Privacy Policy
INTRODUCTION
Last Updated: June 29, 2021
We at the Motion Picture Association, Inc., along with our subsidiaries and affiliates listed here (collectively, the “MPA”) respect your concerns about privacy. This Privacy Policy describes the types of personal information we collect about individuals (other than MPA personnel), how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.
This Privacy Policy applies to the general practices of the MPA with respect to its processing of personal information, as well as to the MPA’s websites listed here (collectively, the “Sites”). The Policy does not apply to websites or mobile apps operated by the MPA that have separate privacy policies or notices that do not reference this Policy.
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. You can view certain country-specific information by clicking here.
If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement” by clicking here.
INFORMATION WE MAY OBTAIN
We may obtain information about you in various ways, such as through our Sites, registration or copyright infringement forms, copyright owners, or the Internet. The types of information we collect include:
- Contact information (such as name, postal and email address and telephone number);
- login credentials;
- employer ID numbers or other government-issued identification numbers in connection with economic impact analyses we perform;
- information about movies and television shows that may interest you (such as titles of trailers you search for or watch);
- information we obtain in connection with a career opportunity at MPA, such as contact details, information in your application and resume, and details about your current employment; and
- other personal information in content you provide to us, such as through emails you send us.
Content Protection
We obtain and share certain personal information to detect, investigate and deter the unauthorized copying, viewing, use, distribution and sale of protected and copyrighted motion pictures. For these purposes, we may obtain personal information from third-party information services companies, the Internet (including social media sites), public registers, law enforcement authorities and others.
We may obtain certain personal information in connection with our content protection activities that we typically do not collect in connection with our other activities covered by this Privacy Policy. To the extent permitted by applicable law, this information may include nicknames, personal characteristics (such as age, gender, marital status), family composition, bank or PayPal account details, details of suspected infringement of copyright and other protections, social media account information, employment information (including job position), education and training, images, web domains registered by an individual, automobile/motorcycle registration and license plate information, and information regarding litigation that has been submitted to courts, tribunals or administrative judicial bodies. We also, to the extent permitted by applicable law, collect personal data about any suspected or actual criminal activity that we are investigating (such as criminal copyright infringement). We can process such personal data pursuant to the 2018 Belgian Data Protection Act.
Information We Obtain By Automated Means
When you visit our Sites, open our emails or interact with MPA-related tools, widgets or plug-ins, we may collect certain information (including IP addresses) by automated means, such as cookies, web server logs, web beacons and JavaScript.
Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Sites may use cookies (such as HTTP and HTML5 cookies), as well as other types of local storage (such as browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites or other websites and online services.
In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to our Sites. We may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Site.
We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
The providers of third-party plug-ins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plug-ins and widgets. This information is subject to the privacy policies or notices of the providers of the plug-ins and widgets.
To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.
HOW WE USE THE INFORMATION WE OBTAIN
We may use the information described above to:
- provide products and services to you;
- send you promotional materials, newsletters and other communications;
- create and manage your account;
- communicate with you about, and administer your participation in, special events, film screenings, programs, promotions, offers, surveys, focus groups and market research;
- respond to your inquiries;
- perform data analyses (including market and consumer research, economic impact analyses, demographic analyses and anonymization and aggregation of personal information);
- manage career opportunities at MPA, including for recruitment purposes, employee onboarding and other HR purposes;
- operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions);
- protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other criminal activity; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms of Use.
In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customizing our users’ visits to our Sites, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (iii) managing our Sites and other aspects of our business.
We also may use the information in other ways for which we provide specific notice at the time of collection, and obtain consent to the extent required by law.
Interest-Based Advertising
If you are a U.S. resident, we may collect information on our websites about your online activities to provide you with advertising about products and services tailored to your interests. This section of our Privacy Policy provides details and explains how to exercise your choices.
You may see our ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
To learn how to opt out of ad network interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com/. Our Sites are not designed to respond to “do not track” signals from browsers.
INFORMATION WE SHARE
We do not disclose personal information we obtain about you, except as described in this Privacy Policy. We may share your personal information with the entities listed in Appendix B, and/or with their respective affiliates or subsidiaries. We also may share personal information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include web hosting providers, analytics services, email list management providers, registrars, registries, ad networks, payment processors, online platforms, content protection organizations, office services providers, accountants and law firms.
