Privacy Policy

Effective Date: 11/1/2024

Last modified and effective: Nov 11, 2024

1. Welcome!

We take your privacy seriously and we know you do too. This Privacy Policy (“Policy”) describes how we collect, use, and share Personal Data, your Rights & Choices, and other important information about how we handle your Personal Data.

2. Scope of this policy

This Policy applies to your use of our “Service” which includes: www.mbps.com, and any website where we post these Terms, and any subdomains and mobile versions thereof (the “Website”), as well as the MBPS platform, mobile application (“Mobile App”), portal, and related client services (the “Platform”), as well as our online products or services, marketing emails, advertisements, or other similar services.

Please read our Policy carefully before accessing or using the Service. Accessing or using the Service indicates that you acknowledge the processing described in this Policy. If you do not accept this Policy, do not access or use the Service. Your use of our Service is also subject to our Terms.

Please note: We provide certain services and process information on behalf of Clients that have entered into an agreement with us (our “Clients”). We process data on behalf of our Clients as a “service provider” or “processor” and this is outside the scope of this Policy. Contact the Client for more information regarding their processing of your Personal Data.

Similarly, we may link to third-party sites, services, or applications (e.g. payment processors). This Policy reflects only how we process Personal Data through our Services. This Policy does not apply to information processed by or on behalf of our Clients or any other third party. We neither can control nor are responsible for the privacy practices or content of websites or apps operated by any third party. Please see the third party’s privacy policy for more information.

3. Contact us

This Service is operated by MBPS, LLC. (“MBPS,” “Company,” “us,” “our,” or “we”), a company registered in Arizona with an address of 200 E Van Buren – Floor 4, Phoenix, AZ 85004.

To contact us, please email us at: team@mpbs.com

4. Categories and Sources of Personal Information

Personal Data We Collect

To provide our Service, we may collect and use information that is defined as Personal Data under applicable privacy laws (“Personal Data”). We collect and use the following categories of Personal Data (note, specific Personal Data elements are examples and may change):

Audio/Visual Data

Image files and records with your name or likeness, such as profile photos, or audio such as voicemails, call recordings, and the like.

Biographical Data

Data relating to professional and employment history, qualifications, and similar biographic information.

Contact Data

Information about you and used to contact you, such as email address, mailing address, or phone number.

Device/Network Data

Personal Data relating to your device, browser, or application e.g. device identifiers, IP address, identifiers from cookies, session history and Service use metadata, and other data generated through applications and browsers, including via cookies and similar technologies.

General Location Data

Non-precise location data, e.g. location information derived from IP addresses.

Identity Data

Information such as your name, account login details, or other account handles/usernames.

Inference Data

Personal Data we create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites or interests.

Transaction Data

Information about transactions you make with us through our website and similar information.

Sensitive Personal Data

Personal Data deemed “sensitive” under data protection laws. For example, if you provide or make available such information in Chats, prompts, or other User Content we may process data that qualifies as, or may be deemed relating to, the following categories of Sensitive Personal Data:

• Payment Data

– Information such bank account details, or payment card information and relevant information in connection with financial transactions.

User Content

Personal Data included in content provided by users of the Service in any free-form or unstructured format, such as a “contact us” box, or other free text field, file, document, or message to us.

How We Collect Personal Data

We collect Personal Data from various sources based on the context in which the Personal Data will be used:

Data we collect from you

We collect Personal Data from you directly, for example, when you create an account, fill out a form, or contact us.

Data collected automatically

We may collect certain Personal Data automatically. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Service, access our Service, or when you open our Marketing Communications.

Data we receive from service providers

We receive Personal Data from service providers performing services on behalf of Revmo.

Social Media Companies

Data we create and infer

We, certain partners and third parties create and infer Personal Data such as Inference Data based on our observations or analysis of other Personal Data used under this Policy, and we may correlate this Personal Data with other information we use about you.

5. How we process Personal Data

Our Website

Generally

We process Device/Network Data, General Location Data, Identity Data, and Inference Data when you use our Website. We process this Personal Data as necessary to operate our Website, such as keeping you logged in, delivering pages, etc., for our Business Purposes, and our other legitimate interests, such as ensuring the security of our website, and other technology systems and analyzing navigation patterns, clicks, etc. to help understand and make improvements to the Website.

