“Personal Information” is information, whether true or not, that can be used to identify you (whether alone or in combination), which may include:
Postal Address (including billing and shipping address);
HOW WE COLLECT INFORMATION
We collect information about your use of our Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, and related data, and store it in log files.
We may receive your Personal Information from other sources, such as public databases, joint marketing partners and social media platforms, and combine that with information we collect about you. To the extent we combine such third-party sourced information with Personal Information we collect directly from you, we will treat the combined information as Personal Information. We are not responsible for the accuracy of the information obtained from third parties or third-party practices.
HOW WE USE INFORMATION WE COLLECT
We and our Service Providers may use information about you for the following purposes:
To provide, maintain, protect and improve our Services, develop new services, and protect COMPANY and our users;
To facilitate, manage, personalize and improve your online experience;
To respond to your inquiries and fulfill your requests, such as to send you newsletters, brochures, catalogs and e-mails;
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving, or modifying our Services, identifying usage trends, and operating and expanding our business activities; and
To send you advertisements and communicate with you about products, services, offers, promotions, rewards and events we believe may be of interest to you (for information about how to manage these communications, see Section 13).
If you are a user from the United States, we may use your Personal Information for direct marketing purposes. If you are a user from outside the U.S., we will not use your Personal Information for direct marketing purposes unless we have received your express consent. As a Non-U.S. User, you have the right to opt-out from direct marketing and can require us to cease using the data at any time for direct marketing purpose at no cost to you
HOW WE SHARE INFORMATION
Our agents, vendors, consultants, marketing service providers, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use de-identified data or aggregate information which does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).We may also share information about you as follows:
As necessary, for the following purposes: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence to meet national security or law enforcement requirements; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain;
- With our affiliates for internal business purposes. For example, processing your orders, fulfilling your requests, providing customer service, and improving our products;
- With our subsidiaries, affiliates, business partners, and other third parties for their own business purposes. For example, improving their products and services; and
- To a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Without limiting the forgoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
Sharing for Marketing Purposes
If you are a user from the U.S., we may share your Personal Information with third parties for direct marketing purposes. California residents have further rights, as set out in Section 14. If you are a user from outside the U.S., we will not share your Personal Information with third parties for direct marketing purposes unless we have received your express consent. Users from outside the U.S. have the right to opt-out from direct marketing and can require us to cease to use the data at any time for direct marketing purpose at no cost to you.
ADVERTISING, ANALYTICS SERVICES, AND ONLINE TRACKING
Online Behavioral Advertising
Some information about your browsing of the Services and certain Third-Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Services and certain Third-Party Services. COMPANY may receive information about Third Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising.”
Do Not Track
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
We seek to use reasonable technical and organizational security measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration or destruction. In addition, COMPANY will not keep your Personal Information for longer than necessary for the purposes set out in this policy. Unfortunately, no data transmission or storage system is completely secure, and we cannot guarantee the security of your information collected through our Services. Your Personal Information is stored on servers in the U.S., U.K., and Hong Kong maintained with the assistance of a third-party data storage provider.
COMPANY complies with the Privacy Shield Framework, as set forth by the U.S. Department of Commerce in consultation with the European Commission, regarding the collection, use and retention of Personal Information received from the European Union. As COMPANY is a U.S. company, it has voluntarily decided to comply with the EU – U.S. Privacy Shield Framework and is subject to the investigatory and enforcement powers of the Federal Trade Commission. MWC annually certifies its adherence to the Privacy Shield Principles of: notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. All U.S. entities and subsidiaries listed in our Privacy Shield certification record (as included at the end of this policy below) adhere to the Privacy Shield Principles. To learn more about the EU – U.S. Privacy Shield Framework, please visit https://www.privacyshield.gov/EU-US-Framework. To view MWC’s certification, please visit https://www.privacyshield.gov/list.In the event Privacy Shield is invalidated information of EU residents will only be transferred in accordance with an approved transfer mechanism, including the model contract clauses.
Our Services are not intended for children and are not targeted to children under the age of thirteen (13). If you are a child under the age of thirteen (13) you are not permitted to use the Services and should not send any information about yourself to us.
We do not knowingly collect any Personal Information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with Personal Information without COPPA-required consent, please contact us at admin@COMPANY.com.
ACCESSING AND CHANGING INFORMATION
COMPANY will provide web pages or other mechanisms allowing you to correct or update some of the Personal Information you have provided us.
Users from the European Union, Singapore, Hong Kong, Japan, New Zealand, Mexico, and Australia have a right to access their Personal Information, request corrections and/or deletions, and oppose the use of their Personal Information for specific purposes, subject to exceptions allowed by law. Such users are also entitled to request information on the origin of their Personal Information, the recipients or types of recipients to whom their Personal Information is provided, the reason for which their Personal Information is being stored, and the ways in which their Personal Information has been or may have been used or disclosed by us within a year before the date of the request. If you would like to do so, please send your request in writing by sending an email to admin@COMPANY.com . To protect your privacy and the privacy of others, we will need evidence of your identity before we can grant you access to information about you or change it. You will not be charged for compliance with such a request.
