Privacy Policy

Last Updated: March 1st 2024

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Our website (the "Site") including any associated mobile application or desktop application downloaded to your computer (the "Applications") are brought to you by Platform Group Limited ("PGL", "we", "us", or "our"). PGL respects the privacy of its customers and users of its Site and Applications ("Customer", "you", or "your") and strives to protect the security of the personal information it receives.

The services, data and information provided by PGL on the Irwin platform, Site, and/or through other websites and channels, together with the Applications and any other associated software applications and functionality are collectively referred to herein as the "Products." Use of the Products is governed by this Privacy Policy, our Terms of Service and any applicable license or other service agreement(s) ("Master Agreement") between PGL and you.

The purpose of this Privacy Policy is to describe to you our privacy policies and practices, including the types of personal information we may collect, how we use and disclose your personal information, your rights, and our practices for maintaining and protecting your information.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, your choice is not to use the Products. By accessing or using our Products, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy.

Collection and Use of Information

We may collect the following information when you use our Products:

Profile and Contact Information

We receive the personal information you provide, such as your name, phone number, and email address, when you sign up to use our Products or when you contact us to request a demo of or regarding any Products. In some situations, we may also record your username and/or password information. We use this information in connection with the provision of services via the Site and Applications. We may also use this information to contact you regarding our products and services, and, in connection with certain Products, we may send you product-related news and other news and information that we believe may be of interest to you. If you wish to unsubscribe from these communications, please follow the instructions in the communication or contact an Account Manager.

Transactional Information

We   may   collect   your   payment   and   financial   information   (such   as   your   credit/debit   card information, and/or banking information) and information on the products and services that you have purchased or are subscribed to.

Aggregate Information

We may collect and use aggregate information regarding use of the Products or about a category of users of the Products, and we may combine that information with other information pertaining to use of our various Products by you and other users. In addition, we may copy and create derivative works of or otherwise use User-Uploaded Information (defined below) for the purpose of aggregating and anonymizing such User-Uploaded Information, such that the anonymized and aggregated information, which will not include any personally identifiable information, may be used by PGL in connection with its provision of Products and for other PGL business purposes.

Employment Opportunities

In connection with a job application or related inquiry, you may provide us with personal information including a resume, cover letter, or similar employment-related materials. This information will be used for the purposes of processing and responding to your application for current and future career opportunities, and to manage any ongoing working relationship.

Cookies and Third-Party Services

We use "cookies," which are small data files that the Site or Applications may transfer to your browser. A cookie is a tiny element of data that the website can send to your browser, which may then be stored on your computer or mobile device so we can recognize you when you return. You can find more information about cookies at websites such as and Generally, the cookies we use fall into the following two categories: (i)"strictly necessary cookies" which are essential for the operation of the Products; and (ii) "performance cookies" which analyze how our users use our Products and to monitor the performance of our Products. Within these two categories, we currently use or may use in the future the following types of cookies: (a) session cookies (temporary cookies that expire when you log off from using our Products or when your session automatically times out) to maintain your session and maintain security and verify details while you use our Products as you navigate from page to page; and (b) persistent cookies (cookies stored on your browser between sessions) to help uniquely recognize you or your browser and remember how you have used the Products.

In addition to cookies that send information to us, our Products may also permit use of cookies to collect information and send it to third parties for analytical purposes, to permit functionality when using the Products, or to help with authentication. Our Products may make use of Google Maps, Google Site Search, Microsoft's Bing Maps, or other third-party services, which may place cookies on your browser and collect Internet Protocol ("IP") address and browser data and related information in order to facilitate functionality and to maintain and improve the quality, security and integrity of the third-party services. In some instances, the third-party services may make use of web beacons to help deliver cookies and compile usage information. Data collected by Google's services is subject to Google's privacy policy, and data collected by the Microsoft Bing map service is subject to Microsoft's privacy policy.

In addition, our Products may use analytics features such as services provided by Google Analytics, Ion Interactive, and Daddy Analytics, as well as marketing software tools such as the e-mail tools provided by Marketo. Cookies placed on your browser by such services may collect limited information pertaining to your use of the Products, including traffic and usage data. Use of data collected by analytics services (generally, in aggregate form only) is subject to the service's privacy policy. Note that Google offers a Google Analytics browser add-on (designed to be compatible only with certain browsers)to provide website visitors the ability to prevent their data from being collected and used by Google Analytics. That add-on may be obtained here: and other privacy controls are available here:

We do not collect personally identifiable information about your online activities across third‑party websites or online services, and thus the Site does not respond to web-browser "do-not-track" signals or other similar mechanisms. We do not permit our third-party service providers to collect information from our Products for other websites other than as described in the preceding paragraph.

