Privacy Policy

Maven | Privacy Policy

1. INTRODUCTION

This Privacy Policy is effective as of August 1, 2022, or earlier if you are presented with it sooner, like when you create an account, pair a Maven device to your mobile device, or visit Maven’s website.

At Maven Pet, Inc. (“Maven,” “us,” “we,” or “our”), our mission is to improve pets’ quality of life and bring owners peace of mind.We provide proactive pet care: the health and well-being of pets are continuously tracked and and thoroughly monitored by their assigned Maven Vet, who provides insights what can be improved and lets the owner know if there’s anything unusual to worry about, potentially avoiding major complications later on.

We exist to improve your life, not invade it. With a focus in using technologies to improve pets’ quality of life, we are committed to the principles of respecting your privacy. We exist to improve your life, not invade it. We take your privacy seriously and want you to understand how we use, collect, and share Personal Data, and the measures we take to protect your Personal Data.

This Privacy Policy applies to Personal Data we collect about members and other consumers who interact with Maven or use our services, including by visiting our website (located at www.maven.pet) and our social media pages, or using our Maven connect software (“Software”), our Maven mobile application for iPhone OS and Android OS (“Maven App”),  and our Pet Health Tracker - Maven (collectively, the “Services”). This Privacy Policy does not cover the practices of companies that we do not own or control, or people that we do not manage. We are not responsible for the policies and practices of any third parties, and we do not control, operate, or endorse any information, products, or services that may be offered by third parties or accessible on or through the Services.

We can guarantee you that:

• We will only collect data that is useful to process transactions, send periodic emails and to improve Maven’s products, services, and user experience;
• We will be transparent about our data practices and will explain them in clear language;
• We will never sell your data, and will only share personally identifiable data when you direct us to;
• We will always take the security of your data seriously.

We have provided supplemental notices below for residents of California.

2. HOW WE COLLECT PERSONAL DATA

Before we go any further, let us tell you what “Personal Information” means to us, at Maven. For the purpose of Privacy Policy, “Personal Information”, means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to a name, an identification number, or, in certain circumstances, location information or an IP address.

Now that we share what we mean by “Personal Information”, let us tell you when and from where we collect Personal Data about you:

• Visiting the website: we collect industry standard log data that records information about your visits, such as your browser type, operating system, the URL of the page that referred you, the different actions you performed, and the IP address from the pages you visited. We use this type of information to provide you with information that’s relevant to your location and to make sure that the website is working properly;

• Placing an order: when placing an order, you will be asked to fill in some personal information, including your email address, shipping address, name, and phone. We save the data so that we can provide customer service related to the purchase and process your order through our fulfillment partner. Note that, in order to complete your order on our website, you’ll need to provide payment information. We do not, however, view or store your credit card information. This is handled by our third-party payment processor.

• Automatic data collection, such as Cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services;

• Creating a Maven account: when using the Maven App and if you want to access data collected by the Pet Health Tracker from the Maven App, you must create a Maven account. When you create a Maven account, we ask for some personal information, including your email address, name, and date of birth.
• Activating a Maven device: When activating the Pet Health Tracker or another device, you will be asked to download the Maven App and enter information about your pet such as a photo, gender, date of birth, weight, and size. Whenever you add this type of data, we collect it and store it with your other account information. We use this information to determine your pets’ personalized fitness stats – for example, active time, excited time and resting time - and transmit this data to the Maven App.

• Syncing your Maven device: when syncing your device, data about your pet’s activity, health and well-being are transferred from your device to our servers. This data is stored and used to provide our Services. Each time a sync occurs, we also log data about the transmission. Some examples of the log data are the sync time and date, device battery level and data related to the pet’s activity, health and well-being since the last sync occurred.

