Last updated date 03 August, 2019

Thank you for using Mailportation

1. INFORMATION WE COLLECT

1.1 Information that is necessary for the use of the Mailportation Platform.
Account Information.
When you sign up for an Mailportation Account, we require certain information such as your first name, last name, email address.
Profile and Listing Information. To use certain features of the Mailportation Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.

Identity Verification Information.
To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.

Payment Information.
To use certain features of the Mailportation Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or paypal information) in order to facilitate the processing of payments (via Mailportation Payments).

Communications with Mailportation and other Members.
When you communicate with Mailportation or use the Mailportation Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using Mailportation Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.

Additional Profile Information.
You may choose to provide additional information as part of your Mailportation profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
Address Book Contact Information. You may choose to import your address book contacts or enter your contacts information manually to access certain features of the Mailportation Platform, like inviting them to use Mailportation.

Other Information.
You may otherwise choose to provide us information when you fill in a form, update or add information to your Mailportation Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us (such as through Shipper Stories).

The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.

Identity Verification and Other Information.
If you are a Shipper, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.

1.3 Information We Automatically Collect from Your Use of the Mailportation Platform and Payment Services.
When you use the Mailportation Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Mailportation Platform and Payment Services.

Geo-location Information. When you use certain features of the Mailportation Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Mailportation may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

Usage Information.
We collect information about your interactions with the Mailportation Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Mailportation Platform.

Log Data and Device Information.
We automatically collect log data and device information when you access and use the Mailportation Platform, even if you have not created an Mailportation Account or logged in. That information includes, among other things: details about how you’ve used the Mailportation Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Mailportation Platform.

Cookies and Similar Technologies.
We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers.
In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Mailportation Platform or engage others to track your behavior on our behalf.
Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads.

Do Not Track Signals.
While you may disable the usage of cookies through your browser settings, the Mailportation Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.

Payment Transaction Information.
Mailportation Payments collects information related to your payment transactions through the Mailportation Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Mailportation Payments and to allow the provision of the Payment Services.

1.4 Information We Collect from Third Parties.
Mailportation and Mailportation Payments may collect information, including personal information, that others provide about you when they use the Mailportation Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Mailportation Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Third Party Services.
If you link, connect, or login to your Mailportation Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

Your References.
If someone has written a reference for you, it will be published on your Mailportation public profile page with your consent. To learn more, see our Help Center article about References.

Background Information.
For Members in the United States, to the extent permitted by applicable laws, Mailportation and Mailportation Payments may obtain reports from public records of criminal convictions or sex offender registrations.
For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, Mailportation and Mailportation Payments may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

Enterprise Product Invitations and Account Management.
Organizations that use our Enterprise products (such a Mailportation for work and programs with property managers and owners) may submit personal information to facilitate account management and invitations to use enterprise products.

Referrals.
If you are invited to Mailportation, the person who invited you may submit personal information about you such as your email address or other contact information.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Mailportation Platform through partnerships, or about your experiences and interactions from our partner ad networks.

1.5 Children’s Data.
Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

2. HOW WE USE INFORMATION WE COLLECT
We may use, store, and process personal information to (1) provide, understand, improve, and develop the Mailportation Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Mailportation Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

2.1 Provide, Improve, and Develop the Mailportation Platform.
We may use the personal information to provide, improve, and develop the Mailportation Platform such as to:

enable you to access and use the Mailportation Platform,
enable you to communicate with other Members,
operate, protect, improve, and optimize the Mailportation Platform and experience, such as by performing analytics and conducting research,
provide customer service, send you service or support messages, updates, security alerts, and account notifications,
if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
to operate, protect, improve, and optimize the Mailportation Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Shipper Guarantee, Shipper Protection Insurance, Experience Protection Insurance or other similar Shipper protection programs, we conduct profiling based on your interactions with the Mailportation Platform, your search and booking history, your profile information and preferences, and other content you submit to the Mailportation Platform, and enable your use of our enterprise products.
We process this personal information for these purposes given our legitimate interest in improving the Mailportation Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

