Privacy policy
This is a very detailed Privacy Notice, likely adapted from a larger corporate standard (Docusign references are visible). For MPOVR, an online IT training company, we need to:
Remove Docusign-specific references: Replace all “Docisign” mentions with “MPOVR.”
Streamline/Focus “Customer Data”: Rephrase sections that refer to “customer data” being processed “on behalf of customers” as a “data processor,” as MPOVR’s primary relationship is directly with the “Learner/User.” While MPOVR might use third-party tools, MPOVR itself is the controller of its learners’ data.
Simplify AI Model Training/Customer Data: Make the AI section specific to MPOVR’s likely use cases (e.g., improving training content, personalized learning paths) rather than generic “eSignature, Contact Lifecycle” data.
Clarify “Other Contacts Data”: It’s unlikely an IT training app needs “Other Contacts Data” from a device.
Placement Assistance: Ensure the data collection and sharing for placement assistance is clearly stated and linked to explicit consent for eligible U.S. learners.
Global Compliance: Ensure the language around GDPR, CCPA, and international transfers remains robust and tailored to MPOVR’s context.
Contact Information: Update all contact emails and addresses to MPOVR’s specific details.
Remove irrelevant country-specific sections: Some sections (like Brazil’s “controller is MPOVR Brasil Soluções Em Tecnologia Ltda”) imply local subsidiaries which MPOVR might not have. Focus on the US entity with global reach.
Make “DocuSign” references into MPOVR links.
Here’s the revised Privacy Notice, tailored for MPOVR:
MPOVR Privacy Notice
Version Date: February 20, 2025
Last Updated: February 20, 2025
Purpose
At MPOVR, protecting your privacy is a key priority. This document sets out how MPOVR and its affiliates (“us,” “our,” or “we”), a U.S.-based online IT training company, collect, use, store, or otherwise process personal information about individuals (collectively “you”) who access or use our websites, including mpovr.us, our mobile applications, our web client or professional client, and/or any of our other websites, products, or services that link to this Privacy Notice (the “Services”). By using our Services, you understand that we will collect and use your personal information as described in this Privacy Notice.
In certain circumstances, MPOVR may process your personal information as a data processor when we utilize third-party platforms or tools on behalf of our primary service delivery. However, for the data directly related to your application, enrollment, and participation in our training programs, MPOVR acts as the data controller. This Privacy Notice (“Notice”) does not apply to any third-party websites and apps that you may use, including those to which we link within our Services. You should review the terms and policies for third-party websites and apps before clicking on any links.
MPOVR’s core Services help users obtain advanced Cloud ERP skills with various IT specializations, such as undergoing a 90-day intensive technical training in Workday Integrations. As part of our Services, we collect and record information that assists learners with their training, assessments, and, for eligible U.S. learners, placement. This includes information about individuals involved in learning programs, interactions with placement partners, and the devices used to access our Services.
We recommend that you read this Notice in full to ensure you are fully informed about the way we collect, use, store, or otherwise process your personal information, as well as your privacy rights. For quick navigation, please refer to the table of contents below:
Table of Contents:
Collection of Personal Information
Use of Personal Information and Lawful Bases for Processing
Disclosure of Personal Information
Retention of Personal Information
Your Choices
Your Privacy Rights and Choices
Children’s Privacy
Notice to California Residents
How We Protect Your Personal Information
Changes to This Privacy Notice
How to Contact Us
Supplemental Privacy Disclosures for Customers and Users in Certain Countries
1. Collection of Personal Information
You have choices about whether you visit our websites, install our apps, or provide personal information to us. However, if you do not provide us with certain personal information, you may not be able to use some functionalities of our Services. For example, if you do not enroll in any of our programs, you will not be able to access our learning services. For choices and rights you may have, please see Sections 5 and 6 of this Notice.
Personal Information We Collect from You: You provide us with personal information about yourself when you:
Register or log in to your account.
Start, sign up for, or review the enrollment process.
Create or edit your user profile.
Contact support.
Comment on our blogs or in community forums.
