PRIVACY POLICY

This Privacy Policy was last updated on September 23, 2016

Our Policy:

Welcome to the web site of Apifia Inc. d/b/a MAVRCK (“MAVRCK,” “we,” “us,” and/or “our”). MAVRCK owns and operates certain web sites, including http://www.mavrck.co (the “Web Sites”), and makes available other marketing and promotional services, including through various “community” web sites affiliated with Brands (as defined below) (collectively, the Web Sites and such services, including any future features and applications, the “MAVRCK Services”). The MAVRCK Services are designed to offer users of the MAVRCK Services (collectively, “Users,” “you,” or “your”) the opportunity to connect with each other and the third parties to which MAVRCK provides marketing and promotional services (“Brands”), share information about and opinions on products and services offered by our Brands, and participate in certain sweepstakes, contests, challenges and other promotions (“Promotions”). This Privacy Policy sets forth MAVRCK’s policy with respect to information including personally identifiable data, such as your name, address, email address or phone number, (“Personal Data”) and other information that is collected from Users.

Information We Collect:

When you interact with us through the MAVRCK Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the MAVRCK Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the MAVRCK Services or use certain MAVRCK Services, including when done so through their integration into social media services, such as Facebook and Twitter (“Social Media Services”).  Data collected may include: First Name, Last Name, Profile Photo, Email, Birthday, Gender, Location, Hometown, Current City, Current State, Current Country, Brands you mention, Topics/Keywords you use, and your social post performance.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data through the MAVRCK Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of MAVRCK and the authorized third parties, including our Brands, as set forth below.

Other Information:

Passively Collected Data: When you interact with the MAVRCK Services, we and third parties that provide functionality on the Services, may engage, receive, collect and store certain types of information through automatic data collection tools including cookies, pixel tags, web beacons, embedded web links and similar technology.  Such information, which is collected passively using various technologies, may include but is not limited to your Internet Protocol (IP) address, information about your device, referring/exit pages and URLs and number of clicks. MAVRCK may store such information itself or such information may be included in databases owned and maintained by MAVRCK affiliates, Brands, agents or service providers. The MAVRCK Services may use such information and pool it with other information to track, for example, the total number of Users, the number of visitors to each page of our Web Sites, and the domain names of our Users’ internet service providers.

In operating the MAVRCK Services, we may set or access small pieces of data called “cookies” on your computer. A cookie is a piece of information that the computer that hosts our MAVRCK Services gives to your browser when you access the MAVRCK Services. Our cookies help provide additional functionality to the MAVRCK Services and help us analyze Web Site usage more accurately. For instance, the MAVRCK Services may set a cookie on your browser that allows you to access the MAVRCK Services without needing to remember and then enter a password more than once during a visit to a given MAVRCK Service. MAVRCK also permits third parties, including our Brands, to show advertisements on some of the MAVRCK Services and to set and access their cookies on your computer. Third parties’ use of their cookies is subject to their respective privacy policies and these third parties do not have access to MAVRCK’s cookies.  Most browsers allow you to block and delete cookies. However, if you block cookies, some portions of our Services may not work properly. The MAVRCK Services do not respond to Do Not Track signals.

Aggregated Data: We may anonymize and aggregate data collected through the MAVRCK Services and use it for any purpose. Such information does not identify you individually.

Our Use of Your Personal Data and Other Information:

MAVRCK uses the Personal Data you provide in a manner that is consistent with this Privacy Policy.

In general, MAVRCK uses information for the following purposes: to customize the advertising and content you see, fulfill your requests for products and services, improve the MAVRCK Services, contact you, conduct research, and provide reporting to third parties, including our Brands. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the MAVRCK Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. MAVRCK and our Brands may also use your Personal Data and other personally non-identifiable information collected through the MAVRCK Services to help us improve the content and functionality of the MAVRCK Services and to better understand our users. MAVRCK may use this information to contact you in the future to tell you about services or products we believe will be of interest to you or other MAVRCK Services-related announcements. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. MAVRCK reserves the right to send you notifications regarding your account even if you opt-out of all voluntary email notifications.

Our Disclosure of Your Personal Data and Other Information:

We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, financing due diligence, dissolution or similar event, Personal Data may be part of the transferred assets.

