We may collect Personal Information about our users in various ways.The USER is the individual using our Service. The User corresponds to the Data Subject,who is the subject of Personal Data.For example, we may collect information that you provide to us and information that wecollect automatically through your use of the Services.

We collect certain contact and professional information when you register for MARVL:Contact information such as your name, e-mail address and phone numberProfessional Information such as job title, company, and related information.

We may collect audio and video recordings (through the MARVL sales assistant and coachproduct).  In such cases, we will request consent if required by applicable law.

If you are a visitor to the Site, we may collect information on your use of the Site, such aspages visited, links clicked, text entered, and mouse movements, as well as informationmore commonly collected such as the referring URL, browser, operating system, andInternet Protocol (“IP”) address. We use publicly available sources to approximate yourgeographic region and Internet Service Provider based on your IP address. We use theterm “Usage Data” to refer to this information about your use of the Site that we collect.Our purpose in collecting Usage Data is to understand better how visitors use the site.

MARVL’s use and transfer to any other app of information received from Google APIs willadhere to Google API Services User Data Policy, including the Limited Use requirements.

To contact you. We may periodically contact you with information about the Services,such as security and fraud notices, online surveys, legal notices, news stories, newfeatures that you are entitled to access, and other important information. You may opt outof receiving commercial email messages from us by following the instructions contained inthose email messages.

We may need to contact you for invoicing, account management, and similar reasons andwe use account data to administer accounts and keep track of billing and payments.

We may use your Personal Information if we require it to comply with any applicable law,legal process or regulation, or enforceable governmental request.

We may use your Personal Information to investigate, detect, prevent, or otherwiseaddress fraud, security, or technical issues.  Additionally, we may use information tounderstand and resolve technical issues, app crashes and other issues being reported.

We may use your Personal Information to tailor and personalize your user experience; andmonitor our Services to ensure our services are working as intended, and to makeimprovements.

We may use your Personal Information as we believe is necessary or appropriate tosecure, protect, enforce, or defend the legal rights, privacy, safety, or property of theServices, its employees or agents, or other users and to comply with applicable law.

We use your Personal Information so that we can deliver the Services to you in aneffective, efficient and accurate way. Without it we would not be able to deliver a tailoredservice to you or respond to issues with these Services that are identified by us or you, orensure you get the most out of your experience.

We may use your Personal Information to facilitate and optimize our marketing campaigns,ad management and sales operations, and to manage and deliver advertisements for ourproducts and services more effectively, including on other websites and applications. Suchactivities allow us to highlight the benefits of using our Services, and thereby increase yourengagement and overall satisfaction with our Services. This includes contextual,behavioral and interests-based advertising based on your activity, preferences or otherdata available to us.

We may use your Personal Information to perform data analytics (such as research, trendanalysis, and financial analysis).

MARVL may use Anonymized Data for any business purpose.

The following provides information about entities with which we may share information.Our practices vary depending on the type of information.

We may share information within our family of affiliated companies, parents and/orsubsidiaries.

We may also share your information with business partners to provide you with servicesthat you request.

We may share the information we collect with vendors providing contractual services tous, such as virtual computing and storage services, hosting vendors, advertising serviceproviders, and list managers. We also may share your information, including yourpayment information, as appropriate, to process your payments for the Services orcomplete a transaction.

We may share your personal information as we believe is necessary or appropriate toprotect, enforce, or defend the legal rights, privacy, safety, or property of the Services, ouremployees or agents or users or to comply with applicable law or legal process, includingresponding to requests from public and government authorities.

Circumstances may arise where MARVL decides to sell, buy, divest, merge or otherwisereorganize businesses in some countries. We may disclose information we maintain aboutyou to the extent reasonably necessary to proceed with the negotiation or completion of amerger, acquisition, divestiture or sale of all or a portion of the MARVL’s assets.

We have in place physical, technical and administrative procedures to protect theinformation we collect online. However, as effective as these measures are, no securitysystem is impenetrable. We cannot guarantee the security of our database, nor can weguarantee that the information you supply will not be intercepted while being transmittedto us over the Internet.