Google API Services Disclosure

The Platform Group uses Google’s Application Programming Interface (API) Services to enable the Irwin platform to connect to a Google Workspace account.  An Irwin user may authorize the Irwin platform to send and receive email, read and create calendar events, and read contacts from a connected Google Workspace Account.  These capabilities are user-facing and are explicitly opt-in, requiring authorization by each Google Workspace account owner.  The Platform Group connection to a Google Workspace account may be revoked at any time by the Google Account owner, from the Google Account Security settings.

Within the Irwin platform, the features known as Irwin Mail, Irwin Calendar Assistant and Irwin Scheduler use Google APIs to enhance the Irwin platform.  Enhancements include the automatic creation of Irwin IRM Activities based on email and calendar data, and allowing email to be sent from within the Irwin platform via a connected Google Workspace Account.

The Platform Group’s use of data received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Types of Data Collected with Google API Services

We collect and send relevant Google authentication information, Google Gmail data, Google Calendar data, as well as read Google People information.  The information collected and used with these API services may include confidential data and personal data, in the form of email messages, calendar activities, and address book contacts.

“Confidential data'' means data that may contain sensitive and/or non-public information that should only be accessible to authorized personnel. For example, private discussions in email, or other sensitive information that should not be made public.

"Personal data" means data allowing someone to identify or contact you. For example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

The Platform Group does not store Google Workspace user credentials, access is managed through an OAuth token.

Use of Google API Services Data

The above described types of Google API Services data are used by the Irwin Mail, Irwin Calendar and Irwin Scheduler.  These are optional features which are part of the core platform. Your data within the irwin platform remains private and is visible to you within the Irwin platform.

The Irwin platform will store copies of email messages, calendar events and contacts which are relevant to your use of Irwin.  For example, if an IRM Activity is created as a result of an email message either sent from or received by the Irwin platform, a copy of that email message, and any follow-up emails in the conversation, will be attached to the IRM Activity for your convenient use within the Irwin platform.

Your information and data is not used outside the Irwin platform, or by other users of the Irwin platform.

The Platform Group policies and procedures define requirements that prohibit the unauthorized use of data within the platform or by employees of The Platform Group.

Data Security

The Platform Group has established policies and procedures to safeguard your sensitive information. These include the implementation and use of security software, security processes, and a team of security professionals to manage and monitor the security of The Platform Group’s network and applications. The Platform Group is industry-standard  SOC 2 Type 2 certified, please consult our report for further details.

Automatic Data Collection Technologies

Our   systems   automatically   record   information   including   your   IP   address,   mobile   device identifier, browser  type and characteristics, operating system details, language preferences, referring URLs, length of visits, pages viewed, whether and how frequently you use the Products and other log data. We use this   information to understand users' preferences, to better serve users, and to improve our Products.

Our Products may also be placed on our customer's websites for the purpose of conducting website analytics. As you interact with our Products, we may use automatic data collection technologies to collect, use and analyze certain information about your website interactions. For example, we collect, use and analyze website traffic data, IP addresses, location data, operating system and browser types, and other communication data. We use the information collected through automatic data collection technologies for the purpose of website analytics and to improve our Products or services.

Important Note Regarding Database Information

As part of our services, we collect, license and use business contact information regarding individuals and companies in the financial and investment community. If you wish to use any business contact information from the PGL Databases, you may only use this information for the purpose of communicating or facilitating communication with such individual in relation to their employment, business or profession.

It is possible that you and some of your contacts may be part of the financial and investment community, and information about you and some of your contacts may appear in our licensed databases, including the PGL Databases. Please be assured that individual entries in our licensed databases, including the PGL Databases, are independently collected by the PGL research department from sources such as publicly available websites, and do not come from data that is received from users' use of our Products.