We may process this Personal Data for our Business Purposes and Targeted Advertising.

Cookies and Similar Tracking Technologies

We process Device/Network Data, Contact Data, Identity Data, Inference Data, Transaction Data, and General Location Data in connection with our use of cookies and similar technologies on our Website. We may collect this data automatically.

We and authorized third parties may use cookies and similar technologies for the following purposes:

• for “essential” purposes necessary for our Service to operate (such as maintaining user sessions, content delivery, and the like);
• for “functional” purposes, such as to enable certain features of our Service (for example, to allow a Client to maintain a logged-in session);
• for “analytics” purposes and to improve our Service, such as to analyze the traffic to and on our Service (for example, we can count how many people have looked at a specific page, or see how visitors move around the Service when they use it, to distinguish unique visits/visitors to our Service, and what website they visited prior to visiting our Service, and use this information to understand user behaviors and improve the design and functionality of the Service);
• for “retargeting,” Targeted Advertising, or other advertising and marketing purposes, including technologies that use Inference Data or other data so that we can deliver, buy, or target advertisements about our Service to you, or which are more likely to be of interest to you; and
• in connection with our integration with “social media” services e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or LinkedIn. These services may also engage in Targeted Advertising.

We may also process this Personal Data for our Business Purposes and Targeted Advertising.

Please note: We use Google Analytics on our Services. In some cases third parties, including Google, may view, edit, or access data directly from you as a result of cookies and similar technologies in use on our Services. We, or third party providers, may be able to use these technologies to identify you across platforms, devices, sites, and services. Third parties have their own privacy policies and their processing is not subject to this Policy.

See the “Rights and Choices” section below for information regarding opt-out rights for cookies and similar technologies.

Our Platform

Generally

We automatically collect and process Device/Network Data, General Location Data, Contact Data, and Inference Data when you access and use the Revmo Platform, our portal, Mobile Apps, and related Client services (our “Platform”). We use this Personal Data as necessary to operate our Platform, such as keeping you logged in, delivering the content and performing the functions and services you request, for information security operations, and our other Business Purposes. We do not sell or “share” Personal Data processed in this context.

Our Mobile App may request access to your device’s contacts (“Device Contacts”). Device Contacts are processed only on your device in order to identify callers on your phone. We do not transmit Device Contacts to our server or share that data any third parties. Our Mobile App may also allow you to access and sync with calendars on your device. We use calendar permissions to allow you to create and view events on your calendar. Data is only shared with users that created or are invited to an event.

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Account Registration

We process Identity Data, Inference Data, Biographical Data, Device/Network Data, and Contact Data when you register and create an account on the Platform. We process Payment Data if you associate payment information with that account, and we may process User Content and Audio/Visual Data if you provide it. Subject to your rights and choices under applicable law, we use this Personal Data to create and maintain your account, to provide the products and services you request, and for our Business Purposes. We do not sell or “share” or process Payment Data for Business Purposes not permitted under applicable law.

Please note, your organization may direct us to limit or control aspects of your account as set forth in the Client Agreement.

Single Sign-On and Linked Accounts

We process Identity Data, Inference Data, Contact Data, and Device/Network Data when you link your Google or other online service account to our Platform in connection with single sign-on (SSO). We may receive this Personal Information, as well as other information, from the service providers that provide the SSO service. The information we receive may vary based on provider, as well as your privacy settings. We process this Personal Information to confirm your identity, establish your account, grant you access to our Services, and for our Business Purposes.

Support & Implementation

We may process Identity Data, Contact Data, User Content, and Device/Network Data in connection with our support and implementation services and administration of our Clients use of our Platform. We process this Personal Data as necessary to perform Services on behalf of our Clients, or for our Business Purposes.

Purchases and Transactions

We process Transaction Data, Identity Data, Payment Data, Inference Data, and Contact Data when you purchase a subscription or complete other payments transactions through our Service. We do not store your Payment Data unless you associate it with your user account on our Platform.

We use this Personal Data as necessary to perform or initiate a transaction with you, process your order, payment, or refund, carry out fulfillment and delivery, document transactions, and for our Business Purposes.