We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets.
Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and the MPA is not responsible for those providers’ information practices.
YOUR RIGHTS AND CHOICES
We offer you certain choices in connection with the personal information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the “How To Contact Us” section of this Privacy Policy. To the extent provided by applicable law, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by applicable law, you may withdraw any consent you previously provided to us or object to the processing of your personal information, and we will apply your preferences going forward.
DATA TRANSFERS
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the United States), we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
CHILDREN’S PRIVACY
Our Sites are not directed to children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen on our Sites.
LINKS TO OTHER WEBSITES AND APPS
Our Sites may provide links to other websites and apps for your convenience and information. These websites and apps may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.
UPDATES TO OUR PRIVACY POLICY
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on www.motionpictures.org and our other Sites and indicate at the top of the Policy when it was most recently updated. To the extent required by applicable law, we will obtain consent prior to updating this Privacy Policy.
If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at [email protected]. You also may write to:
Motion Picture Association, Inc.
Attention: Privacy
15301 Ventura Boulevard, Building E
Sherman Oaks, California 91403
For purposes of our Privacy Policy, below are country-specific contact details for the relevant local MPA entities. References in the Privacy Policy and all country-specific addenda to “we,” “us,” “our” and “MPA” are references to all of the entities below, which are responsible for the processing of your personal information.
| Country | MPA Entity |
| Australia | Australia Screen Association Attention: Privacy Fox Studio Australia 74 38 Driver Avenue, Moore Park NSW 2021, Australia |
| Belgium | Motion Picture Association Attention: Privacy Avenue des Arts 46 B-1000 Brussels Belgium |
| Brazil | Motion Picture Association – America Latina Attention: Privacy Av Das Nações Unidas, 8501, 17º Andar, Sala 1745 Pinheiros, São Paulo 05425-070, SP |
| Canada | Motion Picture Association – Canada Attention: Privacy 20 Eglinton Avenue West, Suite 1004 Toronto, ON M4R 1K8 |
| China | Motion Picture Association B7-2, 9 Guanghua Road Chaoyang District 100020 Beijing China |
| Hong Kong | Motion Picture Association Attention: Privacy Units 3805-6, 38/F 118 Connaught Road West Hong Kong |
| Japan | Japan and International Motion Picture Copyright Association Attention: Privacy Nihon Seimei Ichibancho Building 6F, 23-3, Inchiben-Cho Chiyoda-Ku, Tokyo, 102-0082 Japan |
| Mexico | Motion Picture Association Attention: Privacy Patriotismo #229, 8th Floor Office 305 Col. San Pedro de los Pinos 03800 Benito Juárez, Ciudad de México, D.F. |
| Singapore | Motion Picture Association – International Attention: Data Protection Officer #04-07 Central Mall No. 1 Magazine Road Singapore 059567 |
| South Korea | MPA Korea, Ltd. 220, 34 Sajikro 8-gil, Jongro-gu, Seoul Korea 03174 |
| United States | Motion Picture Association, Inc. Attention: Privacy 15301 Ventura Boulevard, Building E Sherman Oaks, California 91403 USA |
- Walt Disney Studios Motion Pictures
- Paramount Pictures Corporation
- Sony Pictures Entertainment Inc.
- Universal City Studios LLC
- Warner Bros. Entertainment Inc.
- Amazon Studios LLC
- Netflix Studios, LLC
- https://www.mpa-canada.org
- https://www.mpa-apac.org
- https://www.mpa-americalatina.org
- https://www.alliance4creativity.com
Australia Addendum
If you are a resident of Australia, the following Australia-specific provisions (as required under the Privacy Act 1988 (Cth), (“Privacy Act”) apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- We will only collect sensitive information with your consent. The term “sensitive information” has the meaning found in the Privacy Act.
- We may use and disclose your personal information where permitted by law to do so.
- You may be required to provide personal information to obtain certain products or services we offer. If you do not submit your personal information, we may not be able to provide you with certain products or services.