Access and participate in our learner community.
Leave comments or provide feedback.
Refer friends (if a referral program is active).
Your main choice for this type of personal information is simply not providing it, such as by not creating a profile or not leaving a comment in a blog. For other choices you may have, please see Section 5 of this Privacy Notice.
Examples of the categories of personal information you may provide are:
Identifiers and Contact Information: This includes your name, email address, mailing address, phone number, or electronic signature.
Commercial Information: This includes billing and payment information (e.g., credit card number, expiration date, visual cryptogram – processed by third-party secure gateways), and products or services purchased.
Your Account Data: This includes your login information (email and password) and user profile information (contact details, including your name, email address, and photo, if uploaded).
Customer Service and Communications Information: This includes questions and other messages or feedback you address to us directly through online forms, by email, or via our feedback surveys or customer support channels. If you use any of our chat features, we may collect personal information you voluntarily provide during your interactions, such as your name, email address, contact details, or any other information you choose to share, and retain a transcript of your chats for the purposes set forth in this Notice.
Educational/Professional Information: Details about your academic record, professional experience, certifications, and English proficiency, as provided in your application.
Practicum/Placement Information: Information related to your commitment to a practicum, performance in assessments, and, for eligible U.S. learners, career goals and job application history (with explicit consent for sharing).
Personal Information We Collect Automatically: We may automatically collect personal information from you and your devices when you use our Services, including when you visit our websites or apps without logging in. For choices you may have on what information we automatically collect, please see Section 5 of this Privacy Notice.
We collect personal information about how you use our Services and the devices (e.g., computers, mobile phones, tablets) you use to access our Services. This may include, but is not limited to, the following:
Device Data: This includes IP address, unique device identifiers, and device attributes, such as operating system and browser type.
Usage Data: This includes web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date(s) and time(s) you used our Services, the frequency of your use of our Services, error logs, and other related information (e.g., course progress, quiz attempts).
Transactional Data: This includes IP addresses and authentication methods related to purchases, subject line, history of actions that individuals take in connection with transactions (e.g., purchase, enrollment, payment), and information about those parties’ devices.
Marketing and Advertising Data: This includes your interests based on your use of our marketing websites and other online services, preferences in relation to receiving marketing materials from us, communication preferences, and your preferences for particular products and services.
Some of the information we collect automatically is captured using cookies, which are text files containing small amounts of information that are downloaded on your device, or related technologies, such as web beacons, local shared objects, and tracking pixels, to collect and/or store information. For additional information about cookies and related technologies, including details of how to opt-out, please read our Cookies Notice ([Link to MPOVR Cookie Policy]).
Personal Information We Collect from Other Sources: Subject to applicable law, we may collect personal information about you from others, such as:
Third-Party Sources: Examples of third-party sources include marketers, partners, researchers, affiliates (companies under common ownership or control of MPOVR), and service providers where they are legally allowed to share your personal information with us. For example, if you register for our Services on another website, that website may provide your personal information to us.
Third-Party Integrations: You may connect third-party integrations to your MPOVR account and the Services (e.g., a specific CRM or project management tool used within a program), which may access data or send information to and from your MPOVR account. It is your responsibility to review any third-party integrations you authorize. Certain features of third-party integrations may use, transfer, and/or store your data or information outside of the Services, and MPOVR is not responsible for any such use, transfer, or storage. Please carefully review the permissions you grant to third-party integrations. MPOVR may collect information about what types of integrations you use in your account.
Combining Personal Information from Different Sources: We may combine the personal information we receive from other sources with personal information we collect from you (or your device) and use it as described in this Notice.
2. Use of Personal Information and Lawful Bases for Processing
In general, and subject to applicable law, we will use your personal information to provide, maintain, and improve our Services, develop new Services, and market our MPOVR products and Services. Please see the table below for more specific information on these purposes, examples of the types of information processed, and the lawful bases (i.e., legal grounds) on which we rely to process it.
