pharosIQ Privacy Policy

Last updated March 3, 2026

Market Resource Partners, LLC operating as pharosIQ (“Company”, “we”,” us”, “ours”) value the data protection and privacy rights of the persons (“you” or “your”) whose information we collect or receive. This privacy policy (“Policy“) applies to any website (“Website”), data analytics, virtual or physical event, online service form, marketing or other interaction with Company and its affiliates, and explains who we are and the practices that govern how we collect, use, share and protect the information you provide to us and other information we may collect about you and other individuals and companies.

Please read this Privacy Policy carefully to understand our privacy practices when you use our Services. We may modify this Policy at any time at our discretion. Material changes will be conspicuously posted on the website or otherwise communicated to you. All changes will be effective immediately upon posting to the website.

Market Resource Partners, LLC may own, operate, or manage additional websites or online properties. This Policy applies to your use of any website or online service that we own and operate.

About us

pharosIQ is a technology driven sales and marketing solutions company that provides clients with the means to organize target account intelligence and coordinate relevant multichannel account-based marketing programs. pharosIQ operates its website (www.pharosIQ.com), ad hoc microsite (https://iqdirectmail.com/), several aliases, (collectively, “Newsletter Domains”) (listed below) and landing pages on behalf of customers (collectively, the “Company Sites”). The following Newsletter Domains are owned and operated by the companies in our corporate group:

• Analytics Platform Solutions <analyticsplatformsolutions.com>;
• B2B Demand Gen Solutions <b2bdemandgensolutions.com>;
• Blockchain Software Solutions <Blockchainsoftwaresolutions.com>;
• Cloud Info Hub <cloudinfohub.com>;
• Contentreads <contentreads.com>;
• Human Resources Briefings <humanresourcesbriefings.com>;
• Info Business Tech <infobusinesstech.com>;
• IT Local Gov <itlocalgov.com>;
• IT Security World <it-securityworld.com>;
• IT Solutions Report <itsolutionsreport.com>;
• Sales CRM Solutions <salescrmsolutions.com>;
• Tech Marketing Web <techmarketingweb.com>; and
• Video Conference Solutions <vidconferencesolutions.com>.

Additional Newsletter Domains may be adopted from time-to-time, without notice to you.

pharosIQ also uses and maintains our proprietary intelligence platform called atlasIQ formerly known as Content Indication Platform (CIP”) aimed at helping to produce account and contact level intent and key content insights that provide businesses with who to target, what to communicate, and how to optimize messaging. pharosIQ also provides advertising services (Company Ad Services) to clients, helping them to display relevant online advertising to end users (End Users) who interact with third party websites (Third Party Sites). In addition, Company also offers clients a suite of marketing related solutions including content syndication, events, direct mail, and inside sales.

IF YOU ARE A RESIDENT OF CALIFORNIA, COLORADO, CONNECTICUT, DELAWARE, IOWA, INDIANA, MARYLAND, MINNESOTA, MONTANA, NEBRASKA, NEW JERSEY, NEW HAMPSHIRE, OREGON, UTAH, VIRGINIA, OR TEXAS: PLEASE SEE THE “Error! Reference source not found.” SECTION BELOW FOR ADDITIONAL INFORMATION THAT APPLIES TO YOU.

IF YOU ARE A RESIDENT OF CANADA: PLEASE SEE THE “CANADIAN PRIVACY RIGHTS ” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

IF YOU ARE A RESIDENT OF MEXICO: PLEASE SEE THE “CANADIAN PRIVACY RIGHTS ” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

IF YOU ARE A RESIDENT OF BRAZIL: PLEASE SEE THE “BRAZILIANCANADIAN PRIVACY RIGHTS ” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

IF YOU ARE A RESIDENT OF AUSTRALIA: PLEASE SEE THE “CANADIAN PRIVACY RIGHTS ” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

IF YOU ARE A RESIDENT OF SOUTH AFRICA: PLEASE SEE THE “CANADIAN PRIVACY RIGHTS ” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

IF YOU ARE A RESIDENT OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM: PLEASE SEE THE “

EE” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

1. WHAT IS PERSONAL INFORMATION?

For purposes of this Privacy Statement, “Personal Information” or “Personal Data” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information or aggregated information that does not include personal identifiers.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect specific categories of Personal Information when you access our Website, or otherwise communicate with us. The information we collect varies depending on the Services you are using.