Changes and Deletions
We will make good faith efforts to make requested changes in our then-active databases as soon as practicable (but may retain prior information for records to the extent not prohibited by applicable law). Please note that it is not always possible to completely remove or delete all of your information or public postings from our databases (California minors see Section 11) and that residual data may remain on backup media or for other reasons. We also may retain cached or archived copies of information about you for a certain period of time.Individuals may also exercise the right to be forgotten by emailing admin@COMPANY.com.
CHOICES: TRACKING AND COMMUNICATIONS OPTIONS
- Tracking Technologies Generally.
- Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove cookies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. With respect to our mobile applications, you can stop all collection of information by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling location identifying services, by adjusting the permissions in your mobile device.
- Analytics and Interest-Based Advertising.
- Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for interest-based ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile applications at http://www.aboutads.info/appchoices. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt-out of certain targeted advertising delivered by NAI members' ad networks. To learn more about opting out of targeted advertising or to use the NAI tool, visit http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of targeted advertising, you will continue to receive non-targeted ads. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf). and expect that ad networks we directly engage to serve you interest-based ads will do so as well, though we cannot guaranty their compliance.
You may opt-out of receiving promotional communications (e-mails or text messages) from us at any time by: (i) for promotional e-mails, following the instructions as provided in e-mails to click on the unsubscribe link or changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions as provided in text messages from us to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscriptions may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing or our ongoing business relations.
PRIVACY NOTICE FOR NON-U.S. JURISDICTIONS
Obligation to Provide Personal Information
EU persons must, on occasion provide Personal Information to us as necessary to enter into a contract or as required to fulfill contractual obligations, including providing our products and services, taking payment for products and services we provide, and billing, shipping, and delivery of our products and services. You are free to withhold your Personal Information but without this data it will not be possible to execute the contract or provide you with our products and services. When you make a purchase on or of the Services, you must provide Personal Information to us so that we can meet our legal obligations in accordance with applicable tax and statutory provisions. You are free to withhold your Personal Information, but without this data, it will not be possible to provide you with our products and services.
We sometimes use EU persons’ Personal Information submitted through the Services for automated decision-making. For example, we may display advertisements and send emails to you containing content automatically chosen based on the products or services we have provided to you in the past. However, we will not use EU persons’ Personal Information submitted through the Services for automated decision-making, including profiling, that produces legal effects or similarly significantly affects EU persons.
Legal Bases for Processing
We process your Personal Information with your consent and as required by law. In addition, we process your Personal Information as necessary for the performance of the sales contract, for example, when processing your orders and payments and to take steps, at your request, before entering into a contract with you, for example, by providing you with quotes for products and services. We also process Personal Information as necessary for our legitimate interests as follows:
- Research and Development: To research use of our products and services and to improve, and develop new, products and services;
- Marketing and advertising: To the extent permitted by applicable law, we use your Personal Information regarding products and services you have ordered, or in which you have otherwise demonstrated an interest, as necessary to analyze your interests and to provide you information about the products and services that we think might interest you; and
- Security: We use Personal Information for purposes of facility, network, and information security, fraud prevention, and reporting suspected criminal acts. For example, in the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.
Accuracy and Access to Personal Information
EU persons may request access to their Personal Information under this policy to the full extent required by applicable law in the home country of the person making the request. Such persons may request the correction, amendment, or deletion their Personal Information that is inaccurate or has been processed in violation of the Privacy Shield Principles. COMPANY will reasonably fulfill such requests to the extent required by applicable law.
Users from outside the U.S. have the right to ask us not to process their Personal Information for marketing purposes. We will inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.
You can exercise these rights at any time by contacting us at admin@COMPANY.com or by sending a letter to the addresses set forth in Section 16 below
Right to Object to Processing for Direct Marketing or Legitimate Interests: EU persons have the right to object to the processing of their Personal Information for purposes of COMPANY’s direct marketing or legitimate interests by contacting us at admin@COMPANY.com or by sending a letter to the addresses set forth in Section 16 below.
Revocation of Consent
Users from outside the U.S. also have the right to revoke their given consent regarding the use and sharing of their Personal Information. However, it is important to note that in some cases such request may not be immediately or fully executed because it is possible that we have a legal obligation to keep using your Personal Information. Also, you must consider that for certain purposes, the revocation of consent means that we cannot continue providing the services you requested. You can revoke your consent at any time by contacting us at admin@COMPANY.com or by sending a letter to the addresses set forth in Section 16 below.
Accountability and Inquiries
Any EU person who is not satisfied with COMPANY’s compliance with the EU – U.S. Privacy Shield or other applicable legislation may contact us at admin@COMPANY.com. If any EU person believes that such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administered by the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, or some other dispute resolution procedure. The rules governing these procedures and information regarding how to file a claim free of charge can be found here: http://info.adr.org/safeharbor/.
Any EU person who remains dissatisfied may contact his or her national Data Protection Authority in the country where the person resides. COMPANY has agreed to cooperate and comply with appropriate EU Data Protection Authorities and the Department of Commerce in resolving such disputes. If an EU person remains dissatisfied and meets the pre-arbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke binding arbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here: https://www.privacyshield.gov/EU-US-Framework.