2.   Privacy Policy

Scope

This policy covers any services being provided by marGo as a part of it’s online platform.

Privacy Principles we follow

marGo will ensure that all personal data that it holds will be:

• processed lawfully, fairly and in a transparent manner;
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• adequate, relevant and limited to what is necessary;
• accurate and kept up to date;
• kept in a form which permits identification of data subjects for no longer than is necessary;
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.

2.1  Types of information we collect

When you visit our website(s), we may collect personal data from you in order to allow us to provide certain services to you such as responding to your questions or to provide general marketing information to you and for you such as one and one-to-many marketing of products and events to your customers and prospects. We will use this data in connection with your visit to our website(s). You may, for example, provide us with your personal data when you:

• communicate with us through the “Feedback” link on our websites.
• apply for a job or internship.
• request to access a marGo research report; and
• apply to attend a marGo hosted or sponsored event.
• Log into or access marGo applications

If we use your personal data for any other purposes, we will provide you with a separate notice. The personal data that we collect from you include: your name; email address; the company for whom you work; company address; telephone number; the country where you live; and dietary requirements for registrations to attend a marGo hosted or sponsored event. We may also automatically collect data about you, such as technical information about your computer or internet browser. Data may also be collected about you indirectly through monitoring activities which will be conducted by or on our behalf in accordance with relevant legislation or regulatory requirements (for example, monitoring e-mails that we receive from you or recording telephone calls when you contact us). We will process your personal data for the purposes listed above on the basis of one or more of the following:

• the processing is necessary for the performance of a contract or for entering into a contract with you. Please note that where this is the case, we may not be able to perform or enter into a contract with you unless you provide your personal data;
• the processing is necessary to comply with a legal obligation;
• you have given your consent (where we rely on this legal basis, we will always seek to obtain your consent separately as and when necessary).
• Log in to

2.2  How we collect your information

Purposes of collection of personal information:

• Improving and personalizing services
• Marketing activities
• Market research
• etc.

marGo collects information in different ways. Directly from you or from your company. For example, when you:

• Log into your marGo account purchased by your company
• Make a purchase on our Platform.
• Create a personalized marGo shopping account.
• Track an order online.
• Sign up to receive promotional emails or text messages (including offers and sales alerts).
• Sign up to join a loyalty, rewards or similar program or club.
• Participate in one of our promotional sweepstakes, contests, surveys or focus groups.
• Use the Ratings & Reviews or related services and features.
• Submit a request to our Customer Service team.
• Install and use marGo’s mobile apps.
• Visit and navigate marGo’s Platforms on any device.
• Enable location-based features on our Platforms.
• Our business partners and clients, including online advertising networks and companies that co-sponsor our promotions.
• Interact with marGo’s social media pages, including but not limited to Facebook, Twitter, YouTube and Instagram.
• Combine information we collect about you from the different devices you use to access our Platforms.

2.2.1  Collection of personal data by automated means

Information that is passively collected: Cookies and similar technologies:

• When you visit the Services, we may use “cookies” which are small files stored as text on your computer or device.
• These “cookies” and other similar technologies like pixels, web beacons (also known as “clear GIFs”) and local storage may be used to collect information about how you use the Services and provide features to you.
• We may also ask advertisers or other partners to serve marGo ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.
• If a visitor does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. We may share non-Personal Information obtained via cookies with our advertisers and affiliates.

Mobile Device Unique Identifier

• When you use a mobile device to connect to our Services via a service provider that uniquely identifies your mobile device, we may use this unique identifier to offer you extended services and/or functionality. Certain Services may require the collection of your mobile phone number. We may associate that mobile phone number with the mobile device unique identifier.

Physical location

• When you download our mobile applications, we may use and store GPS and cell tower information relating to your mobile device, in combination with other location-based information such as your IP address, your billing postal code provided by your carrier, or your registration location, to provide enhanced location-based services, including delivery of Services to your current location, and to serve location-targeted advertising for marGo search results, and other content.

