EZMTO PRIVACY POLICY

Last Updated June 8, 2023

ezMTO, Inc., as well as any present or future affiliated or related application, website or company (collectively “ezMTO”, “we”, “us” or “our”), recognizes the importance of your privacy. This privacy policy tells you what personal information we collect and how we use it. ezMTO may change this privacy policy from time to time, in its sole discretion (see section 6 below). By using or visiting any ezMTO website, application, product, software, tool, data feed, and/or service ("Service"), you understand and agree to the terms of this privacy policy. Capitalized terms not defined in this privacy policy are defined in the Terms of Service located at https://ezmto.com/termsOfService

1. What Information Do We Collect?

a. Personally Identifiable Information: We only collect personally identifiable information when you specifically and knowingly provide it to us, for example when you provide personal information such as your e-mail address, name, phone number, or other information to create a User Account. Personally identifiable information includes, where applicable, “personal data”, “personal information” and/or “sensitive personal information” each as defined in applicable law. We ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership). This privacy policy does not apply to the privacy practices of third parties that we do not own or control, such as any third party websites, services, applications, online resources to which the Service may link or otherwise reference that you may access through the Services. You may always choose not to provide personally identifiable information, but if you so choose, certain parts of the Service may not be available to you. If you have registered an account with us, you will have agreed to provide your personally identifiable information in order to access the Services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this privacy policy, please do not use our Services.

b. Non-Personally Identifiable Information: We may collect and aggregate information which does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This non-personally identifiable information may include a website that referred you to us, your IP address, browser type and language, hardware types, geographic location, and access times and durations. We also may collect navigational information, including information about the Service content or pages you view, the links you click, and other actions taken in connection with the Service.

c. Cookies and Local Storage: Cookies are small files that a site or its service provider transfers to your device through your browser (if you allow). Cookies enable the Site to recognize your browser and, if you have a registered account, associate it with your registered account. We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may employ two broad categories of cookies: (1) first party cookies, served directly by us or our partners to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by partners or service providers on sites or applications and can be used to recognize your computer or mobile device when it visits other websites. We may contract with third-party service providers to serve our cookies and manage generated data; these service providers are only permitted to use any information collected to help us conduct and improve our business. We also enable local storage, but that information is saved locally to your browser only and not shared with us. The Services may use some or all of the following types of cookies for the purposes set out below:

You can typically remove or reject cookies via your browser settings. To do this, follow the instructions provided by your browser (usually located within the “settings,” “help”, “tools”, or “edit” feature). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of the Services; for example, we may not be able to recognize your computer or mobile device and you may need to log in every time you use the Services.

2. What Do We Do With The Information That We Collect?

Except as disclosed in this privacy policy, ezMTO does not share your personal information with any outside parties. ezMTO will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:

• to operate, maintain, and improve the Services;
• to manage your account, including to communicate with you regarding your account;
• to operate and administer any proposals, events, or promotions you participate in on any site or application;
• to respond to your comments and questions and to provide customer service;
• to send you information including technical notices, updates, security alerts, and support and administrative messages;
• with your consent, to send you marketing e-mails about new proposals, opportunities, upcoming events, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails; non-marketing emails may include emails about your User Account or our business dealings with you; to process payments you make via the Services; and
• as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our privacy policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

We may share this information with service providers who perform services on our behalf, such as processing information requests, displaying stored data you access, to assist us in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose. If you have given your consent for us to do so, we may also send you text messages concerning offers from our partners and other third parties that we think may be of interest to you. If you do not wish to receive marketing emails, you may follow the “unsubscribe” or “stop” instructions included within each text message. We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

3. Your Rights

Consistent with applicable law, you may exercise any of the rights described in this section. Please note that we may ask you to verify your identity and request before taking action on your request.

a. Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information about you.

b. Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain 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).

c. Data Retention and Erasure. We generally retain your personal information for as long as necessary to provide you the Service 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. • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, for tax, legal reporting and auditing obligations. • Because we maintain the Service 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.

d. 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 sending a communication to us specifying which consent you are withdrawing.

e. Objection to Processing. In some jurisdictions, applicable law may entitle you to require us 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 we 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 defense of legal claims. Where your personal information is processed for information-sharing purposes, you may, at any time ask us to cease processing your data for these information-sharing purposes by sending an e-mail to support@ezmto.com.

f. Lodging Complaints. You have the right to lodge complaints about our data processing activities by filing a complaint with us at support@ezmto.com or with a supervisory authority.

g. Notice to EEA Citizens Regarding the General Data Protection Regulation. The European Union's General Data Protection Regulation (GDPR) may apply to accounts owned by citizens of the European Economic Area (EEA). As explained above, we collect Personal Information in various ways depending upon your use of the Service. We process Personal Information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreements; and (3) as necessary for our legitimate interests in providing services where those interests do not override your fundamental rights and freedom related to data privacy. The United States does not have protections in place for personal data as extensive as those within the EEA and may not provide adequate protection for personal data within the meaning of the GDPR. You may refuse to give or revoke your consent to this storage of your personal data at any time by emailing us with the subject line “Revoke EEA data consent.” If you are a citizen of a jurisdiction in the EEA and you decline to consent or revoke your consent, you will no longer be able to use our Services. We use physical, technical and procedural safeguards that comply with applicable legal standards to secure Your information from unauthorized access and use, alteration, and destruction. We process personal data based on consent according to Art. 6(1)(a) GDPR, which you are free to give or refuse. By using our Platform, you consent to our Privacy Policy. If you change your decision it will not affect the lawfulness of processing based on consent before its withdrawal.

4. Children's Policy

The Terms of Service clearly provide that Users must be 18. or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. ezMTO does not knowingly collect personally identifiable information from users under 13. In the event that we learn that we have collected any personal information from a user under the age of 13, we will attempt to identify and delete that information from our database.

5. Security and Encryption

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our Service has security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at support@ezmto.com.

6. Changes to This Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our websites or applications.

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