OUR PRIVACY POLICY AS OF 4/15/22

Sepi Marketing, Inc. doing business as MySites.com, hereinafter collectively referred to as: (“MYSITES”, “we”, “us”, “our”) has developed this Privacy Policy to help you understand how we collect, use, and share your information when you visit or interact with our site, with our personnel during interviews, or when you interact with brands, organizations, institutions, or websites that are using our technology, services, analytics, and any other linked pages, features, content, or any other services we offer (collectively, the “Service” or “Services”). This Privacy Policy is an integral part of the User Agreement and Terms of Service.  It is only separated for the User’s convenience.  Each time you interact with MYSITES either on-line, in person, or by device (phone, tablet, desktop, voice, email) you hereby consent to our Privacy Policy as it exists and may be amended from time to time.

Types of Information Collected

The term “personal information” as used in this Privacy Policy refers to information that specifically identifies an individual (such as an individual’s first and last name, email address, phone number, credit card or other account number). The Service collects personal information when you interact with it; for example: when you collect rewards, subscribe for newsletters; register for membership or subscription services; respond to polls or surveys; purchase merchandise or services from the Service or third parties, register for sweepstakes, contests and other promotional opportunities; contact third parties through the site; or seek help from our customer service departments. We also collect personal information when you purchase products or services offline. We will also obtain personal information from reputable third parties.

Personal information does not include “aggregate” information, which is data we collect about the use of the sites or categories of site users, from which any personal information has been removed. We collect aggregate data for a number of purposes, including improving the Service, to diagnose technical issues, to help identify user needs so that we can better consider new products and services, and to tailor existing products and services to better serve our users. This Privacy Policy in no way limits or restricts our collection, use or disclosure of aggregate information.

How We Collect and Use information

We collect the following types of information:

Information you provide. When you willingly provide your personal information, we combine the information you submit under your account with information from other MYSITES services or third parties in order to provide you with a better experience and to improve the quality of our Services.

When you visit a MYSITES-enabled webpage, we send one or more cookies to your computer or other devices. We use cookies to improve the quality of our Service, including storing user preferences, improving products and ad selection, and tracking user trends such as how people use our Services.

Log information. When you access MYSITES Services via a browser, application or other client our servers automatically record certain information. These server logs include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that uniquely identify your browser.

Affiliated MYSITES Services on other sites. We offer our Services on or through other web sites. Personal information that you provide to those sites will be sent to MYSITES in order to deliver the Service. We process such information under this Privacy Policy.

Third Party Applications. MYSITES will make available third party applications, such as mobile applications, gadgets or extensions, through its Services. The information collected by MYSITES when you enable a third party application is processed under this Privacy Policy. Information collected by the third party application provider is governed by their privacy policies.

Location data. MYSITES will offer location-enabled services, sometimes part of another provider, to its brands. If you use those services, MYSITES will receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID).

Unique application number. Certain services include a unique application number that is not associated with your account or you. This number and information about your installation (e.g., operating system type, version number) will be sent to MYSITES when you install or uninstall that service or when that service periodically contacts our servers (for example, to request automatic updates to the software).

In addition to the above, we will use the information we collect to provide, maintain, protect, and improve our services (including advertising services) and develop new services.

We also engage in general profiling based on the personal information we process on behalf of the brands who use our services and use automated decision-making or profiling to help tailor the offers that you receive from them. However, this processing does not result in legal or other significant effects.

If we use this information in a manner different than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal information for the new purpose.

How We Share Information

Like many businesses, we sometimes hire third party vendors to perform certain business-related functions on our behalf, such as hosting specific portions of the Service, maintaining databases, delivering content, sending emails, administering content, mailing information, processing payments, or otherwise operating the Services. When we employ a third party vendor to perform these functions, that third party vendor will only be provided with the particular personal information or aggregate information it needs to perform its function, and is required to protect such Personal Data and/or Aggregate Data.

In addition, we enter into relationships with brands, advertising partners, networks who provide services to you, sell items or provide promotions to you. MYSITES provides and/or sells personal information of our customers over the age of 18 and/or aggregate information to those partners for marketing, re-marketing purposes, and for monitoring performance metrics.  We share information that has been anonymized or aggregates without limitation.  You have the right, at any time, to direct us to not to share or sell your personal information. This right may be referred to as the right to opt out.  Categories of information we have sold within the last 12 months:  None.

Categories of information we disclose for legitimate business purposes may include some or all of the following:  name, zip code, email, phone number, age, birth date, and gender.