2.2 Create and Maintain a Trusted and Safer Environment.
We may use the personal information to create and maintain a trusted and safer environment such as to:
detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
conduct security investigations and risk assessments,
verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide),
conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
comply with our legal obligations,
Resolve any disputes with any of our Members and enforce our agreements with third parties,
enforce our Terms of Service and other policies, and
in connection with the activities above, we may conduct profiling based on your interactions with the Mailportation Platform, your profile information and other content you submit to the Mailportation Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Mailportation Platform if such processes detect activity that we think poses a safety or other risk to the Mailportation Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting the Mailportation Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Mailportation or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
personalize, measure, and improve our advertising,
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Mailportation or its third party partners,
conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Mailportation Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Mailportation Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an Mailportation Account, and invite you to events and relevant opportunities (for example, when you share your Shipper story, we may use the information provided to reach out to you to invite you to relevant events).
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

2.4 How the Payments Data Controller uses the Personal Information Collected.
We may use the personal information as a part of Payment services such as to:
Enable you to access and use the Payment Services.
Detect and prevent fraud, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laundering regulations).
Enforce the Payment Terms and other payment policies.
With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

3. SHARING & DISCLOSURE
3.1 Advertising and Social Media; Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Mailportation Account or when you participate in promotional activities conducted by Mailportation partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Mailportation Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal information are not controlled or supervised by Mailportation. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

Please note that you may, at any time ask Mailportation to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@Mailportation.com.

3.2 Sharing between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

When you as a Sender submit a booking request, certain information about you is shared with the Shipper, including your profile, full name, the full name of any additional Senders, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
When you as a Shipper have a confirmed booking, certain information is shared with the Sender (and the additional Senders they may invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Accommodation or Experience address.

3.3 Profiles, Listings, and other Public Information.
The Mailportation Platform lets you publish information, including personal information, that is visible to the general public. For example:
Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
Listing trips are publicly visible and include information such as the approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
After completing a booking, Senders and Shippers may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Mailportation Platform (such as the Listing page).
If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Mailportation Platform, that content is publicly visible.
Based on our legitimate interest to promote the Mailportation Platform we may display parts of the Mailportation Platform (e.g., your Listing page) on sites operated by Mailportation’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

3.4 Additional Services by Shippers.
Shippers may need to use third party services available through the Mailportation Platform to assist with managing their Trips or providing additional services requested by you, such as delivering services. Shippers may use features on the Mailportation Platform to share information about the Sender (Sender name, Sender phone number) with such third party service providers for the purposes of coordinating the shipping. Shippers are responsible for third party service providers they use and ensuring those service providers process Sender information securely and in compliance with applicable law including data privacy and data protection laws.

3.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Mailportation and Mailportation Payments may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Mailportation, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Mailportation, its employees, its Members, or members of the public. For example, Shipper tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Mailportation Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Mailportation’s property, its Members and the Mailportation Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.6 Service Providers.
Mailportation and Mailportation Payments uses a variety of third-party service providers to help us provide services related to the Mailportation Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Mailportation Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims (such as claims under the Mailportation Shipper Guarantee). These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions .

Mailportation and the Mailportation Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.7 Corporate Affiliates.
To enable or support us in providing the Mailportation Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.

Sharing with Mailportation. Even if your country of residence is not the United States, your information may be shared with Mailportation, Inc. which provides the technical infrastructure for the Mailportation Platform, product development and maintenance, customer support, trust and safety and other business operation services to other Mailportation entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Mailportation Platform globally.
Sharing with Mailportation Payments. In order to facilitate payments on or through the Mailportation Platform, certain information as described above in “Information that is necessary for the use of the Payment Services” section above, may be shared with the relevant Mailportation Payments entity. The data sharing is necessary for the performance of the contract between you and us.
Sharing with Mailportation Ireland. If your country of residence is the United States, some of your information may be shared with Mailportation Ireland when you create a Listing or when you book a Shipper Service located outside of the United States (other than in China). The information shared in these circumstances may include: (i) your name, e-mail address and phone number, (ii) information relating to the Listing or Shipper Service, including its address, (iii) booking information for the Listing or Shipper Service, including but not limited to booking dates and payment amounts, and (iv) the names, nationalities, and identification details (including passport/national ID numbers and expiry dates) of any Senders. Additionally, when you send a message to a Shipper or Sender outside of the United States (other than China), your first name, profile picture and message content sent via the Mailportation Platform will be shared with Mailportation Ireland. The data sharing is necessary for the performance of the contract between you and us.