Brands: Many of the MAVRCK Services are offered in connection with a specific Brand.  MAVRCK uses the information you provide, including Personal Data, and shares that information with Brands who provide you content targeted to your interests, including opportunities to participate in community forums and other interactive experiences, unless you object as described below.   Brands may use and disclose the Personal Data it receives from MAVRCK Services according to the Brand’s individual privacy policies.

Agents, Service Providers: MAVRCK, like many businesses, sometimes hires other companies to perform certain business-related functions and to help us understand and improve the use of our Services. Examples of such functions include mailing information, database storage and management, MAVRCK Services hosting, processing payments, and direct marketing campaigns. We may share any information we receive with vendors and service providers retained in connection with providing the MAVRCK Services on our behalf and under our instructions. For Personal Data transferred to us from European Union (“EU”) or European Economic Area (“EEA”) member countries under the EU-US Privacy Shield, we will remain liable under the Privacy Shield Principles if third-party agents or service providers that we engage to process the Personal Data on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we will prove that we are not responsible. (Please see further the “Users in the EU and the EEA” section below.)

Legal Requirements: MAVRCK may disclose your Personal Data if required to do so by law, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of MAVRCK or our Brands, (iii) act in urgent circumstances to protect the personal safety of users of the MAVRCK Services or the public, (iv) protect against legal liability or suspected fraud, or (v) investigate, prevent, or take action regarding violations of MAVRCK’s Terms of Use.

For information on your choices and means for limiting use and disclosure of your Personal Data, please see the “Users’ Rights; Contacting MAVRCK” section below.

Account Deactivation and Deletion:

If you no longer desire to use the MAVRCK Services, you may deactivate or delete your account by sending an email to support@mavrck.co. Note that de-activating your account with MAVRCK may not fully remove the data collected from Facebook and other Social Media Services, or the data held or collected by Brands.

Exclusions:

This Privacy Policy does not apply to any information collected by MAVRCK other than Personal Data collected through the MAVRCK Services. This Privacy Policy shall not apply to any unsolicited information you provide to MAVRCK through the MAVRCK Services or through any other means. This includes, but is not limited to, questions, comments, suggestions, ideas, feedback or other information posted provided by a User to MAVRCK or posted by a User to any public areas of the MAVRCK Services, including those integrated with or into Social Media Services (e.g., bulletin boards, community web sites, or your Facebook wall); any ideas for new products or modifications to existing products; and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and MAVRCK shall be free to reproduce, use, disclose, and distribute such Unsolicited Information for any purpose, commercial or otherwise, to others without limitation or attribution.

Children:

MAVRCK does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the MAVRCK Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the MAVRCK Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to MAVRCK through the MAVRCK Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites:

This Privacy Policy applies only to the MAVRCK Services. The MAVRCK Services may contain links to other web sites or provide you the opportunity to post to third party sites not operated or controlled by MAVRCK (the “External Sites”). The policies and procedures we described here do not apply to the External Sites. The links from the MAVRCK Services do not imply that MAVRCK endorses or has reviewed the External Sites. We suggest contacting those sites directly for information on their privacy policies.

Social Media:

Through the MAVRCK Services, you may choose to access certain Social Media Services. When you elect to access and use the Social Media Services, you will be sharing your information (which will include Personal Data) with those Social Media Services. As with other External Sites, the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by the MAVRCK’s policies and procedures. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including MAVRCK. When you provide MAVRCK access to your Social Media Services account, we will collect relevant information necessary to enable the MAVRCK Services to access that Social Media Service, however you will provide your login information, like your password, directly to such Social Media Service (and not to MAVRCK).

As part of the integration of the MAVRCK Services with your Social Media Services account, the Social Media Service will provide MAVRCK with access to certain information that you have provided to such Social Media Service, including but not limited to post-related meta data from your Facebook wall (e.g., post type, date of creation, date of update, post creator, permanent link, and the number of “Likes” and “Comments”). To access your Social Media Services account, we provide a link that directs you to a Social Media Service, like Facebook, where you may access the MAVRCK Services directly. We will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of the applicable Social Media Services provider, and, as a result, MAVRCK shall not have any liability or responsibility for the privacy practices or other actions of Social Media Services that may be enabled within and/or otherwise accessible through the MAVRCK Services.

