(Last updated 1/11/22)
MrPositive.com (hereinafter: “MRP”, “we”, “us” or “our”) is a company in California, which manages the website accessible at www.MrPositive.com (hereinafter: “Site”). We manage the Site and all the services provided therein (hereinafter: “Services”).
We WILL NEVER sell your email address to anyone. You can always unsubscribe from our newsletter by clicking unsubscribe on the bottom of the email.
2.2. The following terms “controller”, “processor”, “data subject”, “processing activity/ies”, “pseudonymisation”, “cross-border processing of personal data”, “supervisory authority” used in this document shall have the same meaning as in the GDPR unless relevant to a different law or regulation.
3. TYPES OF INFORMATION COLLECTED
3.1 General information
When you use our Site and our Services we collect some of your personal data. This enables us to effectively provide you with the Services. All personal data will be processed lawfully, fairly and transparently. Some of the data you provide to us directly, for example, when you provide your email address, make enquiries through our Site or contact us for support, etc. We also gather some of your data by keeping track of your interaction with our Site by using cookies and similar technologies. In order to make our Site available to you we may furthermore obtain and process certain data
3.2 Personal information you provide to us
The personal information that we collect on or through this Site may include:
(a) information that you provide by filling in forms on this Site, including, as applicable, information provided at the time of registering to use this Site, subscribing to our Services, posting material or requesting further Services;
(b) information that you provide when you enter a contest or promotion sponsored by us, and when you report a problem with this Site;
(c) records and copies of your correspondence (including email addresses), if you contact us;
(d) your responses to surveys or quizzes that we might ask you to complete for research purposes to provide you the best Services.
3.3 Personal information we collect through automatic data collection technologies
This type of information may include:
(a) device information which is, data from which your device could be identified, such as device serial number, or about your device, such as browser type;
(b) usage data such as browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data;
(c) in case of using a location-enabled device we may collect location data or use various means to determine the location;
(d) technical information such as the Internet protocol (IP) address used to connect your computer to the Internet, the User login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about the visits, including the full Uniform Resource Locators (URL), clickstream to, through and from the Site (including date and time), products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the Site, and any phone number used to call our customer service number.
4. HOW WE USE YOUR PERSONAL INFORMATION
We may disclose information that does not identify any individual, without restriction. We use information that we collect about you or that you provide to us, including any personal information:
- (a) to present this Site and its contents to you;
- (b) to provide you with information, products or services that you request from us;
- (c) to fulfill any other purpose for which you provide it;
- (d) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- (e) to notify you about changes to this Site or Services we offer or provide though it;
- (f) to allow you to participate in interactive features on this Site;
- (g) in any other way we may describe when you provide the information; and
- (h) for any other purpose with your consent.
4.1. Where and for how long is your personal data stored
We work with third-party email marketing services providers and store your personal data such as your email address on their servers. Payment information will be stored with Third-Party Payment Service Providers. Alternatively, any other personal data we collect ourselves is stored digitally with us in our back office.
Your personal data will be stored for as long as we have your consent or until you unsubscribe, if it is necessary to perform a contract or to promote a legitimate interest of a party, balanced with any risks to your fundamental right to privacy.
4.2 Do we share your personal data with third parties?
We may share aggregated data about our Users, and information that does not identify any individual, without restriction. We also may share personal data that we collect or you provide as described in this Policy:
- (a) to our subsidiaries and affiliates – subject to your consent;
- (b) to contractors, service providers and other third parties that we use to support our business to fulfill orders, deliver packages, send postal or email, email marketing, administer contests or sweepstakes, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments (Third-Party Payment Services Providers, whereas you agree to be bound by any privacy policies or other policies of Third-Party Payment Services Providers), operate the Site, troubleshoot, and provide customer service;
- (c) 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 MRP assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by MRP about this Site’s Users is among the assets transferred;
- (d) to fulfill the purpose for which you provide it;
- (e)for any other purpose disclosed by us when you provide the information;
- (g) with your consent; and
- (h) in connection with any legal investigation or to comply with relevant laws or to respond to subpoenas or warrants served on MRP.
We also may disclose your personal data:
- (a) to comply with any court order, law or legal process, including to respond to any government or regulatory request;
- (b) to enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes; or
- (c) if we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of MRP, our customers or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. UPDATING AND CORRECTING INFORMATION
We believe that you should have the ability to access and edit the personal information you provide us. You may change any of your personal information by sending us an email at legal @mrpositive.com. Please indicate your name, address and email address, and what information you would like to update when you contact us. We encourage you to promptly update your personal information if it changes. You may ask to have the information on your Account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on the Site. We may not accommodate a request to change information if we believe that the change would violate any law or legal requirement or cause the information to be incorrect.
6. USER CHOICES ON COLLECTION AND USE OF INFORMATION
You can always choose not to provide information, although it may be required to engage in a certain activity on the Site.