- You are entitled to seek access to the personal information we hold about you and seek the correction of such information. There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access. We will respond to all requests for access and/or correction within a reasonable time.
- We may disclose your personal information globally to locations outside of Australia.
- To file a complaint about an alleged breach of the Privacy Act 1988, please email us at [email protected] or write to us at the Australian address listed here. Where appropriate, we will attempt to confirm your understanding of the conduct related to your complaint and your expectations regarding the outcome of your complaint. We will inform you whether we will conduct an investigation into your complaint. If we do conduct an investigation, we also will provide contact details of the investigating officer and the estimated completion date of the investigation. After we have completed our investigation, we will advise you of the outcome and allow you to submit a response to our conclusions. If you are unsatisfied with the outcome, we will advise you of additional options for resolution.
- This policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, or an employee record held by us relating to the employee, in accordance with the Privacy Act.
Brazil Addendum
If you are a resident of Brazil, the following Brazil-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- Our Sites are not directed to children or teenagers under the age of 18 and we do not knowingly collect personal information from children or teenagers under the age of 18 on our Sites.
Canada Addendum
If you are a resident of Canada, the following Canada-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- We will not use your personal information for marketing purposes, or provide your personal information to third parties for marketing purposes, without your prior consent.
- We and our service providers also may disclose your personal information (i) if we are required or permitted to do so by applicable law or legal process, and (ii) to Canadian, U.S. or other foreign law enforcement authorities, courts and other government officials based on lawful disclosure requests.
- To access, update or correct inaccuracies in your personal information or if you have a question or complaint about the manner in which we or our service providers treat your personal information, please contact us as described above.
China Addendum
If you are a resident of China, the following China-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- You may be required to provide personal information to obtain certain products or services we offer. If you do not submit your personal information, we may not be able to provide you with certain products or services.
- With your explicit consent, we may use your personal information to send you direct marketing communications. You may withdraw your consent at any time by contacting us as indicated above.
- We will only collect your personal information for purposes that are directly related to our business activities and the provision of our products and services.
- If you have a complaint regarding our privacy practices, or would like to make a request regarding your personal information, please contact us as described above. Upon receipt of a complaint, we will endeavor to respond within 15 days.
European Economic Area Addendum
If you are located in the European Economic Area (the “EEA”), the following EEA-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- We rely on the following legal bases under applicable law toprocess your personal information:
- If you have consented to such processing;
- Where it is necessary for the performance of a contract to which you are party or in order to take steps prior to entering into such a contract;
- Where it is necessary to comply with a legal obligation to which we are subject; or
- Where it is necessary for the purposes of our legitimate interest, such as to prevent, identify and protect against fraud, copyright infringement, unauthorized use and distribution of protected content and other criminal activity. We have balanced our legitimate interests against your data protection rights. You can contact us as described in the “How to contact us” section above if you would like more information on how we balance our legitimate interests.
- Some of the data recipients identified in the Privacy Policy are located outside the EEA, including injurisdictions that have not been recognized by the European Commission as providing an adequate level of data protection. In particular, we share your personal information with affiliates and subsidiaries, and potentially with service providers that process personal information on our behalf, located in the following countries: Australia, Brazil, Canada, China, Hong Kong, Japan, Mexico, Singapore, and South Korea. In addition, your personal information may be transferred to other countries where we carry out content protection activities. The countries to which we transfer personal data will depend on where the particular infringer(s) reside and the country where we need to take action. As these countries may not offer the same level of protection as the countries within the EEA, we ensure that appropriate safeguards aimed at ensuring such a level of data protection are in place as required by applicable law, including by selecting service providers that are certified to the EU-U.S. Privacy Shield framework for which the European Commission has issued an Adequacy Decision pursuant to article 45 of the GDPR, or executing appropriate data transfer agreements with our service providers. You may obtain more information about the location of the recipients with whom we share your personal information and request a copy of the safeguards we have put in place by contacting us as indicated in the “How to Contact Us” section above.
- Under EU data protection law, you have a number of rights with respect to the personal information we process about you, including:
- The right to object, at any time, to the processing of your personal data which is based on the legitimate interest legal basis.
- Where we process your personal information for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing.