Our websites are not directed at children. We do not knowingly collect any personalinformation from children under the age of 16 without parental consent unless permittedby law. If we learn that a child under the age of 16 has provided us with personalinformation, we will delete it in accordance with applicable law.

MARVL will retain user data ( THE USER is the individual using our Service. The Usercorresponds to the Data Subject, who is the subject of Personal Data. ) about use of ourServices only as long as it is being retained to accomplish the business purpose for whichit was collected and to comply with MARVL’s legal and contractual obligations.When you instruct MARVL to delete your Personal Information, we may (1) dispose of thatinformation securely or (2) convert it into non-Personal Information by aggregating it,de-identifying it, or otherwise anonymizing it so that it does not directly or indirectlyidentify you and cannot, with reasonable efforts, resources, and technologies, be used tore-identify you.

The Services are headquartered in Canada. Please be aware that information you provideto us or that we obtain as a result of your use of the Services may be collected in yourcountry and subsequently transferred to Canada or to another country in accordance withapplicable law.

If you are a user in the EEA or the UK, the following information applies with respect topersonal data collected through your use of our Services.

Under the General Data Protection Regulation and other applicable data protection laws,MARVL is considered the “data controller” of the personal data we handle under thisPrivacy Policy. In other words, MARVL is responsible for deciding how to collect, use anddisclose this information, subject to applicable law.  This Privacy Policy does not apply topersonal data for which marvl is a Processor, as defined in the GDPR and applicable dataprotection laws. Our contact information appears at the end of this Privacy Policy.

We process personal data on the following legal bases:
(1) with your consent;
(2) as necessary for our legitimate interests in providing the Services where those interestsdo not override your fundamental rights and freedoms related to data privacy; or
(3) performance of a contract: where use of your information is necessary to provide youwith Services under a contract, for example the relevant Terms of Service.

We will ensure that transfers of personal data to a third country or an internationalorganization are subject to appropriate safeguards.  Marvel offers European Union ModelClauses, also known as Standard Contractual Clauses, to meet the adequacy and securityrequirements for our Customers that operate in the EEA and the United Kingdom.

If you are a resident of the EEA or the UK, you have certain rights under Chapter 3 of theEU General Data Protection Regulation. These rights include:
The right to request access to any personal information we hold about you (“Subject Access Request”) as well as related information, including the purposesfor processing the personal information, the recipients or categories of recipientswith whom the personal information has been shared, where possible, the periodfor which the personal information will be stored, the source of the personalinformation, and the existence of any automated decision making;The right to obtain without undue delay the rectification of any inaccurate personal information we hold about you;The right to request that personal information held about you is deleted;The right to object to the processing of your personal data at any time.The right to restrict processing of your personal information; andThe right to request transfer of personal information to the individual or directly to athird party where that is technically feasible (the “right to data portability”).The right not to be subject to a decision based solely on automated processing, including profiling.

To make a request or otherwise exercise any of these rights, you can contact us atSupport@marvl.io To respond to your request, we will need to verify your identity andresidency and may require you to provide us with supporting information.

Where you believe that MARVL has not complied with its obligation under this PrivacyPolicy or European law, you have the right to make a complaint to an EU Data ProtectionAuthority.

0.1. To delete your personal information.

If you make this request, we will delete the personal information we hold about you as ofthe date of your request from our records and direct any service providers to do the same.In some cases, deletion may be accomplished through de-identification of the information.If you choose to delete your personal information, you may not be able to use certainfunctions that require your personal information to operate.To exercise this right you can contact us at Support@marvl.io.

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0.2. To stop selling your personal information.

We don’t sell or rent your personal information to any third parties for any purpose. Wedo not sell your personal information for monetary consideration. However, under somecircumstances, a transfer of personal information to a third party, or within our family ofcompanies, without monetary consideration may be considered a “sale” under law. Youare the only owner of your Personal Data and can request disclosure or deletion at anytime.If you submit a request to stop selling your personal information, we will stop making suchtransfers.Please note, if you ask us to delete or stop selling your data, it may impact your experiencewith us, and you may not be able to participate in certain programs or membershipservices which require the usage of your personal information to function. But in nocircumstances, we will discriminate against you for exercising your rights.To exercise your data protection rights described above, please send your request(s) by email: support@marvl.io.
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If you are a resident of the European Union (EU) and European Economic Area (EEA), youhave certain data protection rights, covered by GDPR.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use ofyour Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to beremoved from our systems, please email us at Support@marvl.io.

