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Privacy Policy

The M-Partners may collect certain Personally Identifiable Information (“PII”) about you through our website. This Privacy Policy contains important information on how and why we collect, store, use, and share your information, as well as your rights concerning your PII.

PII Collection, Use, and Sharing. We only have access to/collect information that you voluntarily provide via email or other direct contact from you.  This information may include the following PII that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household: your name, email address, and professional or employment-related information.   This website and our services are not intended for those under the age of 18.  We do not knowingly collect information for anyone under the age of 18, and anyone under the age of 18 is not permitted to use the website.

Our website may also use “cookies” to collect certain information from all users.  A cookie is a string of data our system may send to your computer and then use to identify your computer when you return to our website.  Cookies give us usage data, like how often you visit, where you go at the site, and what you do.

We will only use your PII if we have a proper reason for doing so, including:

• We will use this information to respond to you regarding the reason you contacted us,

• To comply with our legal and regulatory obligations;

• For the performance of our contract with you or to take steps at your request before entering into a contract;

• For our legitimate interests or those of a third party;

• To enforce our website terms of service;

• To compile statistical information for analysis of our website; or

• Where you have given consent.

We will always treat your PII with the utmost respect and never sell it to other organizations for marketing purposes.  We may share your PII with:

• Our affiliates, including companies within The M-Partners group;

• Service providers we use to help us run our business and deliver our products and/or services to you, such as payment service providers, subcontractors, and website hosts;

• Third parties approved by you;

• Credit reporting agencies;

• Our insurers and brokers;

• Our bank;

• Our attorneys; and/or

• Law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Keeping Your PII Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and follow top industry standards for information security. Unfortunately, even with these measures, we cannot guarantee the security of PII.  By using our website, you acknowledge and agree that we make no such guarantee, and that you use our website at your own risk. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Transfer of PII abroad. If you utilize our services from a country other than the country where our servers are located, your PII may be transferred across international borders, which will only be done when necessary for the performance of our contract with you, when we have your consent to do so, or when the appropriate standard contractual clauses are in place.  If you would like further information, please contact us at privacy@m-partners-inc.com.

Your Rights Under the GDPR.  You have the following rights under the General Data Protection Regulation (“GDPR”):

• The right to be provided with a copy of your personal information (the right of access);

• The right to require us to correct any mistakes in your personal information;

• The right to require us to delete your personal information—in certain situations;

• The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data;

• The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations;

• The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you;

• The right to object (1) at any time to your personal information being processed for direct marketing (including profiling);
(2) in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About YouYou have the right to know:
• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information, if any; and
• The specific pieces of personal information we have collected about you.
Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business PurposeIn connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, send an email to privacy@m-partners-inc.com with your opt-out notice.

Right to DeletionSubject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against DiscriminationYou have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

How to Exercise Your Rights. We hope that we can resolve any query or concern you raise about our use of your information. If you would like to exercise any of your rights as described in this Privacy Policy, please email us at privacy@m-partners-inc.com. Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly by email, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number))];

• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

The GDPR gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. You may find your supervisory authority by visiting this website: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Changes to This Privacy Policy. This privacy notice was last updated on May 7, 2021. We may change this Privacy Policy at any time by posting a new version on this page or on a successor page.  The new version will become effective on the date it’s posted, which will be listed at the top of the page as the new effective date.

How to Contact Us. Please contact our Privacy Officer by email at privacy@m-partners-inc.com if you have any questions about this Privacy Policy or the information we hold about you.

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