• Asking for Help: whenever you contact Maven for help, we collect your name and email address along with any additional information you provide in your request and store it on our servers in order to provide you with customer service and to improve customer service. You can also contact Maven through public forums such as Instagram, Twitter or Facebook; however, we cannot maintain the privacy of your communication with us if you contact us through these channels.
• Customers and partners, such as employers, insurance companies, coaches, teams, or other organizations that engage with our Services;
• Marketing and advertising partners, such as companies that have entered in joint marketing relationships with us or assist us with marketing or promotional services, which may provide us with data related to how you interact with our Services, advertisements, or communications;
• Social media, other third-party platforms, and linked accounts, devices, or features, if you interact with our pages on social media sites, post content to their sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or features to your Maven account; and
• Data providers, such as information services and data licensors, when we supplement your data.

3. PERSONAL DATA WE COLLECT

We may collect the following types of Personal Data:

• Contact details, such as your first and last name, email and mailing address, and phone number;
• Profile data, such as username and password that you may establish to create a Maven account, as well as any photographs or information you choose to include in your Maven profile;
• Communications that we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews;
• Payment and transactional data needed to complete your orders on the website or through the Services (including name, email address, payment card information, bank account number, billing information) and your transaction history, although Maven does not have access to payment card numbers. Our payment processors will collect the financial information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy;
• Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them (e.g., the marketing emails that you open and the links within them that you click);
• Device data, such as your computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area;
• Online activity data, such as pages or screens you view, how long you spent on a page or screen, the website you visited before visiting our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

4. COOKIES AND SIMILAR TECHNOLOGIES

Maven uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, as well as to analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Cookies are not being used to gather information unnecessarily. Before starting using cookies and similar technologies on our website, you will be asked to agree. Most browsers also have settings to prevent them from accepting new cookies, to notify you when you receive a new cookie, or to delete or disable cookies altogether. You can delete the cookies that have been placed on your hard drive at any time. You can find more detailed information in the "Help" function of your browser.

Cookie Usage and Type. Maven uses the following Cookies:

• Essential Cookies: Essential Cookies are required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable.
• Functionality Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (e.g., your region).
• Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how users use our Services by collecting information on how often a user engages with a particular feature of the Services. We use these aggregated statistics internally to improve the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses Cookies in connection with its Google Analytics services. For more information on how Google uses this information, click here.
• Marketing Cookies: Marketing Cookies collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you. For more information, please see the section below titled “Interest-based advertisements.”

Online tracking opt-outs.There are a number of ways you can opt-out of certain interest-based advertising and other online tracking activities, which we have summarized below.

• Blocking Cookies in your browser. Most browsers let you remove or reject Cookies, including Cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept Cookies by default until you change your settings. For more information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile device settings. Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of your advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting Cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party Cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Visiting our OneTrust Privacy Preference Center. You can click here to customize your Cookie consent preferences.
• Third Party Services. Maven uses third-party services, listed below, to help us analyze certain online activities and improve our services. For example, these providers help us measure the performance of our online campaigns or analyze visitor activity on the Site. These outside services may also collect Personal Information about you and your online activities and place cookies on your computer's hard drive or your mobile device's memory or use web beacons to collect or receive information from the Services and elsewhere on the internet and use that information to provide analytics and to target ads. The information practices of these outside services are not covered by this Privacy Policy. We cannot access, nor do we have any control over, the cookies or other web technologies they may use. We send data to third-party analytics providers, so we can use their tools to understand how you and other Maven users use our services.
  We use advertising cookies to present you with opportunities to purchase Maven products on our website, and retargeting cookies, to present you with Maven advertising on other websites based on your interaction on Maven’s website.
  Social media tools, like widgets and plug-ins, are used so you can share information from Maven on other sites such Facebook, Twitter or by email. These interactive mini-programs collect your IP address, record the pages you visit on Maven, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by Maven’s Privacy Policy. We also use the Facebook and Twitter pixel tags to help us understand how effective our marketing is on those sites.
• Platform opt out. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are:

• Google Adwords Conversion: You can adjust the Google Ads Settings and opt-out of this program;
• Google Tag Manager: To adjust the Settings and opt-out of this program please email us to [e-mail];
• Facebook Pixel: You can adjust the Settings and opt-out of this program in the setting of your Facebook account;
• Hotjar: You can adjust the Settings and opt-out Hotjar to collect your data by visiting https://www.hotjar.com/legal/compliance/opt-out.

• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
• Digital Advertising Alliance for Websites: https://optout.aboutads.info;
• Digital Advertising Alliance for Mobile Apps https://youradchoices.com/appchoices;
• Network Advertising Initiative: https://optout.networkadvertising.org/. 

Please note that some opt-out features are Cookie-based, meaning that when you use these opt-out features, an “opt-out” Cookie will be placed on your computer or other device indicating that you do not want to receive interest-based advertising from certain companies. If you delete your Cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.

Opting-out of interest-based advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.

To opt out of ads on Facebook, Pinterest, or Google that are targeted to your interests, use your Facebook, Pinterest, or Google Ads settings.

Check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.

• Data Analytics. We use Mixpanel as our primary analytics tool to understand how our customers use the Maven Services and Mixpanel People to contact you about the use of our product, for example, to contact you if you have trouble syncing your Device. You can read the MixPanel Privacy Policy and opt-out by visiting https://mixpanel.com/optout.
  We use Google Analytics and Google Optimize analytics cookies that allow us to see how you engage with our services, so we can improve your experience. We encourage you to read the Google Privacy Policy. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on.
  Additionally, we use Fabric that provides analytics from iOS and Android Apps; Instabug that helps as a support for problem resolution related with the app; Firebase in order to send App push notifications and Apple Analytics to obtain Analytics from iOS App. To adjust the Settings and opt-out of these programs please email us to [e-mail].

5. HOW WE USE PERSONAL DATA

We process Personal Data to operate, improve, understand, and personalize our Services. We use Personal Data for the following purposes:

Service delivery, including to:

• Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis and product development;
• Satisfy the reason you provided the information to us, including responding to and fulfilling requests;
• Communicate with you about the Services, including Service announcements, updates, or offers;
• Provide support and assistance for the Services;
• Create and manage your account or other user profiles;
• Customize website content and communications based on your preferences; and
• Process orders, memberships, or other transactions.

Research and development. We may create and use Aggregated Data, De-identified Data or other anonymous data from Personal Data we collect, including Pet Wellness Data, for our business purpose, including to analyze the effectiveness of the Services, to improve and add features to the Services, and to analyze the general behavior and characteristics of users of the Services. We also use anonymous Pet Wellness Data for research purposes to help us and our research partners answer important questions about animal performance and create an even-better experience for our members by identifying cutting-edge insights and providing new content and product features.

Marketing and advertising. We do not use personally identifiable pet wellness data for marketing or advertising purposes. We may use other personal data, such as data collected when you browse our website or your phone number, for example, to send you marketing SMS or advertise the services:

• Direct marketing. We may send you direct marketing messages and SMS as permitted by law.
• Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use Cookies and similar technologies to collect information about your interaction over time across the web, our communications, and other online services, and may use that information to serve online ads. We comply with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising. To learn more about the industry self-regulatory programs and other information and choices about interest-based ads, please see the section above entitled “Online tracking opt-outs.”

Compliance and protection, including to:

• Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services;
• Comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use and Terms of Service;
• Audit our internal processes for compliance with legal and contractual requirements and internal policies;
• Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

6. HOW WE SHARE PERSONAL DATA

We may share your Personal Data with:

• Service providers, such as payment processors, vendors who advertise our Services, security and fraud prevention consultants, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf;
• Advertising partners that may collect information on our website through Cookies and other automated technologies, including for the interest-based advertising purposes described above. We do not share your data with advertising partners;
• Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services they render to us;
• Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process; and
• Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Maven or our affiliates (including, in connection with a bankruptcy or similar proceedings).

We may also share data that you direct us to share:

You can direct us to share data with other parties. For example, you might authorize us to link your Maven account with a third-party. Once you direct us to share your data with a third party, that data is governed by the third-party’s privacy policy. You can revoke your consent to share with the third party at any time by contacting Maven Customer Support.

