Terms of Service and Privacy policy

Version 1.0.3
Last Modified: September 26, 2023

This Privacy Policy and Terms of Service applies to your use of www.mavinindustrial.com (the “Services”). This Policy is effective as of the Last Modified date above. Our Privacy Policy was last reviewed on August 16, 2023

All references to “us” and similar words such as “we” and “our” (even if not capitalized) mean Mavin Industrial Limited. All references to “you” and similar words such as “your” (even if not capitalized) mean the individual using the Services, and if you are using the Services on behalf of a business entity, it means both you and that business.

By using the Services, you are agreeing to this Privacy Policy. If you are using the Services on behalf of a business entity, then you represent that you are authorized to use the Services on behalf of that business and you are agreeing to this Privacy Policy on behalf of both you and that business.

If you do not agree to this Privacy Policy, then you may not use the Services.

Changes made from the previous revision dated July 29, 2022 and August 16, 2022 are denoted by ** within the 'Information We Collect Table', of which both respective responses were previously 'No'.

Terms of Service

Our Terms of Service are available at www.mavinindustrial.com/terms_privacy (the “Terms of Service”). The Terms of Service applies to your use of the Services.

Limitations

We will not collect additional categories of Personal Data, or use the Personal Data we do collect, for materially different, unrelated, or incompatible, purposes without providing notice to you.

Information We collect

Anonymous Data

If you use the Services, then we may collect Anonymous Data from you. “Anonymous Data” means information which is not personal in nature, and which does not identify you as a specific individual or business.

Personal Data

If you use the Services, then we may collect personal data from you (“Personal Data”) as described in this section of this Privacy Policy. In the last 12 months, we have collected the following types of Personal Data (where indicated on the following matrix):

Categories
Examples
Collected in Last 12 Months

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Yes

Personal information described in the California Customer Records Statute

A signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

No (telephone numbers are collected from users during registration but are not required and not collected prior to registration)**

Characteristics of protected classifications under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

Biometric information

Physiological, biological, or behavioral characteristics, DNA information. Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, or voice recordings. Keystroke patterns or rhythms, gait patterns or rhythms, or sleep, health, or exercise data.

No

Internet and network activity

Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.

Yes

Geolocation data

Information about physical locations or movements.

No

Sensory information

Audio, electronic, visual, thermal, olfactory, or similar information.

No

Professional or employment-related information

Current or past job history or performance evaluations.

Yes (current role only for users, general employment and employability data for job applicants)**

Non-public education information (per the Family Educational Rights and Privacy Act)

Non-public education records that are directly related to a student which are maintained by an educational agency or institution or by a party acting on its behalf (for example, grades, transcripts, class lists, student schedules, identification codes, financial information, and disciplinary records).

No

Inferences drawn from other Personal Data

Information used to create a user profile which reflects the users’ preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

No


“Personal Data” does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this paragraph, “publicly available” means: information that is lawfully made available from federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public by you or from widely distributed media; or information made available by a person to whom you have disclosed the information if you have not restricted the information to a specific audience. “Publicly available” does not mean biometric information collected by us about you without your knowledge.

“Personal Data” also does not include your information that is considered Anonymous Data under this Privacy Policy.

Information We Collect Automatically (including cookies)
We may also collect information about you automatically, including your IP address, operating system, browser ID, browsing activity, time stamps, site navigation, button clicks, and similar types of information. We may also use and/or collect cookies and other types of data files (such as web beacons and cookie-equivalent technology), some of which may be stored on your computer or electronic device for use when you use the Services.

Sources of Information We collect

We collect the categories of Personal Data listed above from the following categories of sources:

  • Directly from you or your agent.

Business Purposes for Collecting Information

We collect the categories of Personal Data listed above for the following business purposes:

  • To provide the Services to you for their intended purposes, as well as to customize and/or enhance your use of the Services.
  • To send communications to you, including marketing communications (unless you opt-out).
  • To accomplish the purposes outlined in our Terms of Service.

How We Use Your Information

Aggregated Data

We may aggregate your Personal Data with information we have about other users, individuals, and business, for the purpose of converting it into Anonymous Data. Once converted into Anonymous Data, we may use that Anonymous Data as provided in this Privacy Policy. Notwithstanding, we retain ownership of this aggregated anonymous data at all times and as such this aggregated anonymous data is excluded from your deletion rights detailed below.

Anonymous Data

We may use Anonymous Data for any purpose not otherwise prohibited by applicable law, without your consent, without providing notice to you, and without providing compensation to you, including sharing and selling Anonymous Data to third parties.

Using Personal Data for Business Purposes

We may use your Personal Data for one or more of the business purposes described above.

Sharing Personal Data

We may share your Personal Data in connection to one or more of the business purposes described above to the following categories of recipients.

  • Our Service Providers (including internet service providers, analytics platforms, operating systems, payment processors, and professional service providers)


Within the last 12 months, we have shared the following categories of your Personal Data to the following categories of recipients:

Categories
Shared in the last 12 months?
Recipients

Identifiers

Yes

☒Affiliates
☒Service Providers
☐Other Recipients

Personal information described in the California Customer Records Statute

N/A

N/A

Characteristics of protected classifications under California or federal law

N/A

N/A

Commercial information

N/A

N/A

Biometric information

N/A

N/A

Internet and network activity

Yes

☒Affiliates
☒Service Providers
☐Other Recipients

Geolocation data

N/A

N/A

Sensory information

N/A

N/A

Professional or employment-related information

N/A

N/A

Non-public education information (per the Family Educational Rights and Privacy Act)

N/A

N/A

Inferences drawn from other Personal Data

N/A

N/A

Selling Personal Data

We will not sell your Personal Data to any third parties.

