MPLACE, INC. PRIVACY POLICY FOR WEBSITE AND MOBILE APPLICATION
Last modified: April 9, 2021
Introduction
Mplace, Inc. (“Company,” “Mplace, ” “Our,” “We” or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit our website https://mplace.io/ (our “Website”) or through our mobile application (our “Application”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On our Website
- On our Application
- In email, text, SMS messaging, push notifications, and other electronic messages between you and Mplace.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
- Any other website operated by Mplace or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application. These other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or Application. By accessing or using our Website or Application, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website or Application after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 18
Our Website and Application are not intended for children under 18 years of age. No one under age 18 may provide any information to the Website or Application. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website, Application, or through any of their features, register on the Website or Application, use any of the interactive or public comment features of the Website or Application, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@mplace.io
Information We Collect About You and How We Collect It
Mplace collects several types of information from current and former users and about users of our Website and Application, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, device information, social security number, citizenship status, marital status, subscription information or any other identifier by which you may be contacted online or offline (“personal information”);
- That is related to professional history or status, including work experience, education information, and bar membership;
- That we collected as part of a background check or other verification process;
- That is about you but individually does not identify you, such as statistical information and analytic data relating to Website and Application usage; and/or
- About your internet connection, the equipment you use to access our Website, device you use to access our Application, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Through a background check or other verification process.
- Automatically as you navigate through the Website or Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website or Application may include:
- Information that you provide by filling in forms on our Website or Application. This includes information provided at the time of registering to use our Website or Application, or requesting further services. We may also ask you for information when you report a problem with our Website or Application.
- That is related to professional history or status, including work experience, education information, and bar membership;
- Records and copies of your correspondence including email addresses or SMS messaging, if you contact us.
We may allow you to provide information on public areas of the Website or Application through our interactive features or for transfer to other users of the Website, Application, or third parties (collectively, “User Contributions”). If applicable, your User Contributions are submitted and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website or Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Any information you submit to us via our online forms, email, or SMS messaging, through the Website or Application is done so on a voluntary basis. The collection, use, and distribution of your information will be handled according to the terms and policies outlined in this Privacy Policy. If you object to the collection, use, and distribution policies outlined in this Privacy Policy, we ask that you do not submit information or access our Website or Application. We encourage you to send confidential information via the postal service to the address at the bottom of this document.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website or Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website or Application, including traffic data, location data, and other communication data and the resources that you access and use on the Website or Application.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- When you download, access, and use the Application, it may use technology to automatically collect:
- Usage Details. When you access and use the Application, we may automatically collect certain details of your access to and use of the Application, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Application.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Stored Information and Files. The Application also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
- Location Information. This Application may collect real-time information about the location of your device. If you do not want us to collect this information from your Application do not download the Application or delete it from your device
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website or Application according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website or Application.
The technologies we use for this automatic data collection may include:
- Cookies (or browser/mobile cookies). A cookie is a small file placed on the hard drive of your computer or device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website or Application. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or Application.
- Web Beacons. Pages of our Website, our Application, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Mplace, for example, to count users who have visited those pages or opened an email and for other related website or application statistics (for example, recording the popularity of certain application content and verifying system and server integrity).
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Website or Application are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or Application. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
The Website or Application may contain links to other sites or applications. Please be aware that Mplace is not responsible for the privacy practices of those other sites or applications. We encourage you to be aware when you leave our Website or Application and to review the privacy statements of each website or application that collects personal information. This privacy policy applies solely to information collected on our Website or Application. Information collected on other sites or applications is not covered by this privacy policy.
Social Media, Widgets and Open Forums
Our Website and Application may allow you to engage with social media services, such as Facebook, Twitter, Instagram, and LinkedIn (“Social Networks”), and widgets such as the “Share this” button, connection to your profile or interactive features that run on our Website or Application or which link from Social Networks to our Website (“Social Functions”). These Social Functions may access, collect and integrate with your Social Network accounts and information. For example, these Social Functions may collect your IP address, identify which page you are visiting on our Website, or set a cookie. We do not control those Social Networks or your profiles on those services. We do not modify your privacy settings on those services or establish rules about how your personal information on those services will be used. Social Functions are either hosted by a third party or hosted directly on our Website or Application. Your interactions with them are governed by the privacy policy of the company providing them. Please refer to the privacy settings in your Social Network account to manage the data that is shared with us through your account.
