PRIVACY POLICY
Last updated May 01, 2023
This privacy notice for McPloy ("Company,"
"we," "us," or "our"),
describes how and why we might collect, store, use, and/or share ("process")
your information when you use our services ("Services"), such
as when you:
Questions or concerns? Reading
this privacy notice will help you understand your privacy rights and choices.
If you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns, please contact us at
contact@mcploy.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can
find out more details about any of these topics by clicking the link following
each key point or by using our table of contents below to find
the section you are looking for.
What personal information do we process? When you visit,
use, or navigate our Services, we may process personal information depending on
how you interact with McPloy and the Services, the choices you make, and the
products and features you use. Learn more about personal information you disclose to
us.
Do we process any sensitive personal information? We do not process
sensitive personal information.
Do we receive any information from third parties? We do not receive
any information from third parties.
How do we process your information? We process your information to
provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your
information for other purposes with your consent. We process your information
only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which types of parties do we share personal
information? We may share information in specific situations and with specific
categories of third parties. Learn more about when and with whom we share your
personal information.
How do we keep your information safe? We have organizational and technical
processes and procedures in place to protect your personal information.
However, no electronic transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security and improperly collect, access, steal,
or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the
applicable privacy law may mean you have certain rights regarding your personal
information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your
rights is by submitting a data subject access request, or by contacting us. We will
consider and act upon any request in accordance with applicable data protection
laws.
Want to learn more about what McPloy does with any information we
collect? Review the privacy
notice in full.
TABLE OF CONTENTS
1.
WHAT INFORMATION DO WE COLLECT?
2. HOW
DO WE PROCESS YOUR INFORMATION?
3.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR
STANCE ON THIRD-PARTY WEBSITES?
6. HOW
DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS
YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW
LONG DO WE KEEP YOUR INFORMATION?
9. HOW
DO WE KEEP YOUR INFORMATION SAFE?
10. DO
WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR
PRIVACY RIGHTS?
12.
CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO VIRGINIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO
WE MAKE UPDATES TO THIS NOTICE?
16.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal
information that you provide to us.
We collect personal information that you voluntarily
provide to us when you register on the Services, express an interest in
obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The
personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the products
and features you use. The personal information we collect may include the
following:
Sensitive Information. We do not process sensitive
information.
Payment Data. We may collect data
necessary to process your payment if you make purchases, such as your payment
instrument number, and the security code associated with your payment
instrument. All payment data is stored by Apple Inc. You may find their privacy
notice link(s) here: https://www.apple.com/legal/privacy/en-ww/.
Social Media Login Data. We may
provide you with the option to register with us using your existing social
media account details, like your Facebook, Twitter, or other social media
account. If you choose to register in this way, we will collect the information
described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?"
below.
Application Data. If you use our application(s), we also may collect the
following information if you choose to provide us with access or permission:
This information is primarily needed to maintain the security and
operation of our application(s), for troubleshooting, and for our internal
analytics and reporting purposes.
All personal information that you provide to us must be
true, complete, and accurate, and you must notify us of any changes to such
personal information.
Information automatically collected
In Short: Some information — such
as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you
visit, use, or navigate the Services. This information does not reveal your
specific identity (like your name or contact information) but may include
device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device
name, country, location, information about how and when you use our Services,
and other technical information. This information is primarily needed to maintain
the security and operation of our Services, and for our internal analytics and
reporting purposes.
The information we collect includes:
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your
information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services, including:
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal
information when we believe it is necessary and we have a valid legal reason
(i.e., legal basis) to do so under applicable law, like with your consent, to
comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our legitimate
business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process your
personal information:
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e., express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred (i.e., implied
consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable
law to process your information without your consent, including, for example:
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information
in specific situations described in this section and/or with the following
categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your
data with third-party vendors, service providers, contractors, or agents
("third parties") who perform services for us or on our behalf
and require access to such information to do that work. We have contracts in
place with our third parties, which are designed to help safeguard your
personal information. This means that they cannot do anything with your
personal information unless we have instructed them to do it. They will also
not share your personal information with any organization apart from us. They
also commit to protect the data they hold on our behalf and to retain it for
the period we instruct. The categories of third parties we may share personal
information with are as follows:
We also may need to share your personal information in the following
situations:
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any
information that you share with third parties that we may link to or who
advertise on our Services, but are not affiliated with, our Services.
The Services, including our offer wall, may link to third-party websites,
online services, or mobile applications and/or contain advertisements from
third parties that are not affiliated with us and which may link to other
websites, services, or applications. Accordingly, we do not make any guarantee
regarding any such third parties, and we will not be liable for any loss or
damage caused by the use of such third-party websites, services, or
applications. The inclusion of a link towards a third-party website, service,
or application does not imply an endorsement by us. We cannot guarantee the
safety and privacy of data you provide to any third parties. Any data collected
by third parties is not covered by this privacy notice. We are not responsible
for the content or privacy and security practices and policies of any third
parties, including other websites, services, or applications that may be linked
to or from the Services. You should review the policies of such third parties
and contact them directly to respond to your questions.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to
register or log in to our Services using a social media account, we may have
access to certain information about you.