Lawful Basis for Processing Your Personal Information: Where applicable data protection law requires a lawful basis for processing, MPOVR acts as a data controller for the personal information described in this Notice. Our lawful basis for collecting and using your personal information will depend on the type of personal information concerned and the specific context in which we collect or use it.
We normally collect or use personal information only where we need the personal information to perform a contract with you (e.g., to deliver training services), where the processing is in our legitimate interests (e.g., to operate, provide, and improve the Services; for marketing purposes not requiring consent), and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information, or may need the personal information to protect your vital interests or those of another person. In certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data.
If we process sensitive personal information about you, as well as ensuring that one of the lawful bases referenced above applies, we will make sure that one or more of the grounds for processing sensitive personal information applies (e.g., explicit consent).
Further Information on the Personal Information We Process and Our Purposes:
The table below provides more specific information on our purposes, the types of information that may be processed, and the legal bases on which we process it. The examples provided in the table cannot, of course, be exhaustive.
Depending on the jurisdiction in which you live, there may be other applicable lawful bases for processing your personal information that are not listed here. If you have questions about our lawful bases or need further information, please contact us using the contact details provided in Section 11 of this Notice.
Purpose Examples of personal information that may be processed Lawful basis for processing
Provide you with and collect payment for the Services you request Identifiers and Contact Information, Commercial Information, Account Data, Customer Service and Communications Information, Transactional Data, Device Data, Location Data (general, not precise GPS) Contract (to fulfill our agreement with you)
Consent (in the case of processing of Location Data, where required by applicable law)
Create your account and manage your relationship with us Identifiers and Contact Information, Account Data, Customer Service and Communications Information, Location Data (general, not precise GPS) Contract (to fulfill our agreement with you)
Legitimate interests (to operate, provide, and improve the Services; or to communicate with you, where not necessary to perform a contract)
Consent (in the case of processing Location Data, where required by applicable law)
Record details about your program participation and progress Identifiers and Contact Information, Account Data, Usage Data, Transactional Data (related to learning activities) Contract (to fulfill our agreement with you)
Legitimate interests (to track learning progress, provide personalized learning, improve course effectiveness)
Gather and record data associated with enrollment into MPOVR programs Identifiers and Contact Information, Educational/Professional Information, Transactional Data Contract (to assess eligibility and form agreement)
Legal obligation (for certain record-keeping requirements)
Maintain and improve the security of the Services Account Data, Device Data, Usage Data, Transactional Data, Location Data (general, not precise GPS) Legitimate interests (to operate, provide, and improve the Services; to detect or prevent illegal activities; to manage the security of our IT infrastructure and the Services, and the safety and security of our employees, customers, and vendors)
Troubleshoot the Services, including support, education, and dispute resolution Identifiers and Contact Information, Account Data, Customer Service and Communications Information, Device Data, Usage Data, Transactional Data Legitimate interests (to operate, provide, and improve the Services; and to communicate with you)
Prevent, investigate, and respond to fraud, unauthorized access, or policy breaches Identifiers and Contact Information, Account Data, Device Data, Usage Data, Transactional Data, Location Data (general, not precise GPS) Contract (to enforce terms)
Legitimate interests (to operate, provide, and improve the Services; to detect or prevent illegal activities; and/or to manage the security of our IT infrastructure and the Services, and the security of our employees, customers, and vendors)
Analyze, improve, and enhance the Services and research/develop new features/products Customer Service and Communications Information (product feedback), Device Data, Usage Data, Transactional Data, Location Data (general, not precise GPS) Consent (where required by applicable law)
Legitimate interests (to operate, provide, and improve the Services; and use insights to research and develop new products and services)
AI Model Training (for internal product improvement) De-identified or anonymized usage and transactional data (with customer consent where identifiable data might be used) Consent (where required under applicable law)
Legitimate interests (to improve our products and services; to enhance learning personalization and efficiency). We design systems to minimize use of identifiable personal information for AI training.