As a condition of purchase of our products and services, we will send you information regarding your account activity and purchases (“Administrative Emails”) and as updates about our products and promotional offers (“Promotional Emails”). You cannot opt-out of Administrative Emails. Administrative Emails relate to a User’s activity on the Site, and include emails regarding a particular User’s account, requests or inquiries, and purchases of products and services. In contrast to Administrative Emails, however, you do have a choice with respect to Promotional Emails. Promotional Emails advertise our products and services, including exclusive sales and other offers, and/or the products and services of our advertisers and affiliates. If you do not want to receive Promotional Emails from us, you may elect to opt-out of receiving Promotional Emails at any time after registering emailing us at legal @mrpositive.com, by writing to us at the address contained herein, or by hitting the “unsubscribe” button at the bottom of any of our emails. When contacting us, please indicate your name, address, email address, and what Promotional Emails you do not want to receive.
If you do not want us to use information that we collect or that you provide to us in order to deliver advertisements according to our advertisers’ target-audience preferences, then you can opt-out by sending to us an email stating your request to legal @mrpositive.com.
7. YOUR RIGHTS?
As our User you have certain rights regarding the processing of your personal information. The extent of these rights depends on where you are located. If you reside in the European Union, please refer to section 7.1., on the other hand, if you reside outside the EU refer to section 7.2. and section 7.3. if you are a resident of California. For any further questions regarding your rights, please feel free to contact us at any time via email disclosed below.
7.1. Rights of individuals residing within the European Union
If you are located within the EU, you have the following rights, guaranteed by the European General Data Protection Regulation (GDPR):
Right to be informed – you have the right to concise, transparent, intelligible and easily accessible information regarding the processing of your personal data.
Right of access – you have the right to access the personal data we have about you. You can ask us for confirmation as to whether your personal data is being used and in what way we use it (e.g. the purposes of the processing, the recipients). A copy of your personal data shall also be provided to you at your request.
Right to rectification (updating your information) – on your request we shall, without undue delay, ensure that inaccurate personal data is updated. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed.
Right to erasure (deleting your information) – when certain specific criteria are met (Article 17 GDPR), you have the right to ask us to delete any personal data we hold about you without undue delay.
Right to restriction of processing – under certain circumstances (Article 18 GDPR), you can request that we restrict the way in which we process your personal data.
Right to data portability – you have the right to receive the personal data that we hold about you in a structured, commonly used, machine-readable format. You may also transfer this data to a third party provider of services. Note that this right only applies when we use your data on the basis of your consent or performance of a contract and our use of your data is carried out by automated means.
Right to object – you have the right to object at any time to our processing of your personal data if you have a valid reason. Unless there are compelling legitimate grounds for further processing, we shall stop processing your personal data. This right also enables you to require from us that we stop using your personal data for direct marketing purposes.
Complaints – you may make a complaint to the relevant data protection regulator under the conditions from GDPR.
Since your privacy is very important to us, therefore, if you have any question regarding your rights or the circumstances in which these rights are applicable, please contact us at legal @mrpositive.com. You can also read more detailed descriptions of each right in Chapter III of the GDPR (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=SL).
Legal bases for processing information of EU residents – if you are an EU resident, we will only process your personal information when one (or more) of the following requirements is met:
- When we have your consent to do so. If consent is the legal basis for the processing of your personal data, you may withdraw your consent at any time.
- When processing is necessary for the performance of the contract to which you are a party to (e.g. for providing the services you requested).
- To comply with our legal obligations.
- When it is necessary to protect your vital interests or those of other individuals.
- When processing is necessary for the performance of a task carried out in the public interest.
- When we (or a third party) have a legitimate interest in processing your personal data.
7.2. Rights of the individuals residing outside the European Union
7.3. California Resident Rights
If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) regarding the use of your personal data. You may ask us to disclose what personal information we have about you and what we do with this information, to delete it and not to sell it. You also have the right to be notified when (or before) we collect your personal information, the types of personal information we are collecting and what we might do with that information. Note that we shall not discriminate against you for exercising your CCPA rights. In order to exercise CCPA rights, send us a request with sufficient information regarding your identification as the data subject and a detailed request with the declaration, under the penalty of perjury, that you are exercising your CCPA rights for lawful purposes. We will do our best to respond to your valid request (one that meets the described criteria) within 45 days of receiving it.
8. PROTECTION OF YOUR PERSONAL DATA
We take security seriously and take numerous precautions to protect the security of personal data. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted to or from the Site, and are not responsible for the actions of any third parties that may receive any such information.
8.1. Protection of personal data under EU legislation
If you are located in the European Union, the following safety measures are also provided for securing your personal information.
Security measures: Appropriate technical and organizational measures are implemented to ensure that, by default, the only personal data processed are those, which are necessary for each specific purpose of processing. This applies to the quantity, the extent of the processing, the period of storage and the accessibility of the collected personal data. With such measures, we try to ensure that personal data are not made accessible to an indefinite number of persons without your intervention.
