MVPindex PRIVACY POLICY AND YOUR PRIVACY RIGHTS

Effective Date: 2018-01-09

This Privacy Policy applies to the information U-MVPindex, LLC. (“MVPindex,” “we,” or “us,” or “our”) collects through websites, applications, software, processes, and all other interactive services we provide, and all of the associated content, functionalities and advertising contained therein (collectively, “Platform”). By using the Platform or otherwise agreeing to this Privacy Policy, you are consenting to the collection, use, disclosure and other handling of your information as described below. The Privacy Policy describes:

1. The information we collect and how we collect it;
2. What we do with the information we collect;
3. How we share and disclose information with third parties;
4. Our use of online analytics and tailored advertising;
5. California Do-Not-Track disclosure requirements;
6. Your rights;
7. How we protect information;
8. How long we store your information;
9. Linked sites and advertisements;
10. Use of the Platform by users from outside the United States;
11. Your California privacy rights;
12. Children’s privacy;
13. No rights of third parties;
14. Changes to this Privacy Policy; and
15. How to contact us.

Please note that this privacy policy only covers MVPindex’s use of the data that you provide.  If you are accessing the Platform through the account of a brand, that brand has rights to collect and access certain data as well.  Those rights are governed by the MVPindex subscription agreement.  Please check with the brand whose account you are using about their data policies.

1. The information we collect and how we collect it.
How we collect and store information depends on the features of the Platform that you use. You can use some of the Platform without providing any information other than that automatically collected as described below.

In general, we process your information when necessary to provide you with the services that you have requested when accepting our Terms of Use, or where we have obtained your prior consent, or where we have a legitimate interest to do so.  For example, we may have a legitimate interest to process your information for security, testing, maintenance, and enhancement purposes, or for analytics, research and reporting purposes.

Without your information, we cannot provide you with the Platform or the services you have requested, or you may be limited in your use of both.

1.1 Information you provide

We collect information about you during your use of the Platform, including your name, username, password, email address, postal address, phone number, payment information, gender, your selected influence categories, your self-created biography, general location information such as your city, state, or country, and information you provide to the Platform or allow us to access when you do certain things, such as:

• Request a demo;
• Enter registration information to create an account;
• Subscribe to the Platform;
• Fill out and submit an information request form;
• Request certain features (e.g., newsletters, updates, and other products);
• Enter a sweepstakes or contest or register for a promotion;
• Complete a survey;
• Sign up to receive SMS (text message) notifications; or
• Connect with the Platform or otherwise allow us to access certain information about you via a social media service.

You may also choose to provide us with optional demographic information, solely in your discretion, such as your income range, education level, asking price, religious affiliation, political affiliation, and ethnicity.

If you choose to link or connect a social media account to your MVPindex account (e.g., Facebook, Twitter, Instagram, Google+, YouTube, Twitch), we will collect and store your user ID associated with your social media account. If you choose to link your accounts or otherwise connect to your social media account with the Platform, you authorize MVPindex to collect, store, and use in accordance with this Privacy Policy any and all information available to MVPindex through the social media interface, including without limitation any information that you have made public in connection with your social media account, information that the social media service  shares with us, information that you have authorized the social media service to share with us (e.g., social post metadata and post content), or information that is disclosed as being shared during the sign-in process.  Please see your social media service provider’s privacy policy for more information about the data it shares when you initiate these connections.

1.2 Automatically-collected information

1.2.1 Device/usage information

We automatically collect certain information about the computer or devices (including mobile devices) you use to access the Platform. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Platform; and (b) information related to the ways in which you interact with the Platform, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those page (including search criteria and results), the amount of time spent on particular pages, the date and time you used the Platform, the frequency of your use of the Platform, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.

1.2.2 Location information

We collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform), and use that information to customize the Platform with location-based information and features. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

1.2.3 Cookies and other electronic technologies

When you use the Platform, we use persistent and session cookies and other similar tracking technologies to: (a) store your username and session token; (b) analyze the usage of our Platform by collecting the information discussed in section 1.2.1 above; (c) customize the Platform to your preferences; and (d) control the advertising displayed by the Platform, as well as advertisements that may be displayed on other websites or mobile applications. We and our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Platform, as well as serve you ads when you are using our Platform and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. As we adopt additional technologies, we may also gather additional information through other methods.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browsers toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform.

1.3 Information from third parties

We obtain additional information about you from third parties such as marketers, partners, data enrichment providers, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, demo, or service we provide.