Deliver content and tailored advertising; support marketing efforts Account Data, Usage Data, Marketing and Advertising Data Consent (where required under applicable law, especially for targeted advertising)
Legitimate interests (to improve our business; to promote our products and services; and to use insights to improve or develop our marketing activities)
Send information about new features, products, or special events Identifiers and Contact Information, Marketing and Advertising Data Consent (where required under applicable law, e.g., for email marketing)
Legitimate interests (to improve our business; to promote our products and services; and to develop marketing activities)
Run surveys, sweepstakes, contests, and refer-a-friend programs Identifiers and Contact Information, Account Data, Customer Service and Communications Information Legitimate interests (to drive customer engagement; to promote our products and services; and to collect user feedback)
Comply with legal and regulatory obligations Identifiers and Contact Information, Account Data, Commercial Information, Transactional Data, Location Data (general, not precise GPS), Customer Service and Communications Information Legal obligation
Protect our legal rights (e.g., to establish, exercise, or defend legal claims) Any information relevant or potentially relevant to a dispute or legal proceeding affecting us. Legitimate interests (to protect our business interests, enforce our Terms and Conditions)
Placement Assistance (for eligible U.S. Learners) Identifiers and Contact Information, Educational/Professional Information, Practicum/Placement Information (with your explicit consent to share for this purpose) Consent (explicit consent for sharing with third-party employers/partners)
Contract (to provide placement assistance as part of the service agreement)
Legitimate interests (to support career outcomes for our learners)
Other Uses We may aggregate the personal information we collect, or insights generated or derived from the use of our Services, or remove pieces of personal information (“de-identify”) to limit or prevent identification of any particular user or device to help with goals like marketing, research, and product development (including training our artificial intelligence models that power certain of our Services). Where such information has been aggregated and anonymized so that it is no longer considered personal information under applicable data protection law, this Notice does not apply. N/A (as de-identified or anonymized data is no longer personal data)
AI Model Training: AI models must be trained in order to perform accurately. Through training, an AI model learns to recognize patterns and make predictions. MPOVR has implemented role-based access controls and technical and organizational security measures to help minimize the privacy impact to individuals when we train our AI models. We intentionally design our systems with functionality to avoid training models using personal information that could identify individuals (except when we have consent from a customer to do so). MPOVR is committed to developing our Services that involve AI technology in accordance with our AI Innovation Principles.
3. Disclosures of Personal Information
Subject to applicable law, including to the extent applicable law requires us to obtain consent, we may disclose personal information as follows:
Service Providers: We disclose your personal information to service providers we use to support our Services. These companies provide services like intelligent search technology, intelligent analytics, advertising, authentication systems, bill collection, fraud detection, and customer support. We have contracts with our service providers with applicable privacy and data protection language and controls that require the safeguarding and lawful and proper use of your personal information.
Affiliates: We may disclose your personal information to other companies under common ownership or control with MPOVR (if any). These companies use your personal information as described in this Notice.
Joint Marketing Partners: We may provide your personal information to sponsors of events, webinars, or sweepstakes for which you register, or other parties with whom we may engage in joint marketing activities.
Advertising and Marketing Partners: We may allow third-party advertising and marketing technologies and parties that support our advertising and marketing efforts (e.g., ad networks, ad measurement services, advertising analytics providers, remarketing providers, etc.) on our marketing websites that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the marketing websites and other websites you visit and applications you use. Note that we do not deploy third-party advertising cookies in our core learning product interfaces (the logged-in areas used by learners) or disclose learner performance data to advertising and marketing partners.
Public or Government Authorities: We may disclose your personal information to comply with our legal obligations, regulations, or contracts, or to respond to a court order, administrative, or judicial process, such as a subpoena, government audit, or search warrant where we are legally compelled to do so. We also may disclose your information when there are threats to the physical safety of any person, violations of MPOVR policies or other agreements, or to protect the legal rights of third parties, including our employees, users, or the public.
Corporate Transactions: Your personal information may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual reorganization, sale, merger, consolidation, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding). If a corporate transaction occurs, we will provide notification of any changes to the control of your information, as well as choices you may have.