7. HOW YOU MAY SHARE PERSONAL DATA THROUGH MAVEN

Depending on your use of the Services, you may share Personal Data with:

• Other users of the Services, which allow you to share information and content with other users of the Service, and users are by default searchable by other users;
• Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with Maven or post content to social media;
• Public. When you make Personal Data visible to other users of the Services, it may become publicly available and can be collected, viewed and used by anyone;
• Managing entity. If your use of the Services is on behalf of or managed by a managing entity, such as a coach, team, organizing body, or other entity with which you are affiliated, your account information and Personal Data may be shared with the managing entity subject to your consent, and you consent to that managing entity allowing that information to be publicly shared, subject to any features of the Services that expressly override that control. The managing entity will determine how the relevant information and content is shared;
• Default visibility settings. The privacy settings on new Maven accounts are set to reveal minimal data about you with the purpose of getting you active and involved. You can accept to share more info on the App and can always adjust your privacy settings by sending us an email;
• Newsletter. If you subscribed to our newsletter, we will use your data in the following ways:
• Maven’s newsletter includes news, offers, and other information from Maven. Through the newsletter, you will receive personalized advertising about our products and services or proposals to participate in campaigns;
• By subscribing to the Maven’s newsletter, you agree that we may review your purchasing and use patterns of our sites so that we can compile a personalized newsletter for if it meets your needs and interests. Your data is also stored and used for promotional purposes and market research. For this purpose, we will only contact you by email. Finally, we will also use your data to analyze and improve the effectiveness of our sites.
• If you no longer wish to receive the newsletter, you can unsubscribe from the newsletter at any time. To do so, click on the link in all newsletters. You will be directed to the cancellation process. You may also email us your revocation of consent regarding your subscription to the newsletter.
• Contests and Giveaways. Maven may offer opportunities to participate in contests, giveaways and other promotions. Any data you submit in connection with these activities will be treated in accordance with this Privacy Policy unless the rules for those offers notes otherwise.
• Surveys. Maven may also ask you to participate in surveys that help us understand your use of our products and services. Any PII you provide to Maven in these surveys will only be used in relation to that survey and as stated in this Policy.

8. YOUR CHOICES

Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request a full deletion of your account and corresponding data by contacting Customer Support. By doing that, data that can identify you will be removed from the service, including, but not limited, to your email and name. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it.

Privacy settings. You can change certain privacy settings, such as whether you are searchable on Maven by your name or username, if you scroll down to Settings, located on the Main Menu page of the Maven mobile application, and select “Privacy,” where you can choose to make yourself private or searchable.

Push notifications and device permissions. When you use our mobile application, you may initially opt-out of push notifications that we may send you or revoke any permissions you previously granted to us at any time such as permission to access your camera or camera roll, Bluetooth, microphone, Siri, search, push notifications, background app refresh and/or cellular data access, by changing the settings on your mobile device.

Marketing communications. We will give you the ability to opt-out of marketing-related emails and other communications by going to our preferences management page, or by following the opt-out or unsubscribe instructions contained in the message. You cannot opt-out of receiving certain non-marketing emails regarding the Service.

Online tracking opt-outs. There are a number of ways you can opt-out of certain interest-based advertising and other online tracking activities, which we summarize in the “Online tracking opt-outs” section above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to online services. The Services do not currently support “Do Not Track” requests or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

9. OTHER SITES AND SERVICES

The Services may contain links to websites and other online services operated by Third Parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any Third Party. We do not control websites or online services operated by Third Parties, and we are not responsible for their actions. You can learn about and control how these Third Parties use and share Personal Data about you, including with Maven, by reviewing their privacy notices and exercising the privacy choices the Third Party may offer.

10. DATA SECURITY AND RETENTION OF PERSONAL DATA

We employ a number of physical, technical, organizational, and administrative security measures designed to protect the Personal Data we collect. While we endeavor to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data.

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

If you have a security-related concern, please contact Maven Customer Support.

11. PERSONAL DATA OF CHILDREN

If you are under 13, or 16 where applicable, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13, or 16 where applicable, we will delete that information as quickly as possible. If you believe that a child under 13, or 16 where applicable, may have provided us Personal Data, please contact us at [e-mail].

