Monaco Privacy Notice
Last Updated: December 30, 2025
This Privacy Notice applies to the processing of personal information by Irwin, Inc. d/b/a Monaco ("Monaco," "we," "us," or "our") including on our website available at https://monaco.com/, our mobile application, and our other online or offline offerings that link to, or are otherwise subject to, this Privacy Notice (collectively, the "Services").
Disclosure Regarding Customer Data. This Privacy Notice does not apply to the personal information that our customers independently provide to us about their leads, prospects, customers, and other business contacts pursuant to a written agreement we have entered into with such customers ("Customer Data").
Examples of Customer Data that we may process on behalf of our customers may include:
CRM and Email Inbox Data: Our customers may provide us with personal information from their CRM systems and email inboxes.
Call Recordings: Our Services may allow our customers to record conversations and meetings with third parties including, without limitation, sales leads or prospects. If our Services are used for such recordings, we and our third-party service providers may collect content generated and/or recordings in conversations and meetings, including but not limited to, an audio recording of the entire conversation, transcriptions, transcript edits and recommendations, and meeting summaries.
Our customers' respective privacy notices or policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer.
1. Updates to This Privacy Notice
We may update this Privacy Notice from time to time in our sole discretion. If we do, we'll let you know by posting the updated Privacy Notice on our website, and we may also send other communications.
2. Personal Information We Collect
We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account.
Transactions. We may collect personal information and details associated with your transactions on the Services, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the surveys.
Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered "public."
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and resume or CV.
B. Personal Information Collected Automatically
We may collect personal information automatically when you use the Services.
Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, an approximate location derived from the IP address and precise geo-location information).
Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect personal information through your use of the Services.
Cookies. Cookies are small text files stored in device browsers.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
See "Your Privacy Choices" below to understand your choices regarding these Technologies.
C. Personal Information Collected from Third Parties
We may collect personal information about you from third parties. These third parties may include, but are not limited to, the examples described below.
Third-Party Services. If you access the Services using a third-party website, application, service, products, or technology (each a "Third-Party Service"), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings.
Certain information obtained from Google is subject to the Google API Services User Data Policy.
Third-Party Sources. We may also collect personal information from other commercially available sources including, but not limited to, data co-ops and data brokers ("Leads Data").
3. How We Use Personal Information
We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.
A. Provide the Services
We use personal information to provide the Services, such as: providing access to certain areas, functionalities, and features of the Services; allowing you to review and analyze Leads Data via the Services; creating and supplementing profiles using Leads Data; communicating with you; answering requests; sharing personal information with third parties as needed to provide the Services; sharing Leads Data with third parties as permitted by law; and processing your financial information and other payment methods.
B. Improve the Services and Develop New Products and Services
We use personal information to improve the Services and to develop new products and services.
C. Operate Our Business
We use personal information to operate our business, such as: pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention; carrying out analytics; creating de-identified and/or aggregated information; processing applications if you apply for a job we post on our Services; allowing you to register for events; enforcing our agreements and policies; and carrying out activities that are required to comply with our legal obligations.
D. Marketing
We may use personal information in connection with our marketing activities including to tailor and provide you with marketing communications, promotions, and offers that may interest you.
E. With Your Consent or Direction
We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.
4. How We Share Personal Information
We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide the Services
We may share any of the personal information we collect with the categories of third parties described below.
Leads Data Shared with Monaco Customers. We may share Leads Data with Monaco customers, including in exchange for monetary or other valuable consideration. For clarity, Leads Data is data that we independently source and provide to our customers. Leads Data is not Customer Data.
Any Leads Data shared with a Monaco customer will be subject to the Monaco customer's privacy policy. We are not responsible for the processing of Leads Data by Monaco customers.
Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting services, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be shared with service providers that help provide our chat features.
Other Users You Share or Interact With. The Services may allow Monaco users to share personal information or interact with other users of the Services.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use a Third-Party Service.
Any personal information shared with a Third-Party Service will be subject to the Third-Party Service's privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Business Partners. We may share your personal information with business partners we work with to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Once your personal information is shared with our business partner, it will also be subject to our business partner's privacy policy. We are not responsible for the processing of personal information by our business partners.
Monaco Customers (Authorized Users Only). In cases where you use our Services as an employee, contractor, or other authorized user of a Monaco customer, we may share any information associated with your use of the Services with the Monaco customer, including, but not limited to, account information, usage information, files, and the contents of the communications associated with your account. Your personal information may also be subject to the Monaco customer's privacy policy. We are not responsible for the Monaco customer's processing of your personal information.
Affiliates. We may share your personal information with our corporate affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies on our Services to collect personal information regarding your activities and your device (e.g., IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this personal information (and similar information collected from other services) to tailor and deliver personalized ads to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising," "personalized advertising," or "targeted advertising."
B. Disclosures to Protect Us or Others
We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.
5. Your Privacy Choices
The privacy choices you may have about your personal information are described below.
Opt-Out of the Sale of Leads Data. In accordance with applicable law, you may have the right to opt out of our sale of your Leads Data to third parties. To exercise this right, please email sam@monaco.com. We will process requests in accordance with applicable law.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Notice).
Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in "Contact Us" below.
Mobile Devices. We may send you push notifications through our mobile application. You may opt out of receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services or contact us using the information set forth in "Contact Us" below.
"Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.
Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of certain tracking on some mobile applications by following the instructions for Android, iOS, and other mobile operating systems.
The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative and the Digital Advertising Alliance.
Please note you must separately opt out in each browser and on each device.
6. International Transfers of Personal Information
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.
7. Children's Personal Information
The Services are not directed to children under 16, and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in "Contact Us" below.
8. Contact Us
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: sam@monaco.com.