where necessary to ensure we perform our contractual obligations with you, may use third parties to perform functions in connection with our services (for example, email marketing automation, market research, data analytics and data enhancement, fraud detection, OFAC compliance verification, customer service, site operations and hosting, systems management, accounting, auditing, billing, reconciliation, and collection activities). We may transfer limited information about you into their platforms so that we can utilize their services. If

we partner with another party to provide specific services (for example, transportation services or refurbishment services, and you request or contract for these services, we will share the contact information or other information necessary for the third party to provide the requested services. We may also disclose personal information to legal, financial, and other professional advisors and to our lenders or insurers in connection with the operation of our business where such parties have agreed to confidentiality restrictions.

We may share aggregated demographic information or other de-identified information with our trusted third party partners.

If we become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information in our legitimate interest and in certain cases, where necessary to ensure we perform our contractual obligations with you, to a third party or parties in connection with such business change.

Investigations and Law

To the extent required or permitted by applicable law, we disclose information about you to third parties to:

Comply with law, in response to subpoenas, warrants, or court orders, or in connection with any legal process or cooperate with government or law enforcement officials or private parties, including laws outside of your country of residence;
Protect our rights, reputation, safety and property, or that of our customers or others;
Protect against legal liability;
Establish or exercise our rights to defend against legal claims; or
To investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety or property of us, customers or others, violation of our account terms and conditions, our policies or agreements or as otherwise required or permitted by applicable law.

Where necessary for the purposes above, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

Other iGAM suppliers or users · NRTC Alabama, Inc. corporate family members
Third party service providers including shipping companies
When you make purchases through the services, we may process your payments through a third party application, such as a third party payment processor. In these instances, the third party application may collect certain financial information from you to Process a payment on behalf of iGAM, including your name, email address, address and other billing information in which case the use and storage of your financial information is governed by the third party app’s terms, conditions and privacy policies
External operators of websites, applications, services and tools
Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies
Third parties who are involved in judicial proceedings, in particular, if they submit a legal order, court order or equivalent legal order to us.
Credit agencies bureaus or associations, if required by applicable law (e.g. information on payment delays, payment defaults or other irregularities that may be relevant to your credit report)
Other companies in the context of a company acquisition
Other third parties with whom we partner to offer you specific services

Security

While we take reasonable administrative, technical and physical measures to protect the information you submit or that we collect online and offline against loss, theft and unauthorized use, disclosure, or modification, we cannot guarantee its absolute security. No Internet, email or mobile application transmission is ever fully secure or error free. If you believe your iGAM account has been abused, please contact us at in**@ig**.com. To the extent permitted by applicable law, you also agree that we will not be liable for access to or the use or acquisition of your information by any third party without our knowledge or consent in contravention of our safeguards. By using the services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the services. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Site or sending an email to you. You may have a legal right to receive this notice in writing.

How We Use Cookies

We, as well as third parties that provide content, advertising or other functionality may use cookies, pixel tags, local storage and other technologies to automatically collect information through your use of iGAM.com and our related services. We use technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information whenever you visit or interact with our website, services, applications, messaging and tools, and to recognize you across devices.

Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. For more information, see our Cookie Policy.

A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

The Site includes social media features such as links to Facebook, Instagram, Twitter, YouTube and LinkedIn (that might include widgets, such as, the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on the Site and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy policy of the company providing it.

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our services and to develop website content. This analytics data is not tied to any personal information

At this time, we do not respond to “Do Not Track” signals sent from web browsers.

Links to Other Websites

Our Site may contain links to other sites, including sites maintained by our third party partners for the provision of online payment services and online shipping quotes. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to read the privacy statements of all websites that collect personal information.

Choice / Opt-Out

Registered users of the Site may update their choices regarding marketing communications you receive from us through your online account. You also may opt-out of receiving marketing e-mails from us by following the opt-out instructions provided in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Site (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.

Changing your Information or Closing your Account

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information, and you must update any changes through your online account. If you would like us to delete your account in our system, you can do so by sending an email to us at: in**@iG**.com. We will use commercially reasonable efforts to honor your request; however, certain information may actively persist on the Site even if you close your account. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, such as your purchase history, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Site.

You may request details of personal information which we hold about you. A small fee will be payable. If you would like a copy of the information held on you, please email us this request at in**@iG**.com.

Children

Our services are not intended for the use by children. We do not knowingly collect personal data from users who are considered children under applicable national laws.

Data Retention

We retain the personal information we receive as described in this Privacy Policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. When we are no longer required to retain the personal information as described above, we will destroy, erase, or de-identify it. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold it.

Notice to European Union Users

If you provide information to us, the information will be transferred out of the European Union (EU) to the United States. By providing personal information to us, you are consenting to its storage and use as described herein.

Contact Us

Feel free to reach out to us by emailing us at in**@iG**.com or by regular mail using the address below:

Attn: Privacy Administrator
iGAM.com
3675 Outer Drive East
Detroit, MI 48234