Data Protection & Privacy Review For Marvin20 Feb 2021

Information privacy, also known as data privacy or data protection, is the relationship between the collection and dissemination of data, technology, the public expectation of privacy, legal and political issues surrounding them.
Privacy concerns exist wherever personally identifiable information or other sensitive information is collected, stored, used, and finally destroyed or deleted – in digital form or otherwise. Improper or non-existent disclosure control can be the root cause for privacy issues. Data privacy issues may arise in response to information from a wide range of sources.

Privacy Policy

We recognize that your privacy is very important and take it seriously. This Privacy & Cookies Policy describes Marvin’s policies and procedures on the collection, use and disclosure of your information when you use the services, website and mobile applicationsoffered by Marvin. (the 'Services') and tells you about your privacy rights and how the law protects you. By using the Services, you consent to our use of your information in accordance with this Privacy & Cookies Policy. We will not use or share your personal information with anyone except as described in this Privacy & Cookies Policy. Capitalized terms that are not defined in this Privacy & Cookies Policy have the meaning given them in our Terms of Service.

With that in mind, this Privacy and Cookies Policy is designed to describe:

• Who We Are and How to Contact Us?
• Your Rights Relating to Your Personal Data
• Marketing Communications Preferences
• What Personal Data we collect
• How We Use Your Personal Data and Why
• How We Use Cookies and Other Tracking or Profiling Technologies
• Who We Share Your Personal Data With?
• How long we store your Personal Data
• Where We Store Your Personal Data
• How We Protect Your Personal Data
• Third Parties & Links to Other Websites
• Our Policy on Children's Privacy
• Changes to Our Privacy & Cookies Policy

• This Privacy & Cookies Policy is intended to meet our duties of transparency under the 'General Data Protection Regulation'.
• We will post any modifications or changes to this Privacy & Cookies Policy on this page.

Who We Are and How to Contact Us?

• Who we are? Marvin, a corporation registered in Oakland, is the Controller of your Personal Data (referred to as either 'Marvin', 'we', 'us' or 'our' in this Privacy & Cookies Policy). Our address is 4206 Carson Street, Oakland, CA 94619, United States.
• How to contact us. If you have any questions about our practices or this Privacy & Cookies Policy, please contact us at: [email protected] .

Your Rights Relating to Your Personal Data

You have the right under this Privacy and Cookies Policy to:

• Request access to your Personal Data. If you are within the EU, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
• Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data. If you are within the EU, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent. This right only exists where we are relying on consent to process your Personal Data ('Consent Withdrawal'). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

• How to exercise your rights. If you want to exercise any of the rights described above, please contact us using the contact details in Who We Are and How to Contact Us.
• Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
• Complaints
• If you would like to submit a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected] with the subject: ‘Security / Data Privacy Question’.
• We will reply to your complaint as soon as we can.

Marketing Communications Preferences

You can ask us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:

• by following the opt-out links on any marketing message sent to you; or
• by contacting us at any time using the contact details in Who We Are and How to Contact Us.

• Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to existing or pending hires, using the Services or consent to direct marketing communications.

What Personal Data we collect

Marvin uses Personal Data we collect to provide the Services, personalize content, maintain security, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track user content and users as necessary to comply with the Digital Millennium Copyright Act and other applicable laws.

Information You Directly Provide to Us. There are many occasions when you provide information that may enable us to identify you personally ('Personal Data') while using the Services. The Personal Data we may collect from you is outlined in the table below.

• Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available.
• Aggregated Data. We may also collect, use and share 'Aggregated Data' such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy & Cookies Policy.
• No Special Categories of Personal Data. We do not collect any 'Special Categories of Personal Data' about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences.