In certain circumstances, you have the following data protection rights:
0.1. the right to access, update or to delete the information we have on you;
0.2. the right of rectification. You have the right to have your information rectified if thatinformation is inaccurate or incomplete;
0.3. the right to object. You have the right to object to our processing of your PersonalData;
0.4. the right of restriction. You have the right to request that we restrict the processing ofyour personal information;
0.5. the right to data portability. You have the right to be provided with a copy of yourPersonal Data in a structured, machine-readable and commonly used format;
0.6. the right to withdraw consent. You also have the right to withdraw your consent atany time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to suchrequests. Please note, we may not able to provide Service without some necessary data.You have the right to complain to a Data Protection Authority about our collection and useof your Personal Data. For more information, please contact your local data protectionauthority in the European Economic Area (EEA).

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.According to CalOPPA we agree to the following:

0.1. users can visit our site anonymously;
0.2. our Privacy Policy link includes the word “Privacy”, and can easily be found on thehomepage of our website;
0.3. users will be notified of any privacy policy changes on our Privacy Policy Page;
0.4. users are able to change their personal information by emailing us at Support@marvl.io.

We honor Do Not Track signals and do not track, plant cookies, or use advertising when aDo Not Track browser mechanism is in place. Do Not Track is a preference you can set inyour web browser to inform websites that you do not want to be tracked.You can enable or disable Do Not Track by visiting the Preferences or Settings page of yourweb browser.

If you are a California resident, you are entitled to learn what data we collect about you,ask to delete your data and not to sell (share) it. To exercise your data protection rights,you can make certain requests and ask us:

0.1. What personal information we have about you. If you make this request, we will returnto you:
0.0.1. The categories of personal information we have collected about you.
0.0.2. The categories of sources from which we collect your personal information.
0.0.3. The business or commercial purpose for collecting or selling your personalinformation.
0.0.4. The categories of third parties with whom we share personal information.
0.0.5. The specific pieces of personal information we have collected about you.
0.0.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
0.0.7. A list of categories of personal information that we have disclosed for abusiness purpose, along with the category of any other company we shared it with.Please note, you are entitled to ask us to provide you with this information up to two timesin a rolling twelve-month period. When you make this request, the information providedmay be limited to the personal information we collected about you in the previous 12months.

0.2. To delete your personal information.
If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same.In some cases, deletion may be accomplished through de-identification of the information.If you choose to delete your personal information, you may not be able to use certainfunctions that require your personal information to operate.

0.3. To stop selling your personal information. We don’t sell or rent your personalinformation to any third parties for any purpose. We do not sell your personal informationfor monetary consideration. However, under some circumstances, a transfer of personalinformation to a third party, or within our family of companies, without monetaryconsideration may be considered a “sale” under California law. You are the only owner ofyour Personal Data and can request disclosure or deletion at any time.

If you submit a request to stop selling your personal information, we will stop making suchtransfers.

Please note, if you ask us to delete or stop selling your data, it may impact your experiencewith us, and you may not be able to participate in certain programs or membershipservices which require the usage of your personal information to function. But in nocircumstances, we will discriminate against you for exercising your rights.To exercise your California data protection rights described above, please send yourrequest(s) by email: support@marvl.io.Your data protection rights, described above, are covered by the CCPA, short for theCalifornia Consumer Privacy Act. To find out more, visit the official California LegislativeInformation website. The CCPA took effect on 01/01/2020.

We may modify this Privacy Policy from time to time. If we do so, we will update the“effective date” at the top.  We will notify you of changes by posting changes here, or byother appropriate means. Any changes to the Privacy Policy will become effective whenthe updated policy is posted.

Please feel free to contact MARVL if you have any questions about this Privacy Policy orMARVL’s practices or if you are seeking to exercise any of your statutory rights mentioned in this Privacy Policy. MARVL will respond within a reasonable timeframe. You may contact us at Support@marvl.io.