Our Services offer you the ability to register and log in
using your third-party social media account details (like your Facebook or
Twitter logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile information
we receive may vary depending on the social media provider concerned, but will
often include your name, email address, friends list, and profile picture, as
well as other information you choose to make public on such a social media
platform.
We will use the information we receive only for the
purposes that are described in this privacy notice or that are otherwise made
clear to you on the relevant Services. Please note that we do not control, and
are not responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their privacy
notice to understand how they collect, use, and share your personal
information, and how you can set your privacy preferences on their sites and
apps.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store,
and process your information in countries other than your own.
Our servers are located in the United States. If you are
accessing our Services from outside the United States, please be aware that your
information may be transferred to, stored, and processed by us in our
facilities and by those third parties with whom we may share your personal
information (see "WHEN
AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
above), in the United States, United Arab Emirates, United
Kingdom, and other countries.
If you are a resident in the European Economic Area (EEA)
or United Kingdom (UK), then these countries may not necessarily have data
protection laws or other similar laws as comprehensive as those in your
country. However, we will take all necessary measures to protect your personal
information in accordance with this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal
information, including by using the European Commission's Standard Contractual
Clauses for transfers of personal information between our group companies and
between us and our third-party providers. These clauses require all recipients
to protect all personal information that they process originating from the EEA
or UK in accordance with European data protection laws and
regulations. Our Standard Contractual Clauses can be provided upon
request. We have implemented similar appropriate safeguards with our
third-party service providers and partners and further details can be provided
upon request.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information
for as long as necessary to fulfill the purposes outlined in this privacy
notice unless otherwise required by law.
We will only keep your personal information for as long as
it is necessary for the purposes set out in this privacy notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than three (3) months
past the termination of the user's account.
When we have no ongoing legitimate business need to process
your personal information, we will either delete or anonymize such information,
or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your
personal information through a system of organizational and technical security
measures.
We have implemented appropriate and reasonable technical
and organizational security measures designed to protect the security of any
personal information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to and
from our Services is at your own risk. You should only access the Services
within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not
knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children
under 18 years of age. By using the Services, you represent that you are at
least 18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to promptly delete such
data from our records. If you become aware of any data we may have collected
from children under age 18, please contact us at contact@mcploy.com.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions,
such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you
have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have
certain rights under applicable data protection laws. These may include the
right (i) to request access and obtain a copy of your personal information,
(ii) to request rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to the processing
of your personal information. You can make such a request by contacting us by
using the contact details provided in the section "HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance
with applicable data protection laws.
If you are located in the EEA or UK and you believe we are
unlawfully processing your personal information, you also have the right to
complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data
Protection and Information Commissioner.
Withdrawing your consent: If we
are relying on your consent to process your personal information, which may be
express and/or implied consent depending on the applicable law, you have the
right to withdraw your consent at any time. You can withdraw your consent at
any time by contacting us by using the contact details provided in the section
"HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating
your preferences.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable law allows, will it
affect the processing of your personal information conducted in reliance on
lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe
from our marketing and promotional communications at any time by clicking on
the unsubscribe link in the emails that we send, or by contacting us using the
details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?" below. You will then be removed from the marketing lists. However,
we may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may retain
some information in our files to prevent fraud, troubleshoot problems, assist
with any investigations, enforce our legal terms and/or comply with applicable
legal requirements.
If you have questions or comments about your privacy rights, you may
email us at contact@mcploy.com.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and
mobile applications include a Do-Not-Track ("DNT") feature or setting
you can activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage no uniform
technology standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any
other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future,
we will inform you about that practice in a revised version of this privacy
notice.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a
resident of California, you are granted specific rights regarding access to
your personal information.
California Civil Code Section 1798.83, also known as the
"Shine The Light" law, permits our users who are California residents
to request and obtain from us, once a year and free of charge, information
about categories of personal information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of all third parties
with which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a request,
please submit your request in writing to us using the contact information
provided below.
If you are under 18 years of age, reside in California, and
have a registered account with Services, you have the right to request removal
of unwanted data that you publicly post on the Services. To request removal of
such data, please contact us using the contact information provided below and
include the email address associated with your account and a statement that you
reside in California. We will make sure the data is not publicly displayed on
the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a
"resident" as:
(1) every individual who is in the State of California for
other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of
California who is outside the State of California for a temporary or transitory
purpose
All other individuals are defined as
"non-residents."
If this definition of "resident" applies to you,
we must adhere to certain rights and obligations regarding your personal
information.
What categories of personal information do we collect?
