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Privacy Policy

Effective Date: April 1st, 2026

Last Modified: March 16th, 2026

Iron Horse Ventures LLC dba Iron Horse (“Iron Horse,” “we,” or “us”) is a growth marketing agency headquartered in California. This Privacy Policy describes how we collect, use, and process personal information when you interact with us, including when you visit www.ironhorse.io (the “Site”) or any other website or online service that displays this Policy, view our online advertising, or attend events we host.

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This Privacy Policy does not apply to any website owned or operated by a third party, including websites belonging to our service providers or marketing partners, even if we provide a link to or if it is accessible from or through our website. Please review those sites’ privacy policies directly.

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This Policy applies to our direct interactions with you as a website visitor or third-party contact, including business contacts we have identified through third-party data providers and contacted as part of our outreach. It does not govern data we process on behalf of our clients, which is subject to separate agreements between Iron Horse and those clients. Similarly, our relationships with clients, prospective clients, employees, contractors, and prospective employees are governed by separate agreements that address data collection and use in those contexts. If you fall into any of those categories and have questions about your data rights, please refer to your agreement with us. If you are an individual whose data we process on a client’s behalf, please contact that client directly regarding their data practices.

How we collect information

We use the term “personal information” to describe information that can reasonably be associated with you and used to identify you. Personal information does not include information that has been de-identified or aggregated. We collect and receive personal information through the following methods:

Sources of collection

  • Personal information you provide to us. You may give us your personal information directly, for example, when you contact us with inquiries, complete forms on our Site, subscribe to receive our marketing communications, register for or attend webinars or events we host, apply for a position with us, or provide feedback to us.
  • Personal information we collect automatically. When you access and use our Site, we may collect technical data and usage data automatically, including through our use of cookies and other similar technologies. For more information, please see the Cookies section below.
  • Personal information we obtain from third parties. We may obtain personal information from analytics providers, data suppliers, third-party directories, event partners, social networks, and other technology providers (for instance, when you interact with our ads on platforms such as Google or Meta). This includes business contact information obtained from B2B data providers, which we may use to identify and contact individuals who may be interested in our services. If we contact you using information sourced this way, you may opt out or request deletion of your record using the methods described under “Privacy Preferences, Rights and Choices.”
  • Personal information from public sources. We may collect personal information that is publicly available, such as from websites, social media platforms, or public events.‍
  • Recordings and transcripts of meetings. If you participate in a webinar, sales call, or other virtual meeting with Iron Horse, the session may be recorded and transcribed using the meeting tool. We will notify participants of recording at the start of the session, and you may decline by leaving the meeting or asking us to disable recording.

Types of information we collect

  • Identity Data. Name (first, middle, and last) and title.
  • Contact Data. Email address, telephone number, social media handle, and postal/delivery address.
  • ‍Communications Data. Correspondence or messages including form submissions, surveys, emails, SMS, chat, or social media messages; the nature of your inquiry; and other personal information you choose to provide.
  • ‍Professional Data. Job title and organization you represent.
  • ‍Usage Data. Browsing activity on our Site, interaction with our emails and ads, pageviews and events, referring URLs, session data, and advertising identifiers associated with your device.
  • ‍Technical Data. IP address, full web page URL, browser type, device type, operating system, approximate or precise geolocation derived from IP address, unique device or browser identifiers, and cookie identifiers.
  • ‍Advertising Partner Data. Information independently collected by our advertising partners, which may include unique identifiers and inferred interest profiles built from activity observed across websites and apps that use their services.
  • ‍Marketing Data. Marketing and service communication preferences.

How we may use your information

We may collect, use, disclose, and otherwise process personal information for the following purposes:

  • Services and Support. To operate our Site, respond to your inquiries, provide troubleshooting and technical support, and fulfill your requests for services.
  • ‍Analytics and Improvement. To understand how users access and use the Site, evaluate and develop our services and business operations, and for internal quality control and training purposes.
  • ‍Communication. To respond to your questions, send requested materials and newsletters, and provide administrative information such as changes to our terms and policies.
  • ‍Customization and Personalization. To tailor content we send or display on the Site or in connection with our services.
  • ‍Marketing and Advertising. To send promotional information about our services and to target advertising based on geographic or other information we have collected, so that ads shown to you are relevant to your interests. Except where consent is required, we conduct marketing on the basis of our legitimate business interests. Where we seek your consent, you may withdraw it at any time.
  • ‍Research and Surveys. To administer surveys and questionnaires for market research or user satisfaction purposes.
  • ‍Fraud Prevention and Security. To protect against, identify, investigate, and respond to fraud, illegal activity, hacking, misuse of our websites, and other liabilities.
  • ‍Legal Compliance. To comply with legal requirements, judicial process, and our company policies, including to verify users’ identity in connection with access or correction requests.
  • Recruitment. To process employment applications and monitor recruiting statistics to inform our recruitment activities.
  • ‍General Business Operations. To administer our business, accounting, finance, auditing, compliance, recordkeeping, legal, and human resources functions.
  • ‍Aggregated and De-identified Data. We may aggregate or de-identify information so that it no longer identifies any specific individual, and use such information for lawful business purposes.