Shipper Services.
If you book a Shipper Service located in Japan: (i) your name, phone number, gender, birth date, email address, information relating to where you live and your work on your profile page, IP address in relation to the transaction, (ii) booking dates, (iii) messages between the Shipper and you or other Senders on the same booking, (iv) details (if any) of the payment method used by any Senders for booking the Shipper Service, and (v) the names and identification detail (if available) of any Senders.
Sending Messages. If you send a message to a Shipper in relation to that Shipper’s Listing in Japan, your first name, profile picture and message content.
The data sharing is necessary for the performance of the contract between you and us to enable you to list or book Shipper Services in Japan and communicate with Members in Japan.

Sharing with Mailportation China. Even if your country of residence is not China, some of your information will be shared with Mailportation China in the following circumstances:
Creating a Listing. If you create a Listing in China, information shared includes: (i) your name, phone number, email address, and passport/ID details, (ii) information relating to the Listing (e.g., address), (iii) booking information relating to the Listing, such as Sender details as set out below in Shipper Services, booking dates, and payment amounts, and (iv) messages between you and prospective and confirmed Senders at the Listing.
Shipper Services. If you book a Shipper Service located in China, information shared includes: (i) your name, phone number, and email address (ii) booking dates, (iii) messages between the Shipper and you or other Senders on the same booking, and (iv) the names, nationalities, and identification details (including passport/national ID numbers and expiry dates) of any Senders.
Sending Messages. If you send a message to a Shipper in relation to that Shipper’s Listing in China, information shared includes: your first name, profile picture and message content.
The data sharing is necessary for the performance of the contract between you and us to enable you to list or book Shipper Services in China and communicate with Members in China. Where required under law and you have expressly granted permission, Mailportation China may disclose your information to Chinese government agencies without further notice to you. We’ll notify you in advance in the above situations, and in specific situations where we apply any practices that differ from what is described in this Privacy Policy (including practices pertaining to disclosures to government agencies).

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Mailportation Platform and our affiliates’ services.

3.8 Collection and Remittance of Occupancy Taxes.
In jurisdictions where Mailportation facilitates the Collection and Remittance of Occupancy Taxes as described in the “Taxes” section of the Terms of Service, Shippers and Senders, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Shippers’ and Senders’ data and other information relating to them or to their transactions, bookings, Accommodations and Occupancy Taxes to the relevant tax authority, including, but not limited to, the Shipper’s or Sender’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Shippers from Senders, and contact information.

3.9 Government Registration.
In jurisdictions where Mailportation facilitates or requires a registration, notification, permit, or license application of a Shipper with a local governmental authority through the Mailportation Platform in accordance with local law, we may share information of participating Shippers with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Shipper’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of trips booked.

3.10 Information Provided to Enterprise Customers.
If you have linked your Mailportation Account to the Mailportation Account of a company or other organization (an “Enterprise”), added your work email address, or have a booking facilitated via another party (such as the future employer or other entity) or used a coupon in a similar capacity in connection with an Enterprise (such as using a coupon to pay for an accommodation for an enterprise related event like employment onboarding, orientation, meetings, etc.) through one of our Enterprise products, that Enterprise will have access to your name, contact details, permissions and roles, and other information as required to enable use by you and the Enterprise of such Enterprise products.