We describe how we collect information on our Services below:

• SOURCES OF THE INFORMATION WE COLLECT AND THE PURPOSE FOR WHICH WE COLLECT IT
• DE-IDENTIFIED/AGGREGATED DATA
• AI ChatBOT TECHNOLOGY
• BLOGS and FORUMS
• WEBSITE ANALYTICS, COOKIES, AND OTHER TRACKING TECHNOLOGY
• MARKETING COMMUNICATIONS
• LEAVING OUR WEBSITE AND/OR LINKING TO THIRD PARTIES
• SOCIAL MEDIA AND PLUG-INS
• CHILDREN'S PRIVACY
• DATA SECURITY POLICY & USER RESPONSIBILITIES
• CANADIAN PRIVACY RIGHTS

The charts below list the categories of Personal Information we may collect, as well as the sources we collect the information and the purpose(s) for such collection.

Information we collect from you

We collect certain Personal Information from you directly or automatically using technology for the purposes described below:

Information we collect from third party sources

We collect Personal Information from various third-party companies and public sources as described below:

Disclosing Personal Information

We may disclose your Personal Information as follows:

We may aggregate or de-identify Personal Information we collect through our Website and when operating our business. Once information or data has been de-identified and/or aggregated, such information is no longer Personal Information. pharosIQ may use or share such de-identified or aggregated data for any legal purpose at its sole discretion.

PharosIQ uses chat services and software code that collect users’ interactions with the Website and App in a manner that allows us to monitor and review these interactions for customer service and to improve our Services. These interactions may include users’ Personal Information entered into the chat window, webpages visited on our Website, IP address, and geographic location information such as city, state, or geographic area. These interaction replays help us identify and diagnose usability problems, identify areas for improvement, and improve the customer experience when using the Services. Conversations and interactions with AI features may be logged and processed to improve performance.

Our Website may, from time to time, offer publicly accessible blogs or community forums where you can submit ideas, photographs, writings, music, video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions, or other content (“User Generated Content”), including Personal Information. You should be aware that any User Generated Content you provide in these areas may be read, collected, and used by others who access them. Please note that we do not control who will have access to the User Generated Content that you choose to make public and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.

To request the removal of your Personal Information from our blog or community forum, contact us at  privacy@pharosIQ.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. We are not responsible for the privacy or security of any User Content that you make publicly available on the Website or what others do with the User Content you share with them on the Website. We are not responsible for the accuracy, use, or misuse of any User Content that you disclose or receive from third parties through the Website.

Please visit our Cookie Policy https://pharosiq.com/cookie-policy/ for information about how we use cookies, analytic and advertising technology on our Website and your choices regarding our use of that technology.

If you no longer want to receive marketing-related emails, mail or telemarketing from us on a going-forward basis, you may opt out of receiving these marketing-related communications by (i) visiting the Company Privacy Hub and changing your preferences; (ii) clicking on the unsubscribe link within the email message that you receive from us; or (iii) notifying us during a marketing call. 

We strive to ensure that any information you send us is safe. When you leave our Website and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that we do not represent either the third party or you if you enter into a transaction on the third-party website. Further, the privacy and security policies of the linked website may differ from those practiced by us. The inclusion of any link does not imply our endorsement of any other company, its website(s), or its product(s) and/or services(s). We are not responsible for the privacy practices or content of any other website.

Our online Services may use social media plug-ins (e.g., the Facebook "Like" button and "Share to Twitter" button) to enable you to easily interact with certain social media websites (e.g., Facebook, Twitter, Instagram) and share information with others. When you visit our online Services, the operators of the available social media plugins can place a cookie on your device, enabling such operators to recognize individuals who have previously visited our online Services. If you are logged into these social media websites while visiting our online Services, the social media plugins allow the relevant social media website to receive information that you have visited our online Services or other information.

The social media plugins also allow the applicable social media website to share information about your activities with our online Services with other users of the social media website. For example, Facebook Social Plugins allow Facebook to show your "Likes" and comments on our online Services to your Facebook friends. Facebook Social Plugins also allow you to see your friends' Facebook activity on our online Services. We do not control any of the content from the social media plugins. We may also interact with you on social media platforms. If you contact us on one of our social media platforms, request Services, or otherwise communicate directly with us on social media, we may contact you to interact with you. For more information about social media advertising and social media plugins from other social media websites, please refer to those websites' privacy and data-sharing statements.