12. CHANGES TO THIS PRIVACY POLICY

We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We will alert you to changes by placing a notice on the Maven website, by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

13. CONTACT US

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to [e-mail] or at the mailing address below.

Maven Pet, Inc.

Attn: Legal Department

200 Continental Drive, Suite 401, Newark DE 19713

14. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”).

We do not sell Personal Data. As we explain in this Privacy Policy, we use Cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of Cookies and other tracking technologies, please review the instructions provided in the “Online tracking opt-outs” section. You may also direct us to share your data, as described in the “How You Share Personal Data Through Maven” section of the Privacy Policy.

California Privacy Rights. If you are a California resident, you have the following rights:

• Information: The Privacy Policy describes the types of Personal Data we collect in the “Personal Data We Collect” section above and the sources through which we collect Personal Data in the “How We Collect Personal Data” section above. We describe the purposes for which we use and share this data in the “How We Use Personal Data” section above and the “How We Share Personal Data” section above.
• Access: You can request a copy of the personal information that we maintain about you.
• Deletion: You can ask to delete the personal information that we have collected from you.
• Opt-out of sale of your Personal Data: We do not sell Personal Data. We offer instructions on how to limit online tracking in the “Online tracking opt-outs” section of the Privacy Policy.

Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.

You are entitled to exercise the rights described above free from discrimination.

Exercising your rights. To exercise these rights, you can submit requests as follows:

• To request access to or deletion of Personal Data collected via your use of the Services, please email us at [e-mail]. 
• To learn how to opt-out of interest-based ads and other online tracking, see the “Online tracking opt-outs” section of the Privacy Policy.
• To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional Personal Data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
• Authorized agents: California residents can empower an “authorized agent” to submit requests on the resident’s behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

15. PRIVACY NOTICE FOR EUROPEAN RESIDENTS

If you are a resident of the European Economic Area, the United Kingdom, or Switzerland (collectively, “Europe”), you may have additional rights under the General Data Protection Regulation (the “GDPR”) or other European data protection legislation.

Controller and European Representatives. Maven, Inc. will be the controller of your Personal Data processed in connection with the Services. Our contact information is as follows:

Maven Pet, Inc.

Attn: Data Protection Officer

200 Continental Drive, Suite 401, Newark DE 19713

[e-mail]

Our EU representative is:

Findster Technologies, S.A.

Rua Sá da Bandeira, N651 1D

4000-437 Porto, Portugal

You may contact any one of the above representatives at: [e-mail]

Legal bases for processing. The “How We Use Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others but will depend on the type of Personal Data and the specific context in which we process it. However, the legal bases we typically rely on for each category of processing activity are set out below.

• Service delivery: Processing is necessary to perform our contract, or to take steps that you request prior to engaging our Services. Where we cannot process your Personal Data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or Services you access and request.
• Research and development: These activities constitute our legitimate interests.
• Marketing and advertising: Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
• Compliance and protection: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
• Consent: To the extent that any data that we collect is considered a special category of Personal Data subject to the GDPR, we ask for your explicit consent to process this data. You can use your account settings and tools to withdraw your consent at any time, including by unpairing your Pet Health Tracker, stopping use of a feature, removing our access to a Third-Party service, or deleting your data or your account. In addition, in some cases, such as when you direct us to share it, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, you have the right to withdraw it any time in the manner indicated at the time you give consent or as listed in our Services.

We may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention. To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data subject rights. You have certain rights with respect to your Personal Data, including:

• Access. You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging into your account.
• Rectification. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account.
• Erasure. You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of consent. If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability. You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection. You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of processing: You can ask us to restrict further processing of your Personal Data.
• Right to file a complaint. You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or European Economic Area Member State.

For more information about these rights, or to submit a request, please email [e-mail]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Processing of Personal Data in the United States. To provide the Services, we will process your Personal Data in the United States, where Maven is based. If such processing involves the transfer of Personal Data to the U.S. in a manner governed by European data protection law, the transfer will be performed pursuant to the applicable requirements of the law, such as standard contractual clauses, the individual’s consent, or other circumstances permitted by European data protection law.