We have collected the following categories of personal
information in the past twelve (12) months:
Category |
Examples |
Collected |
A. Identifiers |
Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique personal identifier,
online identifier, Internet Protocol address, email address, and account name |
YES |
B. Personal information categories listed in the
California Customer Records statute |
Name, contact information, education, employment,
employment history, and financial information |
YES |
C. Protected classification characteristics under
California or federal law |
Gender and date of birth |
YES |
D. Commercial information |
Transaction information, purchase history, financial
details, and payment information |
NO |
E. Biometric information |
Fingerprints and voiceprints |
NO |
F. Internet or other similar network activity |
Browsing history, search history, online behavior,
interest data, and interactions with our and other websites, applications,
systems, and advertisements |
NO |
G. Geolocation data |
Device location |
YES |
H. Audio, electronic, visual, thermal, olfactory, or
similar information |
Images and audio, video or call recordings created in
connection with our business activities |
NO |
I. Professional or employment-related information |
Business contact details in order to provide you our
Services at a business level or job title, work history, and professional
qualifications if you apply for a job with us |
YES |
J. Education Information |
Student records and directory information |
YES |
K. Inferences drawn from other personal information |
Inferences drawn from any of the collected personal
information listed above to create a profile or summary about, for example,
an individual’s preferences and characteristics |
YES |
L. Sensitive Personal Information |
NO |
We will use and
retain the collected personal information as needed to provide the Services or
for:
We may also collect other personal information outside of
these categories through instances where you interact with us in person,
online, or by phone or mail in the context of:
How do we use and share your personal information?
More information about our data collection and sharing
practices can be found in this privacy notice.
You may contact us by email at contact@mcploy.com, or by referring to the contact details
at the bottom of this document.
If you are using an authorized agent to exercise your right
to opt out we may deny a request if the authorized agent does not submit proof
that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service
providers pursuant to a written contract between us and each service provider.
Each service provider is a for-profit entity that processes the information on
our behalf, following the same strict privacy protection obligations mandated
by the CCPA.
We may use your personal information for our own business
purposes, such as for undertaking internal research for technological
development and demonstration. This is not considered to be "selling"
of your personal information.
McPloy has not sold or shared any personal information to third parties
for a business or commercial purpose in the preceding twelve (12) months. McPloy has disclosed the following categories of
personal information to third parties for a business or commercial purpose in
the preceding twelve (12) months:
The categories of third parties to whom we disclosed
personal information for a business or commercial purpose can be found under
"WHEN AND WITH WHOM
DO WE SHARE YOUR PERSONAL INFORMATION?".
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information.
If you ask us to delete your personal information, we will respect your request
and delete your personal information, subject to certain exceptions provided by
law, such as (but not limited to) the exercise by another consumer of his or
her right to free speech, our compliance requirements resulting from a legal
obligation, or any processing that may be required to protect against illegal
activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to
provide or delete consumer information that is de-identified in response to a
consumer request or to re-identify individual data to verify a consumer
request.
Right to Non-Discrimination for the Exercise of a
Consumer’s Privacy Rights
We will not discriminate against you if you exercise your
privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process
consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we have the information
in our system. These verification efforts require us to ask you to provide
information so that we can match it with information you have previously
provided us. For instance, depending on the type of request you submit, we may
ask you to provide certain information so that we can match the information you
provide with the information we already have on file, or we may contact you
through a communication method (e.g., phone or email) that you have previously
provided to us. We may also use other verification methods as the circumstances
dictate.
We will only use personal information provided in your
request to verify your identity or authority to make the request. To the extent
possible, we will avoid requesting additional information from you for the
purposes of verification. However, if we cannot verify your identity from the
information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for
security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us by email
at contact@mcploy.com, or by referring to the contact details at the bottom of this document. If
you have a complaint about how we handle your data, we would like to hear from
you.
14. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may
be granted specific rights regarding access to and use of your personal
information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the
Commonwealth acting only in an individual or household context. It does not
include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or
reasonably linkable to an identified or identifiable natural person.
"Personal data" does not include de-identified data or publicly
available information.
"Sale of personal data" means the exchange of personal data for
monetary consideration.
If this definition "consumer" applies to you, we must adhere to
certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary
depending on how you interact with McPloy and our Services. To find out more,
please visit the following links:
Your rights with respect to your personal data
McPloy sells personal data to third parties or processes personal data
for targeted advertising. Please see the following section to find out how you
can opt out from further selling or sharing of your personal data for targeted
advertising or profiling purposes.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be
found in this privacy notice.
You can opt out from the selling of your personal data, targeted
advertising, or profiling by disabling cookies in Cookie Preference
Settings. You may contact us by email at contact@mcploy.com, by submitting
a data subject access request, or by referring to the contact
details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny
a request if the authorized agent does not submit proof that they have been
validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably
necessary to verify you and your consumer's request. If you submit the request
through an authorized agent, we may need to collect additional information to
verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in
all cases, within forty-five (45) days of receipt. The response period may be
extended once by forty-five (45) additional days when reasonably necessary. We
will inform you of any such extension within the initial 45-day response
period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you
of our decision and reasoning behind it. If you wish to appeal our
decision, please email us at contact@mcploy.com. Within sixty (60) days of
receipt of an appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this
notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The
updated version will be indicated by an updated "Revised" date and
the updated version will be effective as soon as it is accessible. If we make
material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you
may email us at contact@mcploy.com or by post to:
McPloy
__________
__________
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have
the right to request access to the personal information we collect from you,
change that information, or delete it. To request to review, update, or delete
your personal information, please fill out and submit a data subject access request.
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