Security:

You use MAVRCK at your own risk. MAVRCK takes reasonable and appropriate measures to protect the Personal Data provided via the MAVRCK Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the MAVRCK Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to MAVRCK via the Internet. We cannot control the actions of other Users with whom you may choose to share information. Therefore, we cannot, and do not, guarantee that information or content posted by a User on or through the MAVRCK Services will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the MAVRCK Services or Social Media Services.

Other Terms and Conditions:

Your access to and use of the MAVRCK Services is subject to any additional terms applicable to such MAVRCK Services that may be posted on the MAVRCK Services from time to time, including without limitation, MAVRCK’s Terms of Use available athttp://www.mavrck.co/legal/terms-of-use and additional terms and conditions set forth by our Brands, including those related to Promotions.

Changes to MAVRCK’s Privacy Policy:

The MAVRCK Services and our business may change from time to time. As a result, at times it may be necessary for MAVRCK to make changes to this Privacy Policy. MAVRCK reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. MAVRCK strives to provide notifications to Users in a timely manner, but is not responsible for lost or late notifications. If the changes are significant, we will, in our sole discretion, post a notice on the homepage of our Web Sites or notify you at the email address we have on file for your account and provide you with an opportunity to opt-out of your continued use of our Services. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the MAVRCK Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

International Users

If you are using the MAVRCK Services from outside of the United States, you expressly acknowledge and agree that your Personal Data and other information will be processed in the United States and in other third countries. Privacy and data security laws may be  less stringent than or otherwise different from the laws in effect in your country of residence.  You expressly agree to the processing of your Personal Data and other information in accordance with this Policy. If you are using the MAVRCK Services from the EU or the EEA, your Personal Data will be processed in accordance with the Privacy Shield Principles as explained below.

Users in the EU and the EEA

MAVRCK complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from EU and EEA member countries. MAVRCK has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. MAVRCK’s participation in the Privacy Shield applies to all Personal Data MAVRCK receives from the EU and EEA that is subject to this Privacy Policy and MAVRCK commits to comply with the Privacy Shield Principles in respect of such Personal Data. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

MAVRCK is subject to the investigatory and enforcement powers of the Federal Trade Commission and of other relevant US statutory bodies authorized to verify and ensure compliance with the Privacy Shield Principles.

Users’ Rights; Contacting MAVRCK:

You have the right to access the Personal Data in our possession that you have previously submitted via the MAVRCK Services and to correct, change or delete your Personal Data if it is not accurate, outdated or has been processed in violation of the Privacy Shield Principles. You have also the right to object to the disclosure of your information to third parties as described in this Privacy Policy, except for disclosures made to agents and service providers, as well as to the use of your information for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by you. You may contact us as specified below. We will take reasonable steps to answer to your requests.

Please also feel free to contact us if you have any questions about this Privacy Policy or the information practices of the MAVRCK Services.

You may contact us at privacy@mavrck.co or by regular mail addressed to:

Apifia, Inc. dba Mavrck

100 N. Washington St. First Floor

Boston, MA 02114

Your California Privacy Rights:

Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us as follows: email your name, social media URL’s, and information request to privacy@mavrck.co. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

Complaints:

In compliance with the EU-US Privacy Shield Principles, MAVRCK commits to resolve complaints about your privacy and our collection or use of your Personal Data.  EU individuals with inquiries or complaints regarding this Privacy Policy should first contact MAVRCK at:

ChiefPrivacyOfficer@Mavrck.co

MAVRCK has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

If a complaint cannot be resolved by any of the mechanisms described above, you also have a right, under certain conditions, to invoke binding arbitration under the Privacy Shield Panel as further explained in the Privacy Shield Principles. If you want to initiate this arbitration procedure, you are required to first formally notify us of your intention to do so by writing at privacy@mavrck.co. Please remember to include in your notice a summary of the steps you have already taken to resolve your complaint and a description of the alleged violation. For additional information about the arbitration process please visit the Privacy Shield website: www.privacyshield.gov.