Log file information:

• Log file information may be automatically reported by your browser each time you make a request to access (i.e., visit) the Services. It can also be provided when the content of the Services is downloaded to your browser or device.
• When you use the Services, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

Strictly Necessary Cookies:

• Necessary cookies are used for the purpose of authentication and providing data security. These cookies are necessary for Our Site to work and enable us to distinguish users and enable you to use its services and features. Disabling these cookies will encumber Our Site’s performance and may make these services and features unavailable. These cookies may include the following:

Functional Cookies:

• These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Analytics or Performance Cookies:

• These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

2.3   How we use your information

The following are the examples of how we may use your information which include:

• To Understand Your Interests. For example, we may use your information to better understand what products interest you based on information we collect about you and your household.
• To Communicate with You. We may communicate with you about your account or our relationship. We may also contact you about this Privacy Policy or our Platform Terms & Conditions.
• To Improve Our Products and Services. We may use your information to enhance our Platforms and services to serve you better.
• To Respond to Your Requests or Questions. This may include responding to your customer feedback.
• For Security Purposes. This could include protecting our company and our customers. It may also include protecting our Platforms.
• For Marketing Purposes. We may provide you with information about new products and special offers. We may use your information to serve you ads about products and offers. We may tell you about new features or updates. These might be third-party offers or products we think you might find interesting.
• To Send Push Notifications. If you use our mobile apps, we may send you push notifications about new products or special offers.
• To Support Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or return transactions.
• Law or regulatory obligations. Certain laws and regulations require us to maintain and disclose collected information.

2.4   How we share your information

We operate globally and, like many businesses, we operate back office IT functions. From time to time, we may also need to transfer your personal data to third parties in other countries where we do business or have a service provider. Such countries may not have the same data protection laws as the USA or European Union or the country in which you reside. When transferring your personal data, we will take all appropriate steps to provide an adequate level of protection for your personal data in accordance with relevant legislation. These steps may include exercising audit and inspection activities in respect of the actions of those third parties in connection with the use of your personal data. We may disclose/share your information in the following ways:

• On our Platforms. For example, we may display information you post on our Ratings & Reviews feature.
• With Our Business Partners. For example, this may include third parties that provide financial products and services related to our business. It may also include a third party that co-sponsors a contest or promotion.
• With Third Parties for Marketing Purposes. This may include third parties in whose products or services we believe you may be interested. These third parties may also share your information with others.
• With Our Service Providers. We may share your information with third parties who perform services on our behalf. For example, this may include vendors and payment processors. It may also include companies that send emails on our behalf.
• Government, courts, and Law enforcement. We will access, preserve, and share any information about you, without your consent, to government or law enforcement officials or private parties as we in good faith believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to comply with applicable laws, to protect the property and rights of marGo, you or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to pose a risk of being, or is illegal, unethical or legally actionable. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

2.5   How we store your information

By registering for and using the Services you consent to the transfer of information to anywhere in the U.S. where the Services or its Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. Although we implement reasonable administrative, physical and electronic security measures to protect your Personal Information from unauthorized access, we cannot ensure the security of any information you transmit to or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Services, you agree to accept notice in that form. How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

2.6     How we protect your information

While no data transmission over the internet is 100% secure, we are committed to protecting the information we receive from you. We take appropriate security measures to protect your information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system. While no computer system is completely secure; we believe the measures, we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved. The website may contain links to other websites that we do not own or control. The Privacy Policy does not apply to these websites and we are not responsible for the privacy practices of such websites or other services operated by such websites. Once you leave the Site via such a link, we recommend your review the privacy policy applicable to such third-party websites to learn how they use and disclosure your personally identifiable information. Our staff are trained in how to keep your information safe and secure. We use secure systems and buildings to hold your information. We aim to only keep your information for as long as we need it. Here are some of the things we do to protect your information.

Staff training	We train our staff in how to keep your information safe and secure.
Secure handling and storage	When we send information overseas or use third parties that handle or store data, we put arrangements in place to protect your information.
System security	When you log into our websites or apps, we encrypt data sent from your computer to our systems so no one else can access it. We have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorized people accessing our systems. When we send your electronic data to other organizations, we use secure networks or encryption. We use passwords and/or smartcards to stop unauthorized people getting access.
Building security	We use a mix of alarms, cameras, guards and other controls in our buildings to prevent unauthorized access.
Destroying or de-identifying data when no longer required	We aim to keep personal information only for as long as we need it – for example, for business or legal reasons. When we no longer need information, we take reasonable steps to destroy or de-identify it.

We will maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows: Confidentiality: only people who are authorized to use the data can access them; Integrity: Personal Data should be accurate and suitable for the purpose for which they are processed; Availability: authorized users should be able to access the data if they need it for authorized purposes.