With whom we may share information we collect

We will not share your personal information with others except as described below, or when we inform you in advance. We may share personal information with:

  • Service Providers. Third parties perform services on our behalf, such as technology providers, payment processors, payroll providers, employee benefits portal providers, web hosting providers, email service providers, demand generation partners, and meeting and transcription tools. Some of these service providers offer AI-enabled features as part of their services. These parties are subject to contractual obligations to keep your information confidential and use it only for the purposes for which it was disclosed. A current list of categories of service providers and key vendors who process personal information on our behalf is available on request.
  • ‍Advertising and Marketing Partners. Partners such as Google, Meta, and LinkedIn, which may use cookies and similar technologies to track activity across websites for advertising purposes.
  • ‍Analytics Organizations. Third-party analytics providers that help us understand how our Site is used.
  • ‍Business Transfers. In connection with a merger, acquisition, sale of assets, financing, or restructuring, we may transfer your information to a successor entity. We may also share certain information with lenders, auditors, and advisors as part of due diligence.
  • ‍Legal and Compliance. To comply with legal and regulatory requirements, respond to court orders, subpoenas, or government requests, and to protect against fraud, illegal activity, and other liabilities, and to protect the rights, property, and safety of Iron Horse and others.
  • ‍Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.

Cookies, tracking technologies, and advertising choices

We use cookies, pixel tags, local storage, and similar technologies to automatically collect browsing, activity, and device information on our Site. We may also engage third-party providers such as Google Analytics to do the same. We use this information to analyze how visitors interact with our Site, optimize performance, conduct marketing and analytics, and personalize content.

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Cookies are small identifiers stored on your device that help us recognize you, support Site security and performance, and track usage. Pixel tags are tiny graphics embedded in web pages and emails that allow us to measure opens, clicks, and forwarding. Local storage lets us cache data in your browser for faster page loading on return visits.

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We honor the Global Privacy Control (“GPC”) opt-out preference signal as an opt-out of the sale or sharing of personal information for California residents, as required under the CPRA. You can also opt out of targeted advertising through the Network Advertising Initiative (www.networkadvertising.org/choices), the Digital Advertising Alliance (www.aboutads.info/choices), or for European users, the European Interactive Digital Advertising Alliance (www.youronlinechoices.eu). Some partners offer their own opt-out mechanisms and may not participate in the programs above. You can additionally disable cookies through your browser settings, though doing so may affect Site functionality.

Careers

If you apply for a role with us, we collect and use the information you submit, including resume content and any voluntarily provided information, to evaluate your candidacy, contact your references and former employers, and fulfill related legal obligations. We process this data based on our legitimate interest in recruiting or, for sensitive information, your consent. We may also disclose this information as required by applicable law and our company policies. Applications are submitted through our third-party applicant tracking system; please review that provider’s privacy policy for information about how your data is handled during submission.

Privacy preferences, rights and choices

Personal information requests

Depending on your location and the nature of your interactions with our services, you may request the following in relation to your personal information:

  • Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
  • Access to a copy of the personal information we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.
  • Correction of personal information that is inaccurate or out of date.
  • ‍Deletion of personal information that we no longer need to provide our services or for other lawful purposes.
  • ‍Object to and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent.
  • Complaint. You may have the right to lodge a complaint with the data protection authority in your jurisdiction.

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To submit a Request to Delete or Request to Correct, contact us using one of the following methods:

  • Email: info@ironhorse.io with the subject line "Privacy Request"
  • ‍We will verify your identity before processing your request and may ask you to provide information that matches what we have on file. We will respond to verified requests within 45 calendar days. If we need additional time, we will notify you in writing within that initial 45-day period. We do not charge a fee unless a request is excessive, repetitive, or manifestly unfounded.
  • Depending on your jurisdiction, you may designate an authorized agent to submit a request on your behalf. We will require written authorization confirming that authority. We will not discriminate against you for exercising any of these rights.

Your choice to provide personal information

Various parts of our Site offer you the opportunity to provide information to us. If you choose not to provide personal information when requested (for example, in a form submission or inquiry), it may limit your ability to interact with certain features of the Site.

Marketing emails

You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. Even if you opt out of marketing communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).

International data transfers

We may transfer personal information to countries other than the country in which the data was originally collected. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where we are headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.

Security

We take appropriate physical, electronic, and other security measures to help safeguard personal information from accidental, unlawful, or unauthorized access, alteration, disclosure, use, loss, or destruction.

Data retention

We retain personal information for no longer than is reasonably necessary to fulfill the purpose(s) for which it was collected. The criteria we use to determine retention periods include: (a) the purpose(s) for which the information is used; (b) the type and sensitivity of the information; (c) contractual obligations governing the data; and (d) applicable legal, regulatory, or statutory requirements, including statutes of limitations. We will then destroy or anonymize the personal information in accordance with applicable law. A more detailed breakdown of our retention practices by data category is available upon request.