1.4 Aggregate or de-identified data

We may aggregate and/or de-identify information collected by the Platform or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

2. What we do with the information we collect.
We use the information that we collect for the following purposes:

• To develop and improve our ranking and scoring processes;
• To personalize your experience;
• To improve the content and features of the Platform or develop new services;
• To process and respond to your inquiries;
• To improve customer service;
• For the purposes for which you provided it;
• To process transactions;
• To send you information about your account or transactions with us;
• To notify you about new features of the Platform, special events, or products, services, and special offers;
• To administer sweepstakes, promotions, surveys, and contests;
• To contact you with information and advertising that we believe will be of interest to you;
• To generate and review reports and data about our user base and Platform usage patterns;
• To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Platform;
• To enforce the legal terms that govern your use of the Platform; and
• To administer and troubleshoot the Platform.

3. How we share and disclose information with third parties.
We will share your information in the following ways:

• MVPindex Customers. We share your information with brands/companies that are MVPindex customers when you use the Platform through the customer’s account or when you have provided us with your consent to share with a particular customer.  Such sharing is governed by the Subscription Agreement between MVPindex and the customer.  Please check with the customer regarding how it uses such information.

• Affiliates and Subsidiaries.  We may share all information we collect within the MVPindex family of companies.

• Service Providers.  We may provide access to or share your information with select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, provision of content and features, advertising, analytics, research, customer service, shipping and fulfillment, data storage, security, fraud prevention, payment processing, and legal services.

• Legal Process and Protection of MVPindex and Others. By using the Platform, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process (e.g., a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of MVPindex, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

• Business Transfers. As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., during due diligence) user information may be among the transferred assets. If a portion or all of MVP’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, MVP will comply with such restrictions.

• Contests and Sweepstakes. When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers, operators, or sponsors privacy policies or practices.

• Aggregate/De-Identified Information. From time to time, we may share aggregate/de-identified information about use of the Platform, such as by publishing a report on usage trends.  This Privacy Policy places no limitations on our use or sharing of aggregate/de-identified information.

• Consent. We may also disclose your information to third parties with your consent to do so. Please note that once your information has been shared with third parties pursuant to your authorization, the third party’s privacy policy, and not this privacy policy, will govern its use of your information.

4. Our use of online analytics and tailored advertising.

4.1 Online analytics

We may use third-party web analytics services on the Platform, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.2 to help us analyze how users use the Platform, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Platform. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

4.2 Tailored advertising

‍When you use the Platform, MVPindex may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

Also, third parties, including without limitation those whose products or services are accessible or advertised via the Platform, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Platform in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of the Platform. We also allow other third parties (e.g., ad networks and ad servers) to serve tailored ads to you on the Platform, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Platform, so that tailored ads may be delivered to you when you are using other websites.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Platform by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiatives Consumer Opt-Out link and the Digital Advertising Alliances Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Platform and learn more about our advertising practices through the About Our Ads link available through the Platform.

To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Platform, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

5. California Do-Not-Track disclosure requirements.
We are committed to providing you with meaningful choices about the information collected on the Platform for third-party purposes, and that is why we provide above the Network Advertising Initiatives Consumer Opt-out link and the Digital Advertising Alliances Consumer Opt-Out Link. However, we do not recognize or respond to browser-initiated Do Not Track signals.

6. Your rights.
To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Platform where such information may be updated, or by contacting us at support@MVPindex.com.

7. How we protect information.
We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

8. How long we store your information.
We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

9. Linked sites and advertisements.
The Platform may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.

We have relationships with third-party providers, including social media services, to provide content, products, services, and functionality through the Platform. When you visit sites or use any services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the Platform in connection with such content, products, services, or functionalities, we may share any information you provide or that is collected during your use of those services with those providers. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.

10. Use of the Platform by users from outside the United States.
MVPindex complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union and Switzerland to the United States, respectively. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles of Notice, Choice, and Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the policies 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/.

In compliance with the EU-US Privacy Shield and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact us at: support@mvpindex.com.

We have further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the JAMS EU Privacy Shield web site, located at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim, for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

MVPindex is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-US and Swiss-US Privacy Shield.

We may transfer information that we collect about you to third party processors across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.  We are potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, respectively.

In addition to the rights granted under the section above entitled, “Your Rights,” some international users (including those whose information we collect under the Privacy Shield) have certain legal rights to access certain information we hold about them and to amend such information or obtain its deletion. To exercise those rights, these users may contact us at support@mvpindex.com with their request.

11. Your California privacy rights.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any, and as defined by California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.  We do not currently share your personal information with third parties for their direct marketing purposes.

12. Children’s privacy.
The Platform is intended for a general audience and not for children under the age of 13.  If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13 without parental consent, we will take reasonable steps to delete it as soon as practicable.

13. No rights of third parties.
This Privacy Policy does not create rights enforceable by third parties.

14. Changes to this Privacy Policy.
MVPindex reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Platform, or advances in technology.  Continued use of the Platform following the posting of changes to this Privacy Policy will mean you accept those changes.  If we make a material change to this Privacy Policy, you will be provided with appropriate notice and we will seek your consent to the updated Privacy Policy in accordance with legal requirements.

15. How to contact us.
If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to support@MVPindex.com.

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