Further, information you include and transmit online in a publicly accessible blog, chat room or Social Network, may be viewed and used by others without any restrictions. As noted above, we do not control such uses of your personal information. By using such services, you assume the risk and acknowledge that the personal information provided by you may be viewed and used by us and/or third parties for any number of purposes, and that the usage restrictions set forth in this Privacy Policy do not apply to such services.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To conduct background checks or other verification processes.
- To help find you employment opportunities with our staffing partners or other businesses and companies.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website, Application, or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website or Application.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Disclosure of Your Information
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates.
- Business partners, subscribers, employers, staffing for the purpose of employment
- Business partners that assist us with tracking how visitors use our Website or Application.
- Those who request information pursuant to a subpoena or court order.
- To other contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Mplace’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Mplace about our Website or Application users is among the assets transferred.
- To external certified verification providers to conduct background checks or other verification processes.
- To staffing partners and other companies and organizations that use Mplace services for verification and/or staffing purposes.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Mplace, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- We will not sell, give, or disclose any information about you to others unless the disclosure is necessary to conduct our business and as allowed by law.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
We do not control third parties’ collection or use of your information to serve interest-based advertising.
Google Analytics
Google Analytics is a web analytics website offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google Websites. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.
Data Security
We have implemented appropriate administrative, physical, and technical security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We endeavor to encrypt the personal information your provide to us. We use the secure socket layer (SSL) protocol and a secure server to safeguard the information you submit. All payment transactions are processed through third parties and are subject to the security, terms and conditions, and policies of that third party provider. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information off-line. All of our users’ information, not just sensitive information, is restricted in our offices. We limit employee access of personally identifiable information to those with a business reason for accessing such information. Mplace also believes in educating our employees so that they will understand the importance of confidentiality of personal information, and in taking appropriate measures to enforce employee privacy responsibilities. Finally, the servers on which we store personal information are kept in a secure environment.
The safety and security of your information also depends on you. Where we have given you or where you have chosen a password for access to certain parts of our Website or Application you are responsible for keeping this password confidential. Protecting your account login credentials (i.e. your username and password) from unauthorized access is your responsibility. You may not share your login credentials with any third party. We recommend you log out after accessing your account, change your password on a periodic basis, and limit access to your computer or device and its browser. While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Website or Application, we cannot guarantee that these efforts will always be successful. We do not represent, warrant, or guarantee that our safeguards will protect the total privacy of your personal information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or the Application. You are responsible for ensuring the security and safety of your internet connection. You should not transfer any data to our Websites or Applications via an unsecured internet connection. Any transmission of personal information is at your own risk. We cannot and do not ensure, represent, warrant, or guarantee the security of any information you transmit through the Website or Application. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or the Application.
Retention of Your Personal Information
We retain your information for as long as required, allowed or as long as we believe it is useful, but do not undertake retention obligations. We may dispose of your information in our sole discretion without notice, subject to applicable law that specifically requires the handling or retention of your information. You must keep your own, separate back-up records of your data.
You can correct, update, and remove your information if it changes or if you no longer want to receive information except that which is related to our services. This can be done by e-mailing a request to us at privacy@mplace.io. We may not be able to completely remove your information from our systems in certain circumstances.
Third Party Links
The Website or Application may contain links to other sites or applications. Please be aware that Mplace is not responsible for the privacy practices of those other sites or applications. We encourage you to be aware when you leave our Website or Application and to review the privacy statements of each website or application that collects personal information. This privacy policy applies solely to information collected on our Website or Application. Information collected on other sites or applications is not covered by this privacy policy.
California Privacy Rights
If you are a California resident, you have certain data protection rights. Under the California Consumer Privacy Act of 2018 (CCPA) and California Civil Code § 1798.83, you have the right to exercise the following rights:
- Disclosures of Personal Information We Collect
You have the right to know:
- The categories of Personal Data we have collected about you
- The categories of sources from which we have collected Personal Data
- Our business or commercial purpose for collecting or selling Personal Data
- The categories of third parties with whom we share Personal Data
- The specific pieces of Personal Data we have collected about you
Personal Data We Sell or Use for a Business Purpose
In connection with any Personal Data we may sell or disclose to a third party for business purposes, you have the right to know:
- The categories of Personal Data that we sold
- The categories of third parties to whom Personal Data was sold
- The categories of Personal Data that we disclosed for a business purpose
Mplace does not sell (as is defined in the CCPA) the Personal Data we collect, and will not sell it without providing a right to opt out.