- You also have the right to request (i) access to the personal information that we process about you, (ii) to have your personal information corrected or erased, (iii) to restrict the processing of your personal information, and (iv) to receive your personal information that you have provided to us in a structured, commonly-used and machine readable format, and to transmit the data to another controller without hindrance from us.
- Where we have obtained your consent for the processing of your personal information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has happened based on your consent prior to the withdrawal.
- To exercise these rights or withdraw consent, please contact us using the contact details set out in the “How To Contact Us” section, above.
- You also have the right to lodge a complaint with a data protection supervisory authority.
- Your personal information will generally be retained for as long as is necessary for the purposes set out in this Privacy Policy. We delete or anonymize the personal information we obtain in connection with our content protection activities within an average of 5 years after the date of collection to help avoid unnecessary investigations of the same individuals. Information we obtain by automated means is typically stored no longer than 1 year. In exceptional cases personal information may need to be maintained for a longer period (e.g., in case of pending litigation).
Hong Kong Addendum
If you are a resident of Hong Kong, the following Hong Kong-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- You may be required to provide personal information to obtain certain products or services we offer. If you do not submit your personal information, we may not be able to provide you with certain products or services.
- To exercise your right to access or correct personal information we maintain about you, please contact us as described above.
- With your consent, we may use the personal information described in the “Information We Obtain” section of this Privacy Policy to send you promotional materials, newsletters and other direct marketing communications in connection with our products and services. We will not use your personal information for direct marketing purposes without your consent. You may withdraw such consent at any time by contacting us as indicated above.
- By entering information on our Sites, contacting us, or otherwise providing us with information about yourself, you voluntarily and expressly consent to our processing of your personal information as described in this Privacy Policy, and for all directly related purposes described in the “How We Use The Information We Obtain” section of this Privacy Policy (other than direct marketing purposes).
- We may transfer your personal information to third parties located within or outside of Hong Kong (including our affiliates and subsidiaries listed in Appendix A, and the entities listed in Appendix B and their affiliates) for the purposes indicated in the “How We Use The Information We Obtain” section of this Privacy Policy. We will take reasonably necessary steps and exercise appropriate due diligence to help ensure that personal information processed outside of Hong Kong by MPA and our affiliates, subsidiaries and members are treated securely and in accordance with this Privacy Policy and in compliance with the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong).
Japan Addendum
If you are a resident of Japan, the following Japan-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- The MPA, its affiliates listed in Appendix A, and the entities listed in Appendix B, and/or their respective affiliates or subsidiaries, may jointly use the personal information listed in the “Information We Obtain” section for the purposes described in this Privacy Policy. Japan and International Motion Picture Copyright Association is responsible for the management of your personal information that is jointly used. To the extent this joint use of personal information takes place outside of Japan, our affiliates and the motion picture studio members that are located outside of Japan will comply with this Privacy Policy and applicable obligations under Articles 15 to 35 of the Act on the Protection of Personal Information (the “Act”) to meet the requirement of legitimate international joint use under Article 24 of the Act.
Mexico Addendum
If you are a resident of Mexico, the following Mexico-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- If you think that any of the uses of personal information described in the “How We Use the Information We Obtain” section of this Privacy Policy do not originate from, or are not necessary for, your relationship with the MPA, you can object to our processing of your personal information for these particular uses. To object to our processing, please email us at [email protected] and include the specific uses of your personal information to which you object. You also may write to us at:
Motion Picture Association
Attention: Privacy
Patriotismo #229, 8th Floor Office 305
Col. San Pedro de los Pinos 03800
Benito Juárez, Ciudad de México, D.F.
- If you do not want your information shared with the entities listed in Appendix B, and/or with their respective affiliates or subsidiaries, please email us at [email protected].
- You may withdraw any previously provided consent and exercise your rights of access, rectification, cancellation and opposition (“ARCO Rights”) regarding our processing of your personal information by emailing us at [email protected]. Your request must contain at a minimum: (i) your full name, address and contact information so we can respond to your request; (ii) information that helps us validate your identity; and (iii) a clear and precise description of both (a) the reasons you are exercising your ARCO Rights, and (b) the specific modifications you wish to make to your personal information and/or the limitations you wish to place on our use of your personal information. We will inform you of a decision regarding your request within 20 business days from the date of receipt of your request. If your request is granted, it will be made effective within 15 business days of our response. With respect to a request for access to your personal information, we will send you a response by email, postal mail or other means of communication.