International Transfers

We may transfer your Personal Data across international borders, including but not limited to transfer to and from the following countries: Canada, USA.

Improvements on the Services

If you share ideas or suggestions with us regarding improving or modifying the Services, then we may use all the same without your consent, without providing notice to you, and without providing compensation to you.

Data Retention & Our Right to Delete

We may retain your Personal Data for as long as you maintain an open account in the Services and for as long as necessary to provide the Services to you. We may also retain your Personal Data after those periods, but only for purposes of complying with legal processes, to resolve disputes, or as otherwise allowed by applicable law. Please note that we do not have any obligation to store your Personal Data for your benefit of for the benefit of any third party. We may delete all or parts of your Personal Data any time, for any reason, without notice to you, unless otherwise prohibited by applicable law.

Compliance with Legal Process

We may use and share your Personal Data as follows: (a) to comply with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms, (b) to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements, (c) to prosecute and defend a court, arbitration, or similar legal proceeding, (d) with our representatives and advisors, including attorneys and accountants, and (e) if we have a good faith belief that disclosure is necessary to enforce our Terms of Service or any policies referenced in our Terms of Service or to investigate or prevent illegal or immoral actions.

Your Rights & Choices

Cookies & Tracking Data

You may restrict our ability to use cookies and certain other types of data files by adjusting the settings on your device or browser. However, please note that if you create such restrictions, all or parts of the Services may not operate as intended (or at all).

Access

You may request information about your Personal Data we collected and how we used that Personal Data in the last 12 months. If you make such a request, then we will provide you with the categories of your Personal Data we collected in the last 12 months, along with the categories of any third parties with which we shared or sold that data, and the specific pieces of that data, as well as any other information of which we are required to provide to you by applicable law.

Deletion

You may request that we delete your Personal Data from our systems. We will comply with that request within a reasonable period, unless we have a legal right to retain that data (for example, to continue providing the Services to you, or to complete a transaction which you initiated in our systems). Aggregated anonymous data derived from your data is exempt from deletion requirements unless expressly required by applicable laws.

Exercising Your Rights

To exercise your rights described in this Privacy Policy, please contact us using the contact information at the bottom of this Privacy Policy. You must include enough information about yourself to allow us to identify you and verify you are the person or business you claim to be and enough information about your request to allow us to understand and respond to your request. We will use reasonable efforts to reply to all such valid requests within 30 days of receipt of the request.

Non-Discrimination

We will not discriminate against you for exercising your rights under applicable laws, including the CCPA or the GDPR.

Rights Under the European Union's General Data Processing Regulation(GDPR)

If you are a “Data Subject” under the GDPR, then in addition to the rights outlined elsewhere in this Privacy Policy, you have the rights outlined in this section. If you have questions about any of these rights or if you would like to exercise any of these rights, please contact us using the contact information at the bottom of this Privacy Policy. Also, please note that certain portions of the Services will not work for you unless you provide us with your Personal Data.

  • You have the right to be informed about what data we collect and how we use it.
  • You have the right to request access to your Personal Data.
  • You have the right to have us rectify your Personal Data if it is inaccurate or incomplete.
  • You have the right to have us erase, remove, or delete, your Personal Data.
  • You have the right to restrict our processing of your Personal Data as provided in the GDPR.
  • You have the right to data portability with respect to your Personal Data.
  • You have the right to object to certain uses of your Personal Data as provided in the GDPR.
  • You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the GDPR.
  • To the extent you provided consent to our processing of your Personal Data, you have the right to withdraw that consent at any time. However, such withdrawal will not be effective with respect to lawful processing based upon consent that occurred prior to your withdrawal. (We require only the information that is reasonably required to enter a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering a contract with us.)
  • We will only retain your Personal Data for as long as necessary for the purposes outlined in this Privacy Policy and our Terms of Service.

Security

We use reasonable efforts to protect your information, especially your personally identifiable information and payment information. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to us. Further, it is your responsibility to protect the security of your account credentials.

Power to Amend This Privacy Policy

We may amend this Privacy Policy at any time, for any reason, with or without notice to you, and your continued use of the Services after the amended Privacy Policy is posted on the Services will constitute your acknowledgment and agreement to the amended Privacy Policy. However, to the extent the amended Privacy Policy materially alters your rights or obligations in this Privacy Policy, the amended Privacy Policy will become effective upon the earlier of (a) your continued use of the Services with actual knowledge of the amended Privacy Policy, or (b) 30 days after the amended Privacy Policy is posted on the Services.You can view prior versions (if any) of this Privacy Policy online at www.mavinindustrial.com/terms_privacy.

Contact

If you have any questions or comments about this Privacy Policy, how we collect and use your information, or your choices and rights regarding the same, then you may contact us at the contact information below. If you are contacting us as an authorized agent for another person or business, please also provide sufficient information in your request so that we can verify that you are authorized to communicate with us as that person’s or business’ authorized agent.

Phone: (709) 800-9336

Email: support@mavinindustrial.com

Address: 100 Signal Hill Rd Suite #0100 St. John's, Newfoundland and Labrador A1A 1B3 Canada

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