Consent: We may disclose your personal information in other ways if you have asked us to do so or have given consent. For example, with your consent, we may post user testimonials that may identify you.
Other MPOVR users: When you allow others to access, use, or edit content in your account for your benefit (e.g., group projects or shared learning spaces), we provide that content to them.
Public Information:
User-Generated Content: When you comment on our blogs or in our community forums, this information may also be read, collected, and used by others.
Profile Information: When you create an MPOVR profile, other MPOVR users can view certain aspects of your profile information. If you would like to make this information private, please visit your account settings.
Placement Partners (with your explicit consent): For eligible U.S. Learners who opt-in for placement assistance, we may share relevant personal and performance data with our partner networks to facilitate career opportunities.
4. Retention of Personal Information
We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our data retention policy and information handling standards. Generally, this means we retain your personal information to comply with any retention compliance obligations or statutory requirements or for purposes of performing a contract with you. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it through implementing appropriate organizational, technical, and security measures.
5. Your Choices
This section describes many of the actions you can take to change or limit the collection, use, storage, or other processing of your personal information.
Profile: You are required to fill out a profile, and you can access and review this personal information. If any personal information is inaccurate or incomplete, you can make changes in your account settings.
Marketing Messages: You can opt out of email marketing messages we send you by clicking on the “unsubscribe” link in the email message or unsubscribe here ([Link to MPOVR Preference Center or generic unsubscribe link]). Please note that we may send you one message to confirm that you want to opt-out. If you are a registered user of our Services, or if you have engaged in transactions with us, we may continue to send transactional or relationship messages after you opt out of marketing messages. If you would like your phone number added to our internal Do-Not-Call list to opt out of telemarketing messages, please contact us via the MPOVR Privacy Request Portal ([Link to MPOVR Privacy Request Portal]). Please include your first name, last name, username, and phone number. You can also let us know at any time, including during a telemarketing call, that you do not want to be called again for telemarketing purposes.
Cookies and Other Related Technology: You can decline cookies through your browser settings or via the MPOVR Cookie Preference Center and other methods detailed in our Cookie Notice ([Link to MPOVR Cookie Policy]). However, if you decline cookies, you may not be able to use some parts of our Services. Please note we do not recognize or respond to browser-initiated Do Not Track signals.
Device and Usage Information: If you do not want us to see your device location (beyond general IP-based geolocation), you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.
Complaints: We are committed to resolving valid complaints about your privacy and our collection, use, storage, or other processing of your personal information. For questions or complaints regarding our data use practices or this Notice, please contact us via the MPOVR Privacy Request Portal ([Link to MPOVR Privacy Request Portal]).
6. Your Privacy Rights and Choices
Rights Regarding Your Personal Information: You may have certain rights related to your personal information, subject to local data protection laws, as described in more detail below. To exercise any of these rights, please contact us via the MPOVR Privacy Request Portal ([Link to MPOVR Privacy Request Portal]). If you are a California resident, you can find more information about your rights with respect to your personal information in Section 8 (“Notice to California Residents”) below.
You also can request the following information: how we collect and use your personal information and why; the categories of personal information involved; the categories of recipients of your personal information; how we received your personal information and its source; our business purpose for using your personal information; and how long we use or store your personal information or the manner in which we determine relevant retention periods.
You have a right to correct inaccurate personal information about you, and you should notify us immediately if you believe the personal information we hold about you is inaccurate, incomplete, or out-of-date.
In certain situations, you can ask that we erase or stop using your personal information, object to or restrict the use of your personal information, or export your personal information to another controller.
Where we rely on your consent to process your personal information, you have the right to decline consent and/or, if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your personal information for direct marketing purposes. See Section 5 (“Your Choices”) of this Notice for more information on your choices.
If you are unsatisfied with our response to your complaint, you have a right to raise questions or complaints with your local data protection authority at any time.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.