You have the right to request that we delete any personal information about you which we have collected from you.  When we receive a verifiable request from you to delete your personal information, we will delete your personal information from our records and direct any of our service providers to delete your personal information from their records.  Our business or a service providers shall not be required to comply with your request to delete your personal information if it is necessary for us or our service providers to maintain your personal information in order to:

(1) Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between you and us.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

(7) To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us or our service providers.

(8) Comply with any legal obligation.

(9) Reset your Password.

(10) Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

International Visitors

This section applies to those that visit the Services from the European Economic Area and Switzerland.

As described in this Privacy Policy, we may obtain personal information collected through the Services from, or on behalf of, brands who use our Services. In this respect, we act as a processor for those brands, which have their own privacy policies that describe how they use information. To the extent that MYSITES is processing your personal Information on behalf of a brand in our role as a processor, please reach out to that brand directly to exercise any of your rights under local data protection laws.

MYSITES is a data controller with regard to personal information collected from individuals using our site from the European Economic Area (EEA) or Switzerland. This section applies to our process.

California Visitors

Under California’s “Shine the Light” law (CCPA), California residents providing personal information to obtain products or services for personal, family, or household use are entitled to request and obtain from mysites.com once per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediate prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 activities).

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

For an explanation of our privacy practices please review our privacy statement by clicking the “Privacy” link on our home page.

Your CCPA rights include:

• Obtain: you can request access to your personal information
• Delete: you can ask us to delete your personal information
• Opt-out from sales: you can instruct us to stop certain transfers of your personal information.

To Obtain, Delete, or Opt-Out, please send an email message to [email protected] with the subject line “California Privacy Information Request,” and we will provide the requested information to you at your e-mail address.  You may also call us at +1(800) 832-3292 Monday through Friday from 8:30 am to 4:30 pm Eastern time. Our offices are closed on Saturdays, Sundays, New Year’s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Day after Thanksgiving, Christmas Eve, Christmas Day, and New Year’s Eve.

If you want to exercise more than one of your CCPA rights, please submit a separate request for each CCPA right, which will help us handle your requests more effectively. Please be aware that we will process your requests in the order we receive them.

Whether or not you email or call us, we will need certain specific information from you to process your request so that we can confirm you are a California resident, determine if we have personal information about you, and for your request(s), verify your identity (such as providing us with a valid California ID or Driver’s License). We may also need to contact you further about your request, and you may choose the contact method you would like us to use (email or phone).

Please be aware there might be circumstances where we will not honor your request, as permitted under the CCPA. For example, if we are not able to verify your identity and that you are a California resident, we may not honor your request(s). In addition, we may not delete your personal information if an exception under the CCPA applies.

Lawful Basis for Processing

MYSITES processes personal information with your consent (e.g., when you agree that MYSITES may place cookies, or when MYSITES processes personal information submitted to the Services for specified purposes).

On other occasions, MYSITES may process personal information when it needs to do this to fulfill a contract (for example, for billing purposes) or where required to do this by law.

If necessary, MYSITES may also process personal information when it is in MYSITES’s legitimate interests to do this (e.g., for customer service or fraud detection) and when these interests are not overridden by your data protection rights.

Links to Other Sites

Please note that, while using the Services, you could be directed to other sites that are developed and administered by people or companies not affiliated with or controlled by MYSITES. These other sites may place their own cookies on your computer, collect data or solicit personal information.

We suggest that when you link to another site you review that site’s privacy policy, as it may be different from this Privacy Policy. MYSITES is not responsible for the actions of those people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Our link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.

How We Protect Your Personal Information

MYSITES uses reasonable efforts to protect your personal information against unauthorized access and unauthorized alteration, disclosure or destruction.

Retention

MYSITES will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine the period of storage of personal information is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of a contract or the initiation of a contract.

Child-Specific Terms

MYSITES understands that children’s privacy is important. We encourage parents and legal guardians to spend time with their age-appropriate children using the Services to be fully familiar with the Service features. By using or logging into the Service, we may ask users for their age. By using or logging into the Service or related features, you agree to respond truthfully and accurately about your age.

Children Under the Age of 18: The Service is prohibited to children under the age of 18. We will not knowingly collect or use personal information from anyone under 18 years of age without the express permission of the child’s Parent or Guardian. Children under the age of 18 years of age are expressly prohibited from submitting or posting any personal information on the Service.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current Privacy Policy.

Contact Us

If you have any questions regarding this Privacy Policy or wish to delete your personal information, or exercise your right to opt out, please contact us at [email protected] or

+1(800) 832-3292

All rights Reserved by Sepi Marketing, Inc., MySites.com © 2022