mParticle Privacy Policy

This Privacy Policy is effective June 6, 2017

About this Policy

This Policy explains how information collected on www.mparticle.com (our “Site”) is used and disclosed by mParticle and its subsidiaries and affiliated companies (“mParticle or “We”). This Policy also explains how information is collected, used and disclosed via our technology platform (the mParticle “Platform”) and how we collect information from our clients and prospective clients.

mParticle complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union and Switzerland. mParticle has certified that it adheres to the Privacy Shield Privacy Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies of 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/

Data Collection and Use for our Site, from Clients and Employees.

Data Collection via the Site, from Clients and from Employees

Our Site is primarily directed to our clients and prospective clients (our “Clients”) which are generally businesses. We collect personally identifiable information (“PII”) via the Site. PII is information that can be used to identify or contact a unique person. We generally will only collect PII via the Site when you provide it directly to us. For example, you may provide PII such as an email address or a telephone number by sending us an email or filling out a form on the Site. Prospective employees may also send their resume or other employment details. And our Clients may register via the Site with their email address and other contact details. Clients, Site visitors and employees will sometimes provide additional PII to bolster what was provided via the Site.

When you visit our Site, some information is automatically collected. This may include information such as the Operating System running on your device, Internet Protocol address, access times, browser type and language, and the website you visited before visiting our Site. We automatically collect information using “cookies” and Web beacons. Cookies are small data files stored on your hard drive by a website and web beacons are electronic images that may be used on our Site or in our emails. Among other things, cookies help us improve our Site, our marketing activities, and your experience. We use cookies to see which areas and features are popular and to count visits to our Site. Most Web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies and / or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/. mParticle does not respond to “Do Not Track” browser signals or other mechanisms.

How We Use Information We Collect via the Site, from Clients and from Employees

We use the information we collect primarily to provide, maintain, protect and improve our current products, to develop new ones and to manage Client accounts and human resources functions. We use PII for the general purpose it was provided. For example, if you ask a question about our products and services, we may send you an email in response, and might even have a salesperson contact you to gauge your interest in learning more about our services. In general, we may use your information to:

  • Improve our services, Site and how we operate our business;
  • Understand and enhance your experience using our Site, products and services;
  • Provide and deliver products and services you request;
  • Respond to your comments or questions and allow our Services team to provide service;
  • Send you related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
  • Communicate with you about promotions, upcoming events and news about products and services offered by mParticle and our selected partners;
  • Link or combine it with other information we get from third parties, to help understand your needs and provide you with better service; and
  • Protect, investigate and deter against fraudulent, unauthorized or illegal activity.

mParticle may store and process PII in the United States and other countries. By using our Platform as a Client, you consent to this transfer of your information into the U.S.

Data Collection and Use for the mParticle Platform

Platform Data Collection and how mParticle Processes that Information

Our Platform is designed to allow our Clients to better understand how their customers, prospective customer and other individuals (their “Users”) utilize the products and services offered by our Clients. The platform provides our Clients with the ability to collect information based on User interaction with their mobile application(s), mobile website(s) or other digital properties where Clients have integrated with the Platform (collectively, “Client Digital Properties”) and send communications to such Users. Some information is automatically collected from or about Users when they use Client Digital Properties. The types of information collected via Client Digital Properties for the Platform includes: the date/time for a visit to a Client Digital Property, referrer information such as what search engine and search keywords Users may have used to get to a Client Digital Property, information about the browser or device your User is on such as their Operating System, as well as the city/country location of Users, and any pseudonymous tokens and mobile advertising IDs (e.g., IDFA in iOS). In addition, our Clients can choose what other User data they want to collect and store on the platform such as an IP address, location information, a User’s age, user names, real names, email addresses and other custom data points as determined by each Client.

We contractually prohibit Clients from placing sensitive information (e.g., passwords, authentication credentials, credit cards, social security or driver’s license numbers) or information that is deemed sensitive by applicable law or self-regulatory codes such as the Digital Advertising Alliance. mParticle functions strictly as the data processing agent of our Clients. Accordingly, other than those aforementioned restrictions, the data stored on the Platform is subject to the privacy policies of each Client.