Access Among Users Within the Same Business Account

For many Customers, PGL has incorporated functionality in the Products that shares information among the Customer's authorized users (which may include "Permitted Users", as defined in the Terms of Service) under the same Master Agreement. Depending on the specific functionality that has been implemented, and the permissions granted to the user by the Customer in accordance with the Customer's Master Agreement, User-Uploaded Information added into our Products by you or another authorized user may be shared with other Permitted Users under the applicable Master Agreement. You should be mindful that, where applicable, the default sharing option for User-Uploaded Information is typically "public," and, if you wish to restrict access, you should review any other sharing options made available under the Products for the applicable Customer account. If you have any questions concerning shared access among authorized users within the same business account, you should speak with an Account Manager. Also, please note that, with respect to certain Products, a Customer may specify a designated user with special rights to access all User-Uploaded Information within the Customer's applicable account, including all information uploaded by you as well as your personal information and related activities and that of any other users under the same Customer account. Again, if you have any questions about such access, you should speak with an Account Manager.

Custom Audience

We may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases or other individuals with similar interests ("Custom Audience Ads"). This is done by matching common factors between our databases and the databases of the third-party services (such as a hashed email address or other contact information). For instance, we may use such ad services offered by Facebook or Twitter and other third-party services. To withdraw your consent for our use of your information for custom audience purposes on third-party services, please contact us at

If we use Facebook, Google, Twitter, or other third parties to serve Custom Audience Ads on their services, you should be able to go to your account settings for those services to find out what options you have to control such ads through those services. We are not responsible for such third parties' failure to comply with your or our opt-out instructions, they may not give us notice of your opt-outs to our ads that you give them, and they may change their options without notice to us or you.

Information Sharing

Except as set forth in this Privacy Policy and as required or permitted by law, we do not sell or share your personal information with third parties without your consent. We are responsible for personal information that has been transferred to a third party for processing.

We may share personal information among affiliates within the PGL family of companies, our employees, consultants, or agents, for purposes of providing the Products and our services and, occasionally, to contact you (subject to any applicable legal requirements) regarding additional products  and services that may be of interest to you. We may also share your information in other ways we may describe when you provide your information, or for another purpose with your consent. In the regular course of business, we provide personal information to our service providers  so that they may assist us in connection with operating our Products. We use third parties to process data, host and manage the Products, and to handle payment processing. Our service providers are given the information they need to perform their designated functions, and are   not authorized to use or disclose personal information for their own   marketing or other purposes. We also require our service  providers,  via contractual measures or other means, to have appropriate safeguards in place to protect your personal information.

In accordance with applicable law, we may also share information to a buyer or other successor in the event of a merger, acquisition, bankruptcy or other transaction, in which personal information held by us about you is among the assets transferred.

Your personal information may be maintained and processed by us, our affiliates and other third party service providers in the US or other foreign jurisdictions. In the event that personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

Legal and Compliance

We may use and may provide our service providers or any third party for their use your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law or legal process. Your personal information may also be disclosed where necessary or desirable for the establishment, in the exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Information Security

We are committed to maintaining the security of personal information. We employ reasonable administrative, technical and physical security measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information to employees and authorized service providers who require access to fulfill their job requirements.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

User-Uploaded Information

Our Products may permit the uploading, posting, storage or viewing of contact information or other content submitted by you or another authorized user under an applicable Master Agreement ("User-Uploaded Information"). You, the Customer and other authorized users are responsible for appropriate handling of any and all User-Uploaded Information in compliance with our Terms of Service and any and all applicable privacy, data security, and other laws and regulations. In particular, you must ensure you have obtained proper consent to submit to PGL any personal information contained in User-Uploaded Information. PGL may access User-Uploaded Information for the purpose of addressing a system, security, or support issue, or a suspected violation of our Terms of Service, and as otherwise necessary or appropriate in connection with PGL's provision of Products.

Access to Personal Information and Withdrawal of Consent

You have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. If you would like to make any of these requests with respect to the personal information we have in our custody or control, please do so by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records and may restrict access to personal information as required or permitted by applicable law or legal process.

You may withdraw or modify your consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to us. If you withdraw your consent to receive information regarding certain products, publications, services or events being offered by us, you may not be made aware of same. Refusal or withdrawal of consent from collection of your personal information may result in you not being able to access the Products.

Personal Information of Children

We do not knowingly collect, maintain or use any personal information from children under the age of 13. If we become aware that we have collected the personal information of children, we will take steps to delete such personal information unless otherwise required by law.

Third-Party Websites

The Products may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our service and go to another site. During this process, another entity may collect personal information from you.

Updates to Privacy Policy

We may update this Policy from time to time as required to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices.

How to Contact Us

Your questions, comments and feedback are very important to us. For privacy-related issues, please contact us at