If you make a request to exercise the rights referenced above, we will require you to provide certain information for identity verification purposes. If you have an account with us, we may verify you through your login of your account. If you do not have an account with us, we may require you to provide additional information from which we can confirm your identity. You may authorize an agent to make a request to us on your behalf, and we will verify the identity of your agent or authorized legal representative by either seeking confirmation from you or documents that establish the agent’s authorization to act on your behalf.
Certain personal information may be exempt from such requests under applicable law. We need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services.
If you wish to exercise these rights, please contact us via the MPOVR Privacy Request Portal ([Link to MPOVR Privacy Request Portal]).
Right to Opt-Out of Sales of Personal Information and Processing of Personal Information for Targeted Advertising Purposes: Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “processing of your information for targeted advertising purposes.”
As explained in Section 3 (“Disclosure of Personal Information”) above, we sometimes disclose information to third-party partners that help us market our products and services to you across platforms. This disclosure of information may be considered a “sale” or “processing of your personal information for targeted advertising purposes” under applicable laws.
Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.
If you would like to opt out of such “sales” or “processing” for targeted advertising purposes through cookies and similar online technologies, please click on the “Your Privacy Choices” link in our website footer ([Link to MPOVR Privacy Choices/Cookie Consent Tool]). Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.
Please note that if you have a legally recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Transfers to the U.S. and Third Countries: Subject to applicable law, we may transfer your personal information outside of your jurisdiction, including for further processing. MPOVR has adopted Standard Contractual Clauses (SCCs) and other appropriate safeguards to facilitate the transfer of personal information from the European Economic Area and/or United Kingdom (“EEA”) to MPOVR outside of the EEA, and to other third countries. Transfers outside the MPOVR group are only made to organizations that agree to adhere to appropriate data protection standards (such as SCCs or other valid alternatives) under data protection law. You may request a copy of these safeguards by contacting us.
7. Children’s Privacy
Our Services are not designed for and are not marketed to people under the age of 18 or such other age designated by applicable law (“minors”). We do not knowingly collect or ask for personal information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your personal information. We delete personal information that we learn is collected from a minor without verified parental consent. Please contact us via the MPOVR Privacy Request Portal ([Link to MPOVR Privacy Request Portal]) if you believe we might have personal information from or about a minor that should be removed from our system.
8. Notice to California Residents
In addition to the other information and rights described in this Privacy Notice, California residents are also entitled to certain additional information and have certain additional rights under the California Consumer Privacy Act (“CCPA”) with respect to their personal information. If you are a resident of California (a “Consumer” as defined by the CCPA), this section of the Privacy Notice applies to you. If you are not a Consumer, this section does not apply to you, and you should not rely on it.
A. Information We Collect and How We Use and Disclose It
Below is a summary of the categories of personal information – including sensitive personal information – that we have collected in the past 12 months leading up to the effective date of this Notice, as well as the purposes for which we use the information and the categories of third parties to whom we disclose or “sell/share” the information.
Categories of Personal Information Collected Purpose of Use Categories of Third Parties to Which Information is Disclosed for Business Purposes Categories of Third Parties to Which Information is Sold/Shared
Identifiers (e.g., name, email address, physical address, phone number, electronic signature, device identifiers, IP address, cookie IDs) Provide and collect payments for the Services.
Communicate with you.
Market our or third parties’ features, products, or special events that may be of interest to you.
Run sweepstakes, contests, and refer-a-friend programs.
Choose and deliver tailored content and advertising.
Analyze and improve the Services and develop new features and products.
Troubleshoot the Services, including answering support questions and resolving disputes.
Manage the Services platform, including support systems and security.
Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior.
Comply with legal obligations.
Meet legal retention periods.
Establish, exercise, or defend our rights in legal claims. Service providers
Payment processors
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent
Placement Partners (with explicit consent) Advertising and marketing partners
Commercial Information, including financial or payment information (processed by third-parties) and transaction information Provide and collect payments for the Services.
Analyze and improve the Services and develop new features and products.
Troubleshoot the Services, including answering support questions and resolving disputes.
Manage the Services platform, including support systems and security.
Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior.
Comply with legal obligations.