Other Relevant Privacy Information

Sharing of Information, Onward Transfer

We may share your information with certain third-parties as specified below:

  • With third-party agents who work on our behalf as sub-processors, provided such third parties agree to adhere to the same privacy principles as mParticle;
  • To protect the rights and property of mParticle, our agents, Clients and others including enforcement of our agreements, policies and terms of use;
  • In an emergency, including protection of the personal safety of any person;
  • For the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture or bankruptcy transaction or proceeding);
  • As required in response to a lawful request by public authorities, including meeting of national security or law enforcement requirements;
  • We may also share aggregate or anonymous information without restriction.

In cases of onward transfer to third parties of data of EU or Swiss individual received pursuant to the EU-US and Swiss-US Privacy Shield, mParticle is potentially liable. Our privacy policy does not cover any third-party websites services. To learn about those third parties’ privacy practices, please visit their privacy policies.

Information Security

We take reasonable steps to help protect your information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. It is your responsibility to protect your usernames and passwords to help prevent anyone from accessing or abusing your accounts and services. You should not use or reuse the same passwords you use with other accounts as your password for our services. We encrypt transmission of data on pages where you provide payment information or otherwise provide sensitive information. However, no security or encryption method can be guaranteed to protect information from hackers or human error. Information we collect may be stored or processed on computers located in any country where we do business.

Children

We do not knowingly contact or collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us so we can promptly obtain parental consent or remove the information. If you are under 18, or the age of majority in the jurisdiction in which you reside, you may only use the mParticle Site and mParticle Services with the consent of your parent or legal guardian.

Data Retention

mParticle retains Client data for so long as you remain are a Client and will delete Client’s information within 12 months of either party’s termination of applicable Client agreement upon written request. We retain User level data on the Platform as directed by our Clients and for a reasonable time thereafter for audit purposes and as otherwise required by law.

Access to your Personal Data

If you are a mParticle Client, you can sign into your account to see any PII we have stored, such as your name, email, address or phone number. You can also contact us by email to request to see this information. If you are a job applicant and have provided this kind of information, you can also contact us via e-mail to request to see the information we have in our systems.

mParticle acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to privacy@mparticle.com. If requested to remove data, we will respond within a reasonable timeframe.

Your Information Choices and Changes

You may opt out of receiving promotional emails from mParticle by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your mParticle projects or our ongoing business relationship. An individual wishing to limit the use or sharing of their data should contact email privacy@mparticle.com. mParticle will respond within ninety (90) days to any request to delete your information. Individuals who have provided information directly to one of mParticle’s Clients must send follow-up requests to change or delete such information to that particular mParticle Client.

Changes To This Policy

mParticle may change this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. You agree that your continued use of our Site Services after such changes to our privacy practice have been published will constitute your acceptance of such revised Policy.

Contacting mParticle and Dispute Resolution

mParticle provides periodic training for its employees involved in the collection and dissemination of data. In addition, mParticle’s internal policies and procedures provide for disciplinary action if our employees fail to follow this Privacy Policy. We periodically self-assess and review these internal policies and procedures to review compliance.

In compliance with the US-EU and Swiss-US Privacy Shield Principles, mParticle commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact mParticle at:

  1. Email: privacy@mparticle.com
  2. Postal mail: mParticle Inc., 257 Park Avenue South, Floor 9, New York, NY 10010

For complaints that cannot be resolved between mParticle and the individual concerned, mParticle has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to 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 are an EU or Swiss individual and 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 your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. mParticle agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC.

Should your complaint remain fully or partially unresolved after a review by mParticle, BBB EU Privacy Shield and the relevant DPA, you may be able to, under certain conditions, seek arbitration before the Privacy Shield Panel. For more information, please visit www.privacyshield.gov. mParticle is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Privacy Inquiries

If you have any questions or concerns about this policy, please contact us:

privacy@mparticle.com
mParticle, Inc
257 Park Avenue South
Floor 9
New York, NY 10010

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