We use the YouTube application programming interface (API) services to allow you to access YouTube content from our Services. Your use of YouTube is governed by YouTube’s Terms of Services and Privacy Policy. We encourage you to read the YouTube Terms of Service and Privacy Policy, which are available on its website at https://www.youtube.com/t/terms.

Our Website and Services are not intended for or directed to individuals under 18 years of age, and we do not knowingly collect any Personal Information from children under the age of 18.

We take the protection of your information seriously and take reasonable and appropriate physical, administrative, and technical measures to protect the information collected through our Website. While we implement commercially reasonable security measures to protect your privacy. There are inherent security risks associated with transferring data over the internet, and we cannot guarantee that the information collected about you will always remain private when using our Website and/or Services. As a result, while we strive to protect your Personal Information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

YOUR STATE PRIVACY RIGHTS: TERMS APPLICABLE TO CALIFORNIA, COLORADO, Connecticut, DELAWARE, INDIANA, IOWA, KENTUCKY, MARYLAND, MINNESOTA, MONTANA, NEBRASKA, NEW HAMPSHIRE, NEW JERSEY, OREGON, TENNESSEE, TEXAS, UTAH, AND VIRGINIA RESIDENTS ONLY, INCLUDING YOUR CALIFORNIA PRIVACY RIGHTS

Certain states have passed laws that provide consumers who are residents of those states with certain privacy rights related to their Personal Information. Those states and the rights are summarized below:

• California Consumers: California Consumer Privacy Act, as amended by the California Privacy Rights Act, ("CCPA")
• Colorado Consumers: Colorado Privacy Act (“CPA”)
• Connecticut Consumers: Connecticut Data Privacy Act (“CTDPA”)
• Delaware Consumers: Delaware Personal Data Privacy Act (“DPDPA”)
• Indiana Consumers: Indiana Consumer Data Protection Law (“ICDPA”)
• Iowa Consumers: Iowa Data Protection Act (“IDPA”)
• Kentucky Consumers: Kentucky Consumer Data Protection Act (“KCDPA”
• Maryland Consumers: Maryland Online Data Privacy Act (“MODPA”)
• Minnesota Consumers: Minnesota Consumer Data Privacy Act (“MCDPA”)
• Montana Consumers: Montana Consumer Data Privacy Act (“MCDPA”)
• Nebraska Consumers: Nebraska Data Privacy Act (“NDPA”)
• New Hampshire Consumers: New Hampshire Privacy Act (“NHPA”)
• New Jersey Consumers: New Jersey Data Protection Act (“NJDPA”)
• Oregon Consumers: Oregon Consumer Privacy Act (“OCPA”)
• Tennessee Consumers: Tennessee Information Protection Act (“TIPA”)
• Texas Consumers: Texas Data Privacy and Security Act (“TDPSA”)
• Utah Consumers: Utah Consumer Privacy Act (“UCPA”)
• Virginia Consumers: Virginia Consumer Data Privacy Act (“VDCPA”).

(“collectively “State Consumer Privacy Laws”) We have provided a summary of the rights under the State Consumer Privacy Laws below. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for residents of the applicable state. Certain capitalized terms not defined in this Policy have the meanings set forth in the applicable State Consumer Privacy Laws.

How to Exercise Your State Consumer Privacy Rights.

Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, you may exercise the following rights with regard to your Personal Information:

Notice of Your Right to Opt Out

California residents have the right to opt out of the Sale or Sharing of their Personal Information for cross-context behavioral advertising at any time.

Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia residents may direct us to cease processing their Personal Data for targeted advertising or selling their Personal Data.

Depending on where you live, you may exercise your right to opt out in the following ways:

Opt-Out Preference Signal

California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, and Texas residents may opt out of the sale or sharing of their Personal Information collected through use of technologies, such as Cookies enabled on the Site by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs.

If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Opt-Out Webform

You may submit your opt-out request by:

• Using the following webform: Privacy Rights Request - pharosIQ

If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, or Texas resident using an authorized agent to exercise your rights to opt out of the Sale or Sharing of Personal Information, please see the section entitled "Authorized Agents" below for the information required when you use an authorized agent.

Right to Know Your Information

California residents have a right to know whether we collected any of the following in the prior 12-month period:

• The specific pieces of Personal Information that we have collected from you;
• The categories of Personal Information we collected from you;
• The categories of sources from which the Personal Information was collected;
• The categories of third parties to whom we have disclosed your Personal Information;
• The categories of Personal Information that we sold or disclosed for a Business Purpose and the categories of third parties to whom it was disclosed for a Business Purpose; and
• The Business or Commercial Purpose for collecting, sharing, or selling your Personal Information.

Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia residents have the right to confirm whether we are processing your Personal Data and to access such Personal Data. Maryland, Minnesota, and Oregon residents may also request a list of third parties to which we disclose Personal Data.

Right to Deletion

Depending on the state in which you live, you may have a right to request that we delete your Personal Information or Personal Data we collected from you or the right to request that we delete all Personal Information or Personal Data we have collected about you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

Right to Correct Your Information

Depending on the state in which you live, you may have a right to request that we correct your inaccurate Personal Information or Personal Data. If you request that we correct inaccurate Personal Information or Personal Data about you, we will use commercially reasonable efforts to correct it. If necessary, we may ask that you provide documentation showing that the information we retained is inaccurate.

Right to Data Portability

Depending on the state in which you reside, you may request a copy of the Personal Information or Personal Data we collected from you or request a copy of all the Personal Information or Personal Data we have collected about you in a portable and, to the extent technically feasible, readily usable format.

How to Exercise Your Rights of Access, Deletion, Correction, and Portability

To exercise your applicable State Consumer Privacy Rights described in this Policy, you may submit your request to us by:

• Using the following webform: Privacy Rights Request - pharosIQ

Who May Exercise Your Rights. You may only make a request to exercise your rights on behalf of yourself. A parent or legal guardian may make a request on behalf of their child. If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, or Texas resident, a person that you authorize to act on your behalf may make a request related to your Personal Information. See the section titled "Authorized Agents" below for more information

Verifiable Consumer Request. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or Personal Data, and you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. To verify your identity, we may ask you to log into your account (if you have an account with us) or provide additional information. Any information you provide will only be used to verify your request. When seeking additional information from you, we may contact you through your account or the contact phone number or email address you provided in your request. If we cannot verify your identity, we may deny your request.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

Authorized Agents. Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, and Texas residents may submit a request to opt out through an authorized agent. California residents also have a right to submit requests to exercise any privacy right through an authorized agent. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf and (b) verify your identity.

We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.

When We Will Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Disclosures we provide to California residents may only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Right to Non-Discrimination

You have a right to not receive discriminatory treatment for exercising any of your rights. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section. We do not use Personal Information to discriminate against any individual.

1. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
2. ADDITIONAL INFORMATION FOR COLORADO, Connecticut, DELaware, INDIANA, IOWA, MARYLAND, MINNESOTA, MONTANA, NEBRASKA, NEW HAMPSHIRE, NEW JERSEY, OREGON, TENNESSE, TEXAS, AND VIRGINIA RESIDENTS: APPEAL PROCESS

Categories of Personal Information Sold or Shared

In the last 12 months we have not sold your Personal Information to a third party for monetary compensation. In the last 12 months, we have shared the following categories of Personal Information with third parties for the purpose of serving targeted advertising and to perform data analytics on the Site.

See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category.

• Identifiers
• Commercial Information
• Internet Activity
• Geolocation Data
• Employment Information

Categories of Personal Information Disclosed for a Business Purpose

In the last 12 months we disclosed the following categories of Personal Information to service providers for our operational purposes. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category.

• Identifiers
• Commercial Information
• Internet Activity
• Employment Information
• Education Information
• Protected Classifications

We Do Not Use or Disclose Sensitive Information. We do not use or disclose sensitive information, as defined in the CCPA.

Financial Incentive Offerings.

We offer product samples, discounts, coupons, survey rewards and sweepstakes or contest rewards from time to time. In exchange, we will collect, use, share and retain certain personal information from you in order for us to ship the sample. We will also maintain and utilize the Personal Information you provide for future marketing purposes. These product samples, discounts, coupons, survey rewards and sweepstakes or contest rewards may be considered a financial incentive under CCPA. These financial incentives are reasonably related to the value of the data you provide.

We make a reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation from brand loyalty and repeat purchases. We calculate the value of the offer and financial incentive by using the expense related to the offer.

Shine the Light.

California law also gives residents certain rights related to how businesses share their information for direct marketing. Under California’s “Shine the Light” law (Civil Code § 1798.83), California residents may request information about how we shared their Personal Information with third parties for those third parties’ own direct marketing purposes during the prior calendar year. If we have made such disclosures, we will identify the third parties involved, describe the categories of Personal Information disclosed, and, where the nature of a third party’s business cannot be reasonably determined from its name, provide examples of the products or services that the third party marketed.