Meet legal retention periods.
Establish, exercise, or defend our rights in legal claims. Service providers
Payment processors
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Other parties to the transaction (transaction history information only) N/A – we do not sell/share this information
Customer service information (e.g., questions and other messages you address to us directly through online forms, by email, over the phone, or by post) Provide the Services.
Communicate with you.
Analyze and improve the Services and develop new features and products.
Troubleshoot the Services, including answering support questions and resolving disputes.
Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior.
Comply with legal obligations.
Meet legal retention periods.
Establish, exercise, or defend our rights in legal claims. Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent N/A – we do not sell/share this information
Internet or other electronic network activity information (e.g., IP address, device identifiers, device attributes, cookie IDs, data about how you interact with the Services) Provide the Services.
Market our or third parties’ features, products, or special events that may be of interest to you.
Choose and deliver tailored content and advertising.
Analyze and improve the Services and develop new features and products.
Troubleshoot the Services, including answering support questions and resolving disputes.
Manage the Services platform including support systems and security.
Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior.
Comply with legal obligations.
Meet legal retention periods.
Establish, exercise, or defend our rights in legal claims. Service providers
Affiliates
Entities for legal and security purposes
Entities for sales or transfer of business or assets
Others with your consent.
B. The Right to Opt-Out of Sales/Sharing of Personal Information
Consumers have the right to opt out of “sales” of their personal information or “sharing” of their personal information for cross-context behavioral advertising purposes under the CCPA. As explained in our Privacy Notice above, we may allow third-party advertising and marketing technologies and parties that support our advertising and marketing efforts (e.g., ad networks, ad measurement services, advertising analytics providers, remarketing providers, etc.) on our Services that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use. This type of information collection and disclosure can be considered to be a “sale” or “sharing” for cross-context behavioral advertising purposes under the CCPA.
Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.
If you would like to opt out of such “sales” or “processing” for targeted advertising purposes through cookies and similar online technologies, please click on the “Privacy” link in our website footer. If you have a legally recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
C. Information Rights
Consumers have other rights with respect to their Personal Information under the CCPA. This includes the right to request that we:
Provide you the categories of personal information we have collected or disclosed about you in the last 12 months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of specific pieces of information we hold about you.
Delete certain information we have about you.
Correct inaccurate personal information we have about you.
You may have the right to receive information about the financial incentives that we offer to you (if any). You have the right not to be discriminated against for exercising your CCPA rights. We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to Consumers who choose to exercise their CCPA rights.
Consumers may submit requests to access, delete, or correct their personal information using any of the following methods:
You may contact us via the MPOVR Privacy email (privacy@mpovr.us).
You may contact us by mail as outlined in Section 11.
For security purposes, we will attempt to verify your identity prior to fulfilling your request. If you have an account with us, we may verify your identity through your login to your account. If you do not have an account with us, we may need to respond to your request or otherwise contact you to request additional information from you to verify your identity (including, but not limited to your name, email address, or telephone number).
If we can verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you, or we may deny your request. If we are unable to fulfill your request in its entirety, we will provide further information to you about the reasons that we could not comply with your request.
Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services.
D. Authorized Agents
Consumers may designate an agent to make CCPA requests on their behalf. For Consumers who do so, we will take steps to verify both the identity of the consumer seeking to exercise their rights as described above, and to verify that the consumer’s agent has been authorized by them to make a request on their behalf by requesting a signed written authorization or a copy of a power of attorney.
E. “Shine the Light”
California residents may ask for a list of third parties that have received your personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. If you are a California resident and would like to request this information, please contact us via email (privacy@mpovr.us).
9. How We Protect Your Personal Information
We have implemented appropriate technical, physical, and organizational measures to protect your personal information from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access, as well as all other forms of unlawful processing. To achieve this, we have developed and implemented an Information Security Management System and other sub-policies and guidelines relating to the protection of your personal information. For example, our staff is permitted to access customer personal information only to the extent necessary to fulfill the applicable business purpose(s) and to perform their job, subject to confidentiality obligations.