Right to Deletion
Subject to certain exceptions set out below, upon receipt of a verifiable request from you, we will:
- Delete your Personal Data from our records; and
- Direct any service providers to delete your Personal Data from their records.
Please note that we may not delete your Personal Data if it is necessary to:
- Complete the transaction for which your Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you
- Detect and protect against security incidents, fraudulent or illegal activity, or for prosecuting those responsible for such activity
- Debug, identify, or repair errors that impair existing functionality
- Exercise free speech
- Comply with the California Electronic Communications Privacy Act
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all applicable ethics and privacy laws
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
- Comply with an existing legal obligation
- Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information
Protection Against Discrimination
You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot:
- Deny goods or services to you
- Provide a different level or quality of goods or services to you
Please note that we may charge a different price or rate to you if that difference is reasonably related to the value provided to us by your Personal Data.
California’s Shine the Light Law
In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Data to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information) . If you are a California resident and would like to make such a request, please email us at privacy@mplace.io.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
The Website does not respond to or support Do Not Track (“DNT”) signals.
Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
European General Data Privacy Regulation (GDPR)
If you are a resident of the European Union (EU), you have certain data protection rights under the European General Data Protection Regulation (GDPR).
Legal Basis for Processing Your Personal Data Under GDPR
To process your Personal Data, we must have a legal basis for doing so. We may process your Personal Data under the following conditions:
- Performance of a Contract: when your Personal Data is necessary for the performance of an agreement that we make with you and/or for any contractual obligations thereof
- Legal Obligation: when your Personal Data is necessary for compliance with a legal obligation to which Mplace is subject
- Legitimate Interests: when processing your Personal Data is necessary for the purpose of the legitimate interests pursued by Mplace
Special Category Data
In limited circumstances, we do collect Personal Data that is identified under the GDPR as special category data. Special category data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, personal or political opinions, trade union membership, information about your health, and genetic and biometric data. We will only process special category data where we have a lawful basis for doing so.
Your Data Protection Rights Under GDPR
In certain circumstances, you have the following data protection rights with respect to your Personal Data that we collect and process:
- The Right to Request Access. You have the right to access, update, or delete the information we have about you.
- The Right of Rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- The Right to Object. You have the right to object to our processing of your Personal Data.
- The Right to Restrict Processing. You have the right to request that we restrict the processing of your Personal Data.
- The Right of Erasure. In certain circumstances, you have the right to ask us to remove or delete your Personal Data.
- The Right to be Forgotten. You have the right to request that we delete your personal information, in certain situations.
- The Right to Transfer. Upon request we will provide you (or a third-party you have chosen) the Personal Data we have collected about you. Your Personal Data will be provided in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.
- Withdraw Your Consent. You have the right to withdraw your consent at any time where Mplace relied on your consent to process your Personal Data.
Data Transfers outside of the European Economic Area (“EEA”)
If you are located in the EEA, we may need to collect, use, process, disclose, and transfer your Personal Data outside of the EEA. You hereby consent to such collection, use, processing, disclosure, and transfer. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable information to a jurisdiction which may provide a different level of privacy protection than that available in your own country.
Exercising Your Rights Under GDPR
You may exercise any of the rights enumerated above by contacting us at privacy@mplace.io. Please note that we may ask you to verify your identity before responding to such requests.
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area.
Changes to Our Privacy Policy
Mplace reserves the right to introduce new services or practices that may require a change in this policy. We are committed to make the necessary changes promptly to keep you informed on how we use the information you provide us. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will post an update privacy policy to both Website and Application. The date the privacy policy was last revised is identified at the top of the page. You are responsible for keeping up to date on the terms of this Privacy Policy and to review this policy frequently for any changes. Your continued use of the Website or Application constitutes your acceptance of any updated Privacy Policy.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@mplace.io or at (877) 931-4566.