We provide this information in a standardized format that is not specific to any individual requestor, and California residents may request it once per calendar year at no charge. To submit a Shine the Light request, residents should send a written request to us at the physical mailing address listed below, which helps us reduce automated or fraudulent submissions:

• Emailing us at  privacy@pharosIQ.com or
• Writing us at:
• Emailing us at  privacy@pharosIQ.com or
• Writing us at:
• Emailing us at  privacy@pharosIQ.com or
• Writing us at:
• Emailing us at  privacy@pharosIQ.com or
• Writing us at:
• Emailing us at  privacy@pharosIQ.com or
• Writing us at:
• Emailing us at  privacy@pharosIQ.com or
• Writing us at:

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103

If you disagree with our refusal to take action on your request to exercise your privacy rights, you have the right to appeal that decision. You must submit your appeal request within 60 days of your receipt of our denial. You may submit your request to us by:

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103

Once we receive your appeal request, we will acknowledge and start processing your request. Within 60 days of receiving your request, we will inform you in writing of any action taken or not taken in response to your request, including a written explanation of the reasons for our decision.

Your Canadian Privacy Rights. Under Canadian privacy laws you have certain rights to access and correct Personal Information, subject to identity verification requirements and certain exceptions.

Right to Access. You have the right to confirm that we hold Personal Information about you, receive an explanation about how we use your Personal Information, and obtain access to your Personal Information.

Right to Rectification. You have a right to examine and challenge the accuracy and completeness of your Personal Information, and have your Personal Information amended where appropriate.

Right to Withdraw Your Consent. You have the right to withdraw your consent to processing your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice. If your withdrawal of consent implicates the quality of our Services to you, we will notify you.

Right to Complain to a Data Protection Authority. You also have the right to lodge a complaint regarding the processing of your Personal Information with the applicable data protection authority. Please contact your local data protection authority for more information.

How to Exercise Your Rights. To exercise your rights described in this Section, you may submit your request to us by contacting us using the contact information listed below.

Data Transfers and Consent To Processing Outside of Canada or Quebec

We are based in the United States. We may transfer your Personal Information to the United States in connection with the operation of our business.

To assist us in meeting our operational and legal obligations, we may also transfer or make your Personal Information accessible to one of our service providers located either in Canada (both inside and outside Quebec) or throughout the world.

When we transfer your Personal Information outside of Canada, your Personal Information may be available to government officials in the United States or other countries. These countries have privacy laws that differ from Canadian privacy laws.

Additional Terms Applicable to Quebec Residents Only

If you are a resident of Quebec, Quebec law provides you with additional rights regarding the use of your Personal Information, subject to identity verification requirements and certain exceptions.

Right to Restriction of Processing. You have a right to direct us to cease disseminating your Personal Information or to de-index any hyperlink attached to your name that provides access to the information by a technological means, if the dissemination of the information contravenes the law or a court order.

Right to Request Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such requests, and direct our Service providers to do the same, subject to certain exceptions permitted by applicable law.

Right to Portability. You may request copies of the Personal Information you have provided to us. Where possible, we will deliver the copy of your Personal Information to you using a structured, commonly used, and machine-readable format. Alternatively, you may request that we send your Personal Information to another business.

Translations. This Privacy Statement may be provided in several languages. In the event of conflict or inconsistency, the English language version of this Privacy Statement controls, unless otherwise required by applicable law. En cas de conflit ou d'incohérence, la version anglaise de cette politique de confidentialité contrôle, sauf si la loi applicable l'exige.

How to Exercise Your Rights. To exercise your rights described in this Section, you may submit your request to us by contacting us using the information below.

1. EEA, DACH, UK & SWISS PRIVACY RIGHTS

The purpose of this Section is to provide information and additional provisions that apply to pharosIQ’s processing of Personal Data in accordance with the EU General Data Protection Regulation 2016/679, the UK General Data Protection Regulation and the Swiss Federal Data Protection Act (collectively “GDPR”). The terms in this section are only applicable to those persons located in the European Economic Area (“EEA”), DACH Region, Switzerland, and the United Kingdom (“UK”) (collectively, “EU Data Subjects”). [A1]

In the event of a conflict between this section and the remainder of the Privacy Policy, this section shall control for EU Data Subjects.