How We Use Your Personal Data and Why

We generally use Personal Data for the following: to deliver and improve our Services; to provide you with customer support; to perform research and analysis about your use of the Services; to develop, display, and track Content and advertising tailored to your interests on the Services and other sites, including, potentially, providing our advertisements to you when you visit other sites; website or mobile application analytics; to diagnose or fix technology problems; to automatically update the Services on your device; to verify your identify and prevent fraud or other unauthorized or illegal activity; to enforce or exercise any rights in our Terms of Service;

In respect of each of the purposes for which we use your Personal Data, the legal bases depend on the Services you use and how you use them. This means we collect and use your Personal Data only where:

• We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; or
• We need to process your data to comply with a legal or regulatory obligation.

We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we do rely on your consent to a use of your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place). We have set out below, in a table format, more detailed examples of relevant purposes for which we may use your Personal Data.

• What happens when you do not provide necessary Personal Data? Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Services). In this case, we may have to stop you using our Services.

How We Use Cookies and Other Tracking or Profiling Technologies

Marvin may collect non-personally identifiable information regarding your usage of the Services, including the pages and articles and presentations you viewed, time spent using the website, demographic data such as server locations, connection speed, and other information that does not identify you. Like most online services, we also use cookies, log files, clear GIFs, tracking pixels, web beacons, and other technologies that may collect Personal Data.
Cookies:

What are cookies? When you visit the Services, we may send one or more 'cookies' – small data files – to your computer to uniquely identify your browser and let Marvin help you enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser.

What cookies do we use? Our Site uses the following types of cookies for the purposes set out below:

• How can I disable cookies? You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the 'settings', 'help' 'tools' or 'edit' facility). Many browsers are set to accept cookies until you change your settings.
• If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.
  Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
• Log Files: Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
• Third Party Services: Marvin may use third-party services such as Google Analytics, FB pixels to help understand/improve the use of the Services. These services typically collect the information sent by your browser as part of a web page request, including cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You can also prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
• CalOPPA Disclosures: We do not currently respond to web browsers 'do not track' signals that provide a method to opt out of the collection information about users' activities on the Services and on other websites. If we do so in the future, we will provide relevant information in this Privacy & Cookies Policy.

Who We Share Your Personal Data With?

We may share your Personal with third parties in the ways that are described in the table below. We consider this information to be a vital part of our relationship with you.

• As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.
• We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.
• If you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information.

How long we store your Personal Data

We will retain your information for as long as it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your Personal Data for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Where We Store Your Personal Data

The Services are maintained in the United States of America. Personal Data that you provide us may be stored, processed and accessed by us, our staff, sub-contractors and third parties with whom we share Personal Data in the United States of America or elsewhere for the purposes described in this policy. We may also store Personal Data in locations outside the direct control of Marvin (for instance, on servers or databases co-located with hosting providers). Although we welcome users from all over the world, by accessing the Services and providing us with your Personal Data, you consent to and authorize the export of Personal Data to the United States and its storage and use as specified in this Privacy & Cookies Policy. Note the laws of the United States might not be as comprehensive or protective as laws in the country where you live.

How We Protect Your Personal Data

We use ‘AWS' & ‘Heroku’ for our infrastructure and hosting, we use ‘Salesforce’ as crm software, we use industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to Marvin or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, Marvin will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy & Cookies Policy, or as otherwise required by applicable law.

Marvin cannot ensure that your Personally Data will be protected, controlled or otherwise managed pursuant to this Privacy & Cookies Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.

Third Parties & Links to Other Websites

We may use ‘Mailchimp’ as our email marketing service provider, we may use ‘Hubspot’ as our marketing automation platform, and by requesting our services or using our platform, you acknowledge that you understand and agree to their policies.
This Privacy & Cookies Policy applies only to the Services. Our website may contain links to other websites not operated or controlled by Marvin. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy & Cookies Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our Site, is subject to that website's own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Our Policy on Children's Privacy

Our Services are not directed to or intended for use by children under 18 years of age. If you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 18. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under the age of 18. If we learn that we have received any Personal Data directly from a child under age 18, we will use that Personal Data only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s Personal Data. If you believe that a child under 18 may have provided us with Personal Data, please contact us.

Changes to Our Privacy & Cookies Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy & Cookies Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy & Cookies Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our services following the posting of any changes to this Privacy & Cookies Policy means you consent to such changes.