In case of a personal breach: If a personal data breach occurs we shall without undue delay, where feasible, not later than 72 hours after having become aware of it, notify the supervisory authority. This does not apply when the personal data breach is unlikely to resolve in risk to your rights and freedoms. In case of a risk to your rights and freedoms due to a personal data breach, we shall also inform you without undue delay. This does not apply to situations where we have implemented appropriate technical and organizational protection measures that were applied to the personal data affected by the breach or if our subsequent measures ensure that the risk is no longer likely to materialize. It also does not apply when it would involve disproportionate effort. In the described cases we shall inform you through public communication or similar way in an equally effective manner.
9. DATA TRACKING
10. PRIVACY POLICIES OF THIRD PARTY WEBSITES
We do not address anyone under the age of 18. We do not knowingly collect personal data from anyone under the age of 18. If You are a parent or guardian and If you are aware that your child has provided us with personal data or information, please contact us. If we become aware that we have collected personal data or information from anyone under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers.
13. PUBLIC AREAS
We may provide areas on our Site where you can publicly post information about yourself. This information may be accessible by other consumers and companies. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any personal information.
Last updated: 7.5.2022
COOKIES, HOW AND WHY WE USE THEM
LIST OF COOKIES WE USE
The information provided below will help you understand the different types of cookies:
– Session Cookies: are temporary Cookies that remain in the cookie file of your browser until you leave the Site, so that none is registered on the User’s hard disk. Information obtained through these Cookies are used to analyze traffic on the web guidelines. Ultimately, this enables us to provide a better experience, to improve the content and facilitate its use. A Session Cookie expires immediately when you end your session.
– Permanent Cookies: a persistent cookie stores information on the hard drive so when you end your session and return to the same website at a later time the cookie information is still available.
List of the main cookies used on our Site:
– Strictly Necessary Cookies: Cookies that we need to operate our Site or to comply with legal obligations, e.g. Cookies such as those which serve to correct navigation or which allow to perform Services requested by the User or Cookies that will serve to ensure that the content of the Site is loaded efficiently. Without these Cookies certain features on our Site may not be available to you.
–Flash Cookies. Certain features of this Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on this Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
–Web Beacons. Pages of this Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit MRP, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
– Third-Party Cookies: These Cookies are placed on a User’s hard drive by a website from a domain other than the one a User is visiting, e.g. those used by social networks, or external content plug-ins.
– Analytical Cookies: These Cookies collect information that is used either in aggregate form to help us understand how our Site is being used or how effective our marketing campaigns are, or to help us customize our Site for you. They help us to perform periodic maintenance and guarantee the best Services to our Users. In general, websites make use of Analytical Cookies to collect statistical data of activities.
We use Google Analytics, which is a third party analytic tool that helps us measure how our Users interact with the content of our Site. For more information regarding how Google Analytics collects and processes data you can visit the website “How Google uses information from sites or apps that use our services” (https://policies.google.com/technologies/partner-sites?hl=en-US).
|__ga||Google Analytics||2 years||Used to distinguish users.|
|_icl_current_language||Google Analytics||1 day||Determines the user’s language preferences.|
|_utma||Google Analytics||2 years||This is a Google Analytics cookie that we use to collect information about how visitors locate and use our Site. This helps us to continue to improve the site. This is a 3rd party cookie.|
|_utmb||Google Analytics||30 minutes||This is a Google Analytics cookie that we use to collect information about how visitors (anonymously) locate and use our Site.|
|_utmc||Google Analytics||Session||More information: developers.google.com/analytics/resources/concepts/gaConceptsCookies.|
|_utmv||Google Analytics||2 years|
|_utmz||Google Analytics||6 months|
|APISID||2 years||This cookie is used by Google to store user preferences and information when viewing pages with Google maps on them.|
|devicePixelRatio||Google Analytics||1 week||Identifies the device’s screen resolution to improve the presentation of contents.|
|HSID, SID||2 years||In the long term, this allows us to provide a better user experience and to provide security mechanisms that prevent unauthorized access to user access data or the information they provide in contact forms for example.|
|JSESSIONID||Server||Cookie set by the server to provide functionality throughout your session on the site.|
|NID||6 months||To make advertising more attractive.|
|OGPC||More information about cookies of Google you can find at: https://www.google.com/intl/en/policies/technologies/types|
|PREF||2 years||These cookies are used by Google to store user preferences and information when viewing pages with Google maps on them|
|SAPISID||2 years||This cookie is used to remember user preferences while browsing.|
|SSID||2 years||This cookie is used by Google to know the number of users that use maps.|
Cookies play a very important role in optimizing your online experience. You can however disable them if you wish to do so. In this case access to certain parts of our Site may be affected. All web browsers allow you to limit the behavior of a Cookie or disable Cookies within settings or browser options. The steps for doing so are different for each browser. It is therefore possible that you set your computer to warn you when a Cookie is being sent or you can turn off all Cookies (for the latter go to your browser’s settings – Help menu).
Most browsers allow you to turn on a private function by which cookies are always deleted after the visit (“Private Mode”).
Important: Please, read the help section of your browser to learn more about how to activate Private Mode. You can continue visiting our Site even if your browser is in Private Mode, even if our Site browsing may not be optimal and some utilities may not work correctly.