3.11 Shipper Information Provided to Mailportation for Work Customers.
If a booking is designated as being for business purposes and made by a Sender affiliated with an Enterprise, and the Enterprise is enrolled in our Mailportation for Work , such as a booking made for business purposes using a coupon provided by an Enterprise, we may disclose information related to the booking to the Enterprise, such as the name of the Shipper, the Accommodation address, booking dates, pricing, Listing details, and other related information, to the extent necessary for the adequate performance of Mailportation’s contract with the Enterprise and to provide the services. . At the request of the Enterprise or the Sender, we may also share this information with third parties engaged by the Enterprise to provide travel management, travel planning, financial reporting, personnel management, crisis management, or other services.

3.12 Sender Information Provided to Mailportation for Work Customers.
If you have linked your Mailportation Account with an Enterprise, and you are included on a booking designated as being for business purposes, we may disclose information related to the booking to the Enterprise to the extent necessary for the adequate performance of Mailportation’s contract with the Enterprise. Typically, this includes information related to the booking, such as your name, dates of the booking, number of Senders, pricing, Listing details, the Accommodation address, and other related information. At the request of you or your Enterprise, we may also disclose this information to service providers engaged by it, such as companies that provide travel management, financial reporting, personnel management, crisis management, or other services. In the event of a dispute, emergency, or similar situation involving a booking identified as being for business purposes, Mailportation may also share additional relevant information it believes is necessary to safely and quickly address the situation.

3.13 Programs with Managers and Owners.
We may share personal information and booking information with landlords, management companies, and/or property owners in order to facilitate programs with these partners. For example, Sender booking and personal information may be shared with owners and property managers of the building, complex, or planned community where a Shipper lives and/or the listing is to facilitate Shippering services, security, billing, and other services that may be provided.

3.14 Business Transfers.
If Mailportation undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.15 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

4. OTHER IMPORTANT INFORMATION
4.1 Analyzing your Communications.
We may review, scan, or analyze your communications on the Mailportation Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Mailportation’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2 Linking Third Party Accounts.
You may link your Mailportation Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:

some of the information you provide to us from the linking of your accounts may be published on your Mailportation Account profile;
your activities on the Mailportation Platform may be displayed to your Friends on the Mailportation Platform and/or that third party site;
a link to your public profile on that third party social networking service may be included in your Mailportation public profile;
other Mailportation users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
other Mailportation users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
the publication and display of information that you provide to Mailportation through this linkage is subject to your settings and authorizations on the Mailportation Platform and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

4.3 Third Party Partners & Integrations
The Mailportation Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Mailportation doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Mailportation, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of the Mailportation Platform may use third party services such as Google Maps/Earth services, including the Google Maps API(s), and Citibank for Mailportation Payments. Use of these respective services is subject to their privacy policies such as Google Maps/Earth Additional Terms of Use, and the Google Privacy Policy, Citi Privacy Policy.

5. YOUR RIGHTS
You may exercise any of the rights described in this section before your applicable Mailportation Data Controller and Payments Data Controller by sending an email to dpo@Mailportation.com. Please note that we may ask you to verify your identity and request before taking further action on your request.

5.1 Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your Mailportation Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

5.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Mailportation Account).

5.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

5.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Mailportation Account for fraud or safety reasons, we may retain certain information from that Mailportation Account to prevent that Member from opening a new Mailportation Account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Mailportation and Mailportation Payments may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Mailportation Platform, even after your Mailportation Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Mailportation Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

5.5 Withdrawing Consent and Restriction of Processing.
If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Mailportation specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 5.6 and pending the verification whether the legitimate grounds of Mailportation override your own.

5.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Mailportation and Mailportation Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Mailportation and/or Mailportation Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Mailportation to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@Mailportation.com.

6. SECURITY
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Mailportation Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Mailportation Account, please contact us following the instructions in the Contact Us section below.

7. CHANGES TO THIS PRIVACY POLICY
Mailportation reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Mailportation Platform and update the “Last Updated” date at the top of this Privacy Policy.

8. CONTACT US
If you have any questions about this Privacy Policy or Mailportation’s information handling practices, you may contact us.

Last Updated: August 3, 2019

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