WHO WE ARE

1. We are Irrigreen, Inc. located at 5250 W 73RD Street, Suite I, Edina, MN 55439. This privacy
   policy sets out how we handle your personal information if you are an Irrigreen user or visitor to our Sites and Facebook Pages. This includes our Irrigreen Homeowner Android app and our Irrigreen 2 iOS app, as well as legacy mobile applications that we no longer support.
2. When we say ‘we’, ‘us’ or ‘Irrigreen’ it is because that is who we are, and we own and run the Sites.
   
3. If we say ‘policy’ we are talking about this privacy policy.

THE TYPE OF PERSONAL INFORMATION WE COLLECT

1. We collect certain personal information about visitors and users of our Sites.
2. The most common types of information we collect include, but are not limited to: usernames,
   member names, phone numbers, email addresses, home addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as payment agent details, transnational details, tax information, support queries, forum comments, content you direct us to make available on our Sites (such as item descriptions) and web analytics data. We will also collect personal information from job applications (such as, your resume, the application form itself, cover letter and interview notes).

HOW WE COLLECT PERSONAL INFORMATION

1. We collect personal information directly when you provide it to us, automatically as you
   navigate through the Sites, or through other people when you use services associated with the Sites.
   
2. We collect your personal information when you complete membership registration and buy or
   provideitemsorservicesonourSites,subscribetoanewsletter,emaillist,submitfeedback, enter a contest, fill out a survey, or send us a communication.

PERSONAL INFORMATION WE COLLECT ABOUT YOU FROM OTHERS

Although we generally collect personal information directly from you, on occasion, w e also collect certain categories of personal information about you from other sources. In particular:

1. Financial and/or transaction details from payment providers located in the US or Canada to process a transaction.
2. Third-party service providers (such as Google, Facebook) who are in the US or Canada which may provide information about you when you link, connect, or login to your account with the third - party provider and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider.
3. Other third-party sources/ and or partners from the US or Canada whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service. We also receive in formation about you and your activities on and off the Irrigreen platform through partnerships, or about your experiences and interactions from our partner ad networks. We also receive information about you as a rights holder from our third-party authors. For example, information in the form of a model release when your image is used in an item made available on our Sites.

HOW WE USE PERSONAL INFORMATION We will use your personal information:

1. To fulfill a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Sites, like where you purchase an item or service from us.
2. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These
   interests include:

• Operating the Sites.
• Providing you with services described on the Sites.
• Verifying your identity when you sign into any of our Sites.
• Responding to support tickets and helping facilitate the resolution of any disputes.
• Updating you with operational news and information about our Sites and services e.g., to
  notify you about changes to our Sites, website disruptions or security updates .
• Carrying out technical analysis to determine how to improve the Sites and services we
  provide.
• Monitoring activity on the Sites, e.g., to identify potentially fraudulent activity and to
  ensure compliance with the user terms that apply to the Sites.
• Managing our relationship with you, e.g., by responding to your comments or queries
  submitted to us on the Sites or asking for your feedback or whether you want to
  participate in a survey.
• Managing our legal and operational affairs (including, managing risks relating to content
  and fraud matters).
• Training HSC staff about how to best serve our user community.
• Improving our products and services.
• Providing general administrative and performance functions and activities.
• Processing your job application to Irrigreen.

WHERE YOU GIVE US CONSENT

1. Providing you with marketing information about products and services which we feel may interest
   you.
2. Customizing our services and websites, like advertising that appear on the Site – where this
   involves the use of cookies or similar technologies – to provide a more personalized experience.
3. For purposes which are required by law.
4. To responding to requests by government, a court of law, or law enforcement authorities
   investigating.

WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

We will disclose personal information to the following recipients:

1. Companies that are in the Irrigreen group which are in the US.
2. Authors of any items or services made available to you, so they can facilitate support and license
   validation, who may be in any of the countries our products are available in.
3. Subcontractors and service providers who assist us in connection with the ways we use personal
   information (as set out above), in particular: website hosting providers which are located in the US; technical and customer support services which are located in the US and Canada; recruitment agencies which are located in the US and Canada; marketing and analytics services which are located in the US and Canada; security and fraud prevention services which are located in the US; subscription management services which are located in the US and Canada; payment processing services which are located in the US; identification verification services located in the US; and operational tooling services which are located in the US and Canada. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
4. Our professional advisors (lawyers, accountants, financial advisers etc.) which are in the US.
5. Regulators and government authorities in connection with our compliance procedures and
   obligations.
6. A purchaser or prospective purchaser of all or part of our assets or our business, and their
   professional advisers, in connection with the purchase .
7. A third party to respond to requests relating to a criminal investigation or alleged or suspected
   illegal activity.
8. A third party, to enforce or defend our rights, or to address financial or reputational risks .
9. A rights holder in relation to an allegation of intellectual property infringement or any other
   infringement.
10. Other recipients where we are authorized or required by law to do so.

WHERE WE TRANSFER AND/OR STORE YOUR PERSONAL INFORMATION

1. We are based in the US so your data will be processed in the US. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside the US in places like Canada. We do this based on your consent to this policy. To protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

1. We store personal information on secure servers that are managed by our service providers, and occasionally hard copy files that are kept in a secure location in the US and Canada. Personal information that we store or transmit is protected by security and access controls, includingusernameandpasswordauthentication,two-factorauthentication,anddata encryption where appropriate.

HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION

1. You can access some of the personal information that we collect about you by logging in to your account if applicable. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact us using the contact details at the end of this policy.

MARKETING CHOICES REGARDING YOUR PERSONAL INFORMATION

1. Where we have your consent to do so(i.e., if you have subscribed to one of our email lists or
   have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
2. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly for you.

COOKIES AND WEB ANALYTICS

When you visit our Sites, there’s certain information that is recorded which is generally anonymous information and does not reveal your identity. If you are logged into your account, some of this information could be associated with your account. We are talking about the following kinds of information:

1. Your IP address or proxy server IP address.
2. The domain name you requested.
3. The name of your internet service provider is sometimes captured depending on the
   configuration of your ISP connection.
4. The date and time of your visit to the website.
5. The length of your session.
6. The pages which you have accessed.
7. The number of times you access our site within any month.
8. The file URL you look at and information relating to it.
9. The website which referred you to our Sites.
10. The operating system which your computer uses.
11. Occasionally, we will use third party advertising companies to serve ads based on prior visits to
    our Sites. For example, if you visit our Sites, you may later see an ad for our products and services when you visit a different Site.

INFORMATION ABOUT CHILDREN

1. Our Sites may not be suitable for children under the age of 16 years. If you are under 16, we ask that you do not use our Sites or give us your personal information. If you are from 16 to 18 years, you can browse the Sites, but you will need the supervision of a parent or guardian to become a registered user. It is the responsibility of parents or guardians to monitor their children’s use of our Sites.

INFORMATION YOU MAKE PUBLIC OR GIVE TO OTHERS

1. If you make your personal information available to othe r people, we cannot control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, i.e., when you post a public message on a forum thread, share information via social media, or contact another user (such as a third-party Author) whether via our Sites or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Sites, ask them how they will handle your information. If you ’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

1. We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with the Irrigreen communication / services, you can request that we erase your personal information and close your Irrigreen account. Please note that if you request the erasure of your personal information, we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service, and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

WHEN WE NEED TO UPDATE THIS POLICY

1. We will need to change this policy from time to time to make sure it stays up to date with the latest
   legal requirements and any changes to our privacy management practices.
2. When we do change the policy, we will be sure to notify you about such changes, where required.
   A copy of the latest version of this poli cy will always be available on this page.

HOW YOU CAN CONTACT US

1. Please feel free to contact our company if you have any questions about this Privacy Policy or
   our practices, or if you are seeking to exercise any of your statutory rights. You may contact us
   at info@irrigreen.com or at our mailing address 5250 W 73RD Street, Edina, MN 55439.
2. If you are a user or visitor in the European Economic Area these rights also apply to you . For the
   purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.

HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION

1. You are also entitled to ask us to port your personal information (i.e., to transfer in a structured,
   commonly used, and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profilingthatweperformforthepurposesofdirectmarketing,and,wherewehaveaskedfor your consent to process your data, to withdraw this consent as more fully described below.
2. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
3. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
4. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.

Both personal information and personal data have the same meaning in the context of this Privacy Policy.

Irrigreen, Inc.

Effective March 17, 2021

Copyright 2022 Irrigreen