10. Changes to This Privacy Notice
We may amend this Notice to reflect changes in the law, our companies, our Services, our data processing practices, or advances in technology. Our use of the personal information we collect is subject to the Privacy Notice in effect at the time such personal information is used. Depending on the type of change, we may notify you of the change by posting on this page, or by email to your registered address.
11. How to Contact Us
For questions or complaints regarding our use of your personal information or this Notice, please contact us at privacy@mpovr.us specifying in detail.
12. Supplemental Privacy Disclosures for Customers and/or Users in Certain Countries
If you reside in one of the following countries, the below Privacy Notice also applies to the processing of your personal information. To the extent there is a conflict between the country-specific language below and the provisions above, the below provisions control to the extent of that conflict.
Australia
Transfers and Disclosures to the U.S. and Third Countries: We may transfer or disclose your personal information to recipients in the following countries: Australia, Brazil, Canada, Germany, United States, France, United Kingdom, Mexico, Singapore, Ireland, Egypt, Israel, India, Japan, Costa Rica, Norway, Philippines, Sweden, Spain, Uruguay, and Georgia.
How We Protect Your Personal Information: Your personal information is likely to be stored on IT infrastructure located within Australia, United States, European Union, and/or Canada.
How to Contact Us: To submit a complaint regarding our compliance with Australian law, please email us at privacy@mpovr.us with details. We will take reasonable steps to investigate the complaint and respond to you within a reasonable timeframe.
Brazil
Your Privacy Rights: In addition to the rights listed above, customers and users located in Brazil have the right to:
Confirm the existence of processing;
Correct inaccurate or out-of-date information;
Request the anonymization, blocking, or elimination of unnecessary or excessive personal information processed in noncompliance with Brazilian data protection law;
Request the revision of decisions made solely on the basis of automated processing of your personal information whenever they affect your interests;
Obtain information about the entities to which we disclose your personal information; and
Brazilian residents may ask for a list of third parties that have received your personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information disclosed. We provide this list at no cost. We will provide this information within 15 (fifteen) days from the date of your request, respecting our commercial and industrial secrecy. If you are a Brazilian resident and would like to request this information, please contact us via the MPOVR Privacy Request Portal ([Link to MPOVR Privacy Request Portal]).
Canada
Transfers to the U.S. and Third Countries: We may transfer your personal information outside of your jurisdiction for further processing where it will be subject to that foreign jurisdiction’s law.
France
Your Privacy Rights:
You have the right to object, on legitimate grounds, to the processing of your personal information, except where we are obliged to process such personal information in compliance with our legal obligations or where we cannot satisfy this request, based on a prohibition from a statutory provision.
Under specific conditions, you have the right to give instructions on how you would like us to store, delete, or disclose your personal information after your death. Please contact us for more information about this.
If you are unsatisfied with our response to a complaint, you have a right to raise questions or complaints with the French supervisory authority (Commission Nationale de l’Informatique et des Libertés – “CNIL”) at any time. You can contact this authority by sending a letter to the CNIL at 3 Place de Fontenoy, 75007 Paris, France, or by phone at +33 1 53 73 22 22.
If you make a request to exercise the privacy rights referenced above, we will take reasonable steps to verify your identity. You may authorize an agent to make a request to us on your behalf. In order to do so, we will verify the identity of your agent or authorized legal representative and require proof of your own identity. We can only satisfy such a request if the documents that establish the agent’s authorization to act on your behalf contain the precise duration and purpose of such authorization, and confirmation of whether your agent is entitled to be the recipient of the information we will send.
Israel
Collection of Personal Information: You are not legally required by law to provide us with the personal information described in Section 1.
Transfers to the U.S. and Third Countries: We may transfer your personal information outside of your jurisdiction for further processing. If you are a resident in a jurisdiction where transfer of personal information related to you to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.
Philippines
How to Contact Us: For questions or complaints regarding our processing of your personal information or this Notice, you may contact by sending an email to privacy@mpovr.us specifying details.