Marketing communications

We process Device/Network Data, Contact Data, Identity Data, and Preference Data in connection with marketing communications (e.g. emails, SMS, push notifications, telemarketing, or similar communications) and when you open or interact with those communications (“Marketing Communications”).

You may receive Marketing Communications if you consent and, in some jurisdictions where permitted by law, as a result of account registration, purchase, or other inquiry or transaction that allows us to send marketing communications without consent. Marketing communications will include information such as offers, newsletters, and other information relating to our services or promotional material we believe will interest you.

We process this Personal Data to contact you about relevant products or services and for our Business Purposes and Targeted Advertising. See your Rights & Choices for more information about how to opt out of Marketing Communications.

Contact Us

When you contact us though the Service via email we use Contact Data, Device/Network Data, User Content, and any Personal Data contained within any User Content. We use Contact Data and User Content as necessary to communicate with you about the subject matter of your request and related matters. We may also use this Personal Data for our Business Purposes.

6. Purposes of use

Business Purposes

In addition to the uses described above, we generally use Personal Data for several common purposes in connection with our business (“Business Purposes”). Please see below for more information regarding the purposes for which we use your Personal Data.

Operate our Service and Fulfill Obligations

We use any Personal Data as is necessary to provide the Service, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.

Internal Processes and Service Improvement

We may use any Personal Data we process through our Service in connection with the development, operation, improvement, and maintenance of the Service, to determine how the Service is used or functions, for Client service purposes, in connection with the creation and analysis of logs and metadata relating to Service use, and for ensuring the security and stability of the Service. Additionally, we may use Personal Data to understand what parts of our Service are most relevant to users, how users interact with various aspects of our Service, how our Service performs or fails to perform, etc., or we may analyze use of the Service to determine if there are specific activities that might indicate an information security risk to the Service or our users.

Analytics

We use Personal Data as necessary in connection with our creation of analytics relating to how our Service is used, the pages and content users view, and the creation of reports regarding the use and performance of our Service and other similar information and metrics.

Compliance, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, use any Personal Data subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may use information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Corporate Events

Your Personal Data may be used or shared as part of routine corporate operations, as part of corporate reorganizations, or any business transition, such as a merger, acquisition, liquidation, or sale of assets.

Other Uses of Personal Data

If we use Personal Data in connection with our Service in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it.

Targeted Advertising

7. Data Sharing

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with Business Purposes, as described below.

Vendors and Service Providers

In connection with our general business operations, service improvements, enablement of certain features, and other lawful business interests, we may share Personal Data with vendors, licensors, service providers, and subprocessors who provide certain services to us or process data on our behalf. For example, we use third party hosting providers to host our Service or Content, and we may disclose information as part of our own internal operations, such as security operations, internal research, etc.

Clients

If you access and use the Platform, we may share your Personal Data with Clients on whose behalf we operate the accounts. For example, User Content you submit through the Platform, user account information, logs, and similar may be shared with the Client, e.g. for operational or security purposes.

Advertisers, and Social Media Platforms

We may share certain Personal Data with social media platforms, advertisers, ad exchanges, data management platforms, and the like in support of our Business Purposes and Targeted Advertising. We may allow these third parties to operate on or through our Services. These parties may be third party controllers, and may have their own privacy policies and their processing is not subject to this Policy.

Corporate Events

Your Personal Data may be disclosed to a third party in the event that we consider or go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Affiliates; Successors

To streamline certain business operations and develop services that better meet the interests and needs of our Clients, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.

Legal Disclosures

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the interests of us or any person. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

8. YOUR Rights & Choices

Your Rights

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on where you reside, and our obligations under applicable law. See the following section for more information regarding your rights/choices in specific regions. See below for more information.

Note: we are able to fulfill rights requests regarding Personal Data that we control or use. We may not have access to or control over Personal Data controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information.

Verification Requirements

All rights requests we receive directly must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. For example, we may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

Your Choices

You may have the following choices regarding the Personal Data we use, to the extent required under applicable law:

Changing Your Information

To change your information, please see your account settings or contact us at team@mpbs.com

Closing Your Account

If the email account associated with your email address is not active, we may remove it from our system without notice. To close your account, please see your account settings or email us at team@mpbs.com

Consent

If you consent to our use of Personal Data, you may withdraw your consent at any time. You may be required to close your account to withdraw consent where your consent is necessary to perform essential aspects of our Service.