- We will inform you of a decision regarding your request within 20 business days from the date of receipt of your request. If your request is granted, it will be made effective within 15 business days of our response. With respect to a request for access to your personal information, we will send you a response by email, postal mail or other means of communication.
- Our response to your request to exercise your ARCO Rights will be free of charge. You will be responsible for the costs associated with sending or duplicating documents (e.g., in photocopies or other formats) if necessary, about which we will inform you.
- If you are not satisfied with our response, you may initiate the rights protection procedure before the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (“INAI”) at Insurgentes Sur No. 3211, Insurgentes Cuiculco, Delegración Coyoacán, C.P. 04530. That procedure should be brought by you within the 15 business days from the date on which our resolution to your request was communicated to you. In the event that you do not receive a response from us, you may initiate the rights protection procedure before the INAI after the deadline for our response has passed. In this case, it will be sufficient for you to accompany your data protection request with a document proving the date on which you filed the request for the exercise of your ARCO Rights.
- You may view a complete version of our data privacy notice here, in English and Spanish, respectively.
Singapore Addendum
If your personal information is processed in Singapore, the following Singapore-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- You may be required to provide personal information to obtain certain products or services we offer. If you do not submit your personal information, we may not be able to provide you with certain products or services.
- By submitting information on our Sites, contacting us, or otherwise providing us with your personal information, you consent to our collection, use, and disclosure of your personal information for the purposes described in this Privacy Policy.
- If you have any questions or would like to contact our data protection officer, please email us at [email protected].
South Korea Addendum
If you are a resident of South Korea, the following South Korea-specific provisions apply to our processing of your personal information in addition to or in lieu of the relevant sections of the Privacy Policy:
- The MPA may share your personal information with its affiliates listed in Appendix A, and the entities listed in Appendix B, and/or their respective affiliates or subsidiaries.
- We may share your personal information with our service providers who perform services on our behalf, based on our instructions, for purposes of content protection, as further described in the Privacy Policy above.
- We may transfer your personal information to recipients in countries other than the county in which the information was originally collected, for purposes of content protection, as further described in the Privacy Policy above.
- We will retain your personal information for the time period necessary to achieve the purposes outlined in this Privacy Policy, taking into account applicable records retention requirements. We will destroy, or render unreadable or indecipherable, personal information that is no longer necessary for its intended use, unless we are prohibited by applicable law from doing so.
- MPA is required to retain your personal information for the periods prescribed under applicable law, including the Act on the Consumer Protection in Electronic Commerce, the Electronic Financial Transactions Act, and the Protection of Communications Secrets Act:
- Act on the Consumer Protection in Electronic Commerce
- Records on subscription or withdrawal of subscription: Store for five (5) years
- Records on payment settlements and supply of goods: Store for five (5) years
- Records on customer complaints or dispute settlements: Store for three (3) years
- Electronic Financial Transactions Act
- Records on electronic finance: Store for five (5) years
- Protection of Communications Secrets Act
- Records on sign-in: Store for three (3) months
You may exercise your rights under this Privacy Policy through your legal representative or authorized agent.
- Act on the Consumer Protection in Electronic Commerce
- Our Sites are not directed to children under the age of fourteen and we do not knowingly collect personal information from children under the age of fourteen on our Sites.
California Consumer Privacy Statement
Effective: January 1, 2023
This California Consumer Privacy Statement supplements the Privacy Policy and applies solely to California consumers. This Statement does not apply to MPA personnel or job applicants.
This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018, the California Privacy Rights Act of 2020, and/or its implementing regulations (together, the “CCPA”).
- Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, Social Security number, driver’s license number, passport number, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
- Employment Information: professional or employment-related information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:
| Purposes | Categories of Personal Information |
| Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services |
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| Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance |
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| Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction |
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| Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity |
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| Debugging to identify and repair errors that impair existing intended functionality |
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