Privacy Shield Guidelines. The EU-U.S. Privacy Shield Framework was set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU to the U.S. For more information about the Privacy Shield Program, and to view our certification, please visit www.privacyshield.gov.

Although Maven cannot rely on the Privacy Shield Framework to facilitate cross-border data transfers, Maven is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield before it was invalidated. The Privacy Shield Principles require that we remain potentially liable if any Third-Party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Our compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

If you have any questions about this section or our data practices generally, please contact us at [e-mail] or using the contact information above.

16. DEFINITIONS

We use some specifically defined terms in our Privacy Policy and when we communicate about our Privacy Policy. We want to be clear on how the terms we use are defined to help you better understand our policies.

Aggregated Data

CCPA

Cookies

De-Identified Data

GDPR

IP Address

Personal Data

Services

Third Parties

Maven, we, us, our

Aggregated Data

Aggregated Data is data that has undergone a process whereby raw data is gathered and expressed in a summary form for statistical analysis. Raw data can be aggregated over a given time period, across individuals, or both, to provide statistics such as average, minimum, maximum, sum, and count. After the data is aggregated, analysis can be performed to gain insights about particular data sets. When data is aggregated across a number of individuals, the resulting aggregation is considered anonymized such that it is no longer Personal Data. See our Privacy Policy here for more information on how we use Aggregated Data.

CCPA

The California Consumer Privacy Act, or CCPA, is a state law that provides California consumers with robust data privacy rights. These rights include the right to know, the right to delete, and the right to opt-out of “sale” of personal information that businesses collect, as well as additional protections for minors. A “sale” under the CCPA is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or to a third party for monetary or other valuable consideration.” See our Privacy Policy here for more details on the information we may share with others.

Cookies

Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data specific to a particular user and website, and can be accessed either by the web server or the user computer. This allows the server to deliver a page tailored to a particular user, or the page itself can contain some script which is aware of the data in the cookie and is therefore able to carry information from one visit to the website (or related site) to the next. See our Privacy Policy here to learn about cookies and how they are used on our websites.

De-Identified Data

De-Identified Data is data where all the personally identifiable information has been removed, rendering the data anonymous by stripping out information that would allow an individual’s identity to be determined from the remaining data. Data is “de-identified” to protect the privacy and identity of individuals associated with the data. De-identified Data is no longer Personal Data. See our Privacy Policy here for more information on how we use De-identified Data.

GDPR

The General Data Protection Regulation, or GDPR, is a data privacy and security regulation under European law that sets guidelines for the collection and processing of personal information from individuals who live in the European Economic Area, Switzerland and United Kingdom (collectively, “Europe” or “European”). The GDPR provides data protection rights to European residents and applies to any organization that offers goods or services to individuals in Europe, even if that organization is not based in Europe. See our Privacy Policy here for more information on the data rights available to European residents.

IP Address

An IP Address is a unique address that identifies a device on the internet or a local network. It allows a system to be recognized by other systems connected via the internet protocol. An IP Address may be considered Personal Data and is at times used by advertisers to serve interest-based ads. See our Privacy Policy here for details on how we share Personal Data.

Personal Data

Personal Data is any data that identifies or relates to you as a particular individual, including information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. See our Privacy Policy here for an outline of the ways in which we use, collect, and share Personal Data.

Services

Services means, collectively, our websites and mobile apps, any software embedded within the Pet Health Tracker, and any features, content, or applications offered, from time to time, by Maven in connection therewith.

Third Parties

Third Parties in the context of the relationship between Maven, Maven Members (our end users), and third parties are entities or businesses involved in an arrangement, contract, deal, or transaction but are not one of the principals (i.e., Maven or Maven Members). We use Third Parties to enable us to do business with our members, such as charging for transactions or storing data. Third Parties also include advertisers that serve interest-based ads to visitors to our website. See our Privacy Policy here for more information on the Third Parties that do business with Maven.

Maven, we, us, our

The terms “Maven,” “we,” “us,” or “our” mean Maven, Inc. and each of its wholly owned subsidiaries.