Cookies & Similar Technologies

If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies and certain similar technologies using your browser’s settings menu. You must opt out of the use of some third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”)  Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising on other websites. You may continue to receive our advertisements, for example, based on the particular website content that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

Do Not Track

Our Services do not respond to your browser’s do not track signal.

9. Security

We implement and maintain commercially reasonable security measures to secure your Personal Data from unauthorized use. While we endeavor to protect our Service and your Personal Data against unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

10. Children

Our Services are neither directed at nor intended for use by persons under the age of 13 or the age of minority in your local jurisdiction. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Data if required by law. Do not access or use our Services if you are not 18 of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

11. Data Retention

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant purposes described in this Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of use. We generally consider the following factors when we determine how long to retain data (without limitation):

• Retention periods established under applicable law;
• Industry best practices;
• Whether the purpose of use is reasonably likely to justify further use;
• Risks to individual privacy in continued use;
• Applicable data protection impact assessments;
• IT systems design considerations/limitations;
• The safety, security, and usability of our products and service; and
• The costs associated with continued use, retention, and deletion.

We will review retention periods periodically and may pseudonymized or anonymize data held for longer periods.

12. Links to third-party websites or Applications

This Policy applies only to our Service. The Service may contain links to other websites or apps or may forward users to other websites or apps that we may not own or operate and to which this Policy does not apply. The links from the Service do not imply that we endorse or have reviewed these websites or apps. The policies and procedures we describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, we seek to protect the integrity of the Service and welcome any feedback about these linked websites and mobile applications.

13. International Transfers

We operate in and use service providers located in the United States and Singapore, and may operate our Services using services in other jurisdictions from time to time. If you are located outside the U.S., your Personal Data may be processed in the U.S. and Singapore and other jurisdictions where we operate. These jurisdictions may not provide the same legal protections guaranteed to Personal Data in your home country.

14. Changes to our Policy

We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Service following notice of any changes indicates acceptance of any changes. Unless explicitly stated otherwise, any new features that augment or enhance the current Service shall be subject to this Policy.

15. Regional SUPPLEMENTS

US STATES/CALIFORNIA

Scope

This section applies to individuals located in the United States, to the extent users have such rights under applicable law.

U.S. State Privacy Rights & Choices

To the extent U.S. state privacy laws apply to us, some residents of applicable U.S. states may have the following rights, subject to regional requirements, exceptions, and limitations. Please note, in some cases, to exercise your rights, you may be required to close or delete your account.

Confirm

Right to confirm whether we process your Personal Data.

Access/Know

Right to request any of following: (1) the categories of Personal Data we have collected, sold/shared, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the purposes for which we collected or sold/shared your Personal Data; (4) the categories of third parties to whom we have sold/shared your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.

Portability

Right to request that we provide certain Personal Data in a common, portable format.

Deletion

Right to delete certain Personal Data that we hold about you.

Correction

Right to correct certain Personal Data that we hold about you.

Opt-Out (Sales, Sharing, Targeted Advertising, Profiling)

Right to opt-out of the following:

• If we engage in sales of data (as defined by applicable law), you may have the right to direct us to stop selling Personal Data.
• If we engage in Targeted Advertising (aka “sharing” of Personal Data or cross-context behavioral advertising,) you may have the right to opt-out of such processing.
• If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may have the right to opt-out of such processing.

Opt-out or Limit Use and Disclosure of Sensitive Personal Data

Right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Data, if we collect it. This right does not apply in cases where we only use Sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law. You may be required to delete Chat history or prompts containing Sensitive Data in order to limit the use of this data.

Non-Discrimination

Individuals have the right to not receive discriminatory treatment as a result of their exercise of rights in their Personal Data.

List of Direct Marketers

California residents may request once per year a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year, if we have done so.

Submission of Requests

You may submit requests by contacting us via email to our privacy team at team@mpbs.com (please review our verification requirements section). If you have any questions or wish to appeal any refusal to take action in response to a rights request, contact us at team@mpbs.com. We will respond to any request to appeal within the period required by law.