Children's privacy

Our website and services are designed for business professionals and are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent, as required by the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe we have collected information from a child under 13, please contact us at info@ironhorse.io and we will promptly delete such information.

California privacy rights

This section supplements the rest of this Privacy Policy and applies solely to California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”). We also do not knowingly sell or share the personal information of consumers we know to be under 16 without their affirmative opt-in consent (or, for consumers under 13, parental consent).

Categories of personal information collected

In the preceding 12 months, we have collected the following categories of personal information from California residents: (a) Identifiers (name, email address, IP address, phone number); (b) Internet or electronic network activity (browsing behavior and device data collected via cookies); (c) Approximate geolocation data; (d) Professional or employment-related information (job title, employer name); (e) Employment-related information collected from job applicants (credentials, work history, references); (f) Audio and visual information (recordings and transcripts of webinars, sales calls, and virtual meetings); (g) Sensitive personal information (voluntarily provided demographic information from job applicants); and (h) Inferences drawn from the above (including lead and engagement scores). We collect these categories for the business purposes described in “How We May Use Your Information” and disclose them to the parties described in “With Whom We May Share Information We Collect.”

Sale or sharing of personal information

We do not sell personal information. We may share personal information with third-party advertising partners (such as Google, Meta, and LinkedIn) for cross-context behavioral advertising. California residents may opt out of such sharing by clicking the “Do Not Sell or Share My Personal Information” link in the footer of our website, by visiting “Your Privacy Choices,” or by enabling a Global Privacy Control (GPC) signal in their browser. We will honor GPC signals as required under CPRA §1798.135.

California-specific privacy rights

In addition to the rights described in “Privacy Preferences, Rights and Choices” above, California residents have the following additional rights under the CPRA:

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Opt out of the sale or sharing of your personal information, including for cross-context behavioral advertising (“interest-based advertising”). To exercise this right, click the “Do Not Sell or Share My Personal Information” link in the footer of our website, visit “Your Privacy Choices,” enable a GPC signal in your browser, or contact us at info@ironhorse.io.

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Limit the use or disclosure of your sensitive personal information, to the extent we collect sensitive personal information as defined under the CPRA (such as precise geolocation data, racial or ethnic origin, or financial account details). To exercise this right, click the “Limit the Use of My Sensitive Personal Information” link in the footer of our website or contact us at info@ironhorse.io.

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Appeal a decision we make regarding your request. If we deny your request, you may appeal by contacting us at info@ironhorse.io with the subject line “Privacy Request Appeal” and describing the basis for your appeal. We will review your appeal and respond within 45 calendar days. If you remain unsatisfied after our review, you may contact the California Privacy Protection Agency (CPPA) at: https://cppa.ca.gov.

Residents of other U.S. states

If you are a resident of a U.S. state with a general consumer privacy law (for example, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, or another state with similar legislation), you have rights analogous to those described above for California residents, including the right to access, correct, delete, and obtain a portable copy of your personal information; the right to opt out of targeted advertising, sale of personal information, and (where applicable) profiling that produces significant effects on you; and the right to appeal a denial of your request. Specific rights, response timelines, and verification requirements vary by state and we will apply the standard required by your state of residence. To exercise any of these rights, contact us at info@ironhorse.io.

EU/EEA and UK residents

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), the General Data Protection Regulation (“GDPR”) or UK GDPR applies to our processing of your personal information. We process your personal data on the following legal bases: (a) your consent; (b) performance of a contract with you; (c) compliance with a legal obligation; or (d) our legitimate business interests (such as improving our services and preventing fraud), where those interests are not overridden by your data-protection rights.

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In addition to the rights described in “Privacy Preferences, Rights and Choices” above, EEA and UK residents have the right to lodge a complaint with their local data protection authority (“DPA”). A list of EU DPAs is available at https://edpb.europa.eu. The UK’s supervisory authority is the Information Commissioner’s Office (ICO) at https://ico.org.uk. We rely on Standard Contractual Clauses approved by the European Commission as the mechanism for international transfers of personal data from the EEA to countries not deemed adequate by the European Commission.

Governing law

This Privacy Policy is governed by and constructed in accordance with the laws of the State of California, without regard to its conflict of law principles.

Changes to our privacy policy

We reserve the right to change this Privacy Policy at any time. We will post any updates to this Privacy Policy on this page along with an updated “Last Modified” date at the top. If we make material changes to how we handle personal information, we will post a clear notice on our website and, where required by applicable law, notify you directly. We encourage you to review this page periodically for the most current version. Continued use of our website following notice of changes does not waive your rights under applicable privacy law.

How to contact us

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

  • Iron Horse Ventures LLC dba Iron Horse
  • 11040 E Bollinger Canyon Road, Suite E861
  • San Ramon, CA 94582
  • Email: info@ironhorse.io
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