Lawful basis for Processing Personal Data of European Data Subjects

We process the Personal Data of European Data Subjects on the following lawful bases:

• Legitimate Interests. Where the processing is necessary for the purposes of the legitimate interests pursued by pharosIQ or by a third party and not overridden by your fundamental rights and freedoms (e.g., product development and security purposes);
• Performance of a Contract. Where the processing is necessary for the performance of a contract with you (e.g., to deliver the service you have requested);
• Consent. Where you have given explicit consent to the processing of your Personal Information for one or more specific purposes (e.g., new and unexpected processing activities); and
• Legal Obligation. Where processing is necessary for compliance with a legal obligation to which pharosIQ is subject (e.g., compliance with laws and regulations).

In this case, we rely on the following lawful basis for processing personal data for the purposes set forth below:

PRIVACY RIGHTS OF EUROPEAN DATA SUBJECTS

European Data Subjects have the following rights concerning their Personal Information under the General Data Protection Regulation, the Polish Personal Data Protection Act, and the German Federal Data Protection Act:

• Withdrawal of Consent. If we are processing Personal Data on the basis of consent, you may have the right to withdraw consent to our processing at any time.
• Access and Rectification. You may have the right to access, correct, and update your Personal Data.
• Deletion/Erasure. You may have the “right to be forgotten” through the erasure or deletion of your Personal Data.
• Portability. You may have the right to move, copy, and/or transfer certain Personal Data from our Service to another service.
• Stop Processing. If processing is on the basis of legitimate interests, you may have the right to object to the processing of your Personal Data and to ask us to restrict the processing of your Personal Data, subject to certain limitations.
• Submit a Complaint. You have the right to submit a complaint to a data protection authority about our collection and use of your Personal Data. Contact details for the EU/EEA are here:
  • If you are located in the European Economic Area, https://edpb.europa.eu/about-edpb/about-edpb/members_en
  • If you are located in Switzerland, https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
  • If you are located in the United Kingdom, https://ico.org.uk/global/contact-us/contact-us-public/
• Right To Withdraw Consent. In the event you provide your consent for us to process your Personal Data, you may withdraw your consent at any time by emailing to request such change at no additional cost.

Exercising your rights under the European Data Protection Laws

You, or an authorized agent, may exercise your privacy rights by submitting a request to  privacy@pharosIQ.com.

We respond to and process requests promptly and within the time frames required by the European Data Protection Laws. Please note that all requests are subject to proper prior verification before processing.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Retention of European Data Subject personal data

PharosIQ retains Personal Data for a period commensurate with the purposes for which the Personal Data was collected or obtained. The criteria used to determine the retention of Personal Data includes any time necessary for legal and compliance purposes. Personal Data may be retained in archival format (e.g., data backups) beyond its retention period.

Marketing.

PharosIQ does not process Personal Data of European Data Subjects for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of Personal Data for marketing purposes at any time by contacting us at:

• Completing the webform: Privacy Rights Request - pharosIQ
• Emailing us at:  privacy@pharosIQ.com

Automated Decision Making.

We do not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of Personal Data via automated decision making at any time by contacting us at.

DATA PROTECTION INQUIRIES

If you are a European Data Subject and you have questions about how we process your Personal Data, you may contact pharosIQ’s Privacy Team at the following:

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103

• RESIDENTS OF SOUTH AFRICA
• RESIDENTS OF MEXICO
• RESIDENTS OF BRAZIL
• RESIDENTS OF AUSTRALIA
• CHANGES TO THIS PRIVACY POLICY

In accordance with South Africa’s Protection of Personal Information Act (POPIA), if you are a resident of South Africa, you have the following rights concerning your Personal Information:

• Ask what Personal Information we maintain about you.
• Request to correct any out-of-date or incorrect Personal Information we hold about you.
• Request that we delete the Personal Information we hold about you. We are authorized under POPIA to retain your Personal Information for certain purposes, such as protecting our rights or complying with our legal obligations.
• Object to the processing of your Personal Information on reasonable grounds.
• Request that we restrict the processing of your Personal Information in certain conditions.
• Unsubscribe to any direct marketing communications we send to you.
• Not be subject to decision-making based on the automated processing of your Personal Information.
• Additionally, you have the right to submit a complaint to the Information Regulator if you feel a covered entity violates your rights.

You can exercise your data subject rights by contacting us at  privacy@pharosIQ.com. We may respond to your request in 21 days and charge a small administrative fee.

The terms in this section are only applicable to residents of Mexico. In compliance with the Federal Law on Protection of Personal Data Held by Individuals (“LFPD”), we provide the following additional information regarding our privacy practices and your privacy rights.

You have the additional rights (i) to cancel your Personal Data when you deem it is not required for the purposes established in this Privacy Statement or that it is being used for unauthorized purposes, (ii) to oppose the processing of your Personal Data for certain specific purposes, and (iii) to file a complaint with the Federal Public Information Access Institute at www.ifai.org.mx.

How to Exercise Your Rights

You may exercise rights (i) and (ii) through a written petition to us at the address below, accompanied by your email address and telephone number, and if applicable, specific details of the reasons for which a rectification, opposition or revocation of consent is requested. We will respond to your petition within a reasonable amount of time and inform you of its outcome through the phone number and/or email address provided by you.

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103

In accordance with Brazilian Data Protection Law of August 13, 2018 (Lei Geral de Proteção de Dados, “LGPD”) and the regulations of the Brazilian Data Protection Authority, the Autoridade Nacional de Proteção de Dados, (the “ANPD”) visitors, users, and others who reside in Brazil may have certain rights regarding their Personal Data, including:

Right to Access

You have the right at any time to ask us to confirm that we are processing your Personal Data or to request information on the origin of the data and the purpose of the processing.

Right to Request Erasure

In certain circumstances, you have the right to have your personal data anonymized, to block the processing, or request the deletion of your personal data by contacting us using the details in the Contacts section at the bottom of the Privacy Policy.

Specifically, please note that you have the right to request the deletion of your Personal Data where:

• the Personal Data processed is unnecessary or excessive;
• the Personal Data is processed in non-compliance of the LGPD, or
• the processing is based on consent and your consent has been withdrawn.

Right to Rectify

You have the right to request the correction of incomplete, inaccurate, or out-of-date Personal Data.

Right of Data Portability

You have the right to request to port your Personal Data and receive it in a commonly used computerized format, if possible.

Right Not to be Subject to Automated Decision-Making

You have the right to request the review of decisions made solely based on automated processing of Personal Data affecting your interests, including decisions intended to define their personal, professional, consumer, and credit profile, or aspects of your personality. ASQ does not conduct automated decision-making.

Please note that these rights are not absolute and in certain circumstances we may deny your request. We will notify you of the reasons of such denial in writing. You may at any time petition the ANPD regarding the processing of your Personal Data.

How to Exercise Your Rights

To exercise your rights described in this section or request us to reconsider our response to your previous request, you or your duly appointed representative may submit your request by mail or email:

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103

This section provides additional terms and information that apply to residents of Australia.

Right to Access

You have the right to request access to your Personal Information we maintain about you. In responding to your request, we will provide the information in the format you request, if it is practicable for us to do so.

Right to Rectification

You have the right to request that we rectify your Personal Information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading. We will take reasonable steps to rectify such Personal Information, including destroying or de-identifying the Personal Information subject to the request. Please note that we may keep the Personal Information in its current form as needed to comply with our business and legal obligations.

Right to Withdraw Consent

You may request to withdraw your consent to processing at any time, including requesting not to receive direct marketing communication from us.

Before substantively responding to your request, we must be satisfied that your request is made by you or your representative who has authority to make a request on your behalf. Depending on the type of request and the sensitivity of the information to be shared in response to the request, we may ask for additional information to verify your identity and/or the authority of your representative.

Upon receiving a request and verifying your identity, we will substantively respond to your request within 30 calendar days.

You may submit your request to exercise a data privacy right by mail or email:

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103

If you are not satisfied with our response to your request to exercise a data privacy right, you may contact the Australian Information Commissioner at:

Mail:

GPO Box 5218

Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Online: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint

As our organization changes over time, this Privacy Policy may change as well. We reserve the right to amend the Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our Services. We will provide you notice of material changes by indicating that the Privacy Policy has been updated on our homepage and will indicate the date we made the update above. Your continued use of any of the Services after the changes have been made will constitute your acceptance of the changes. Please, therefore, make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of the Policy, please cease using the Services.

Contact Us:

Market Resource Partners, LLC operating as pharosIQ
Attn: Legal Department

1818 Market Street, 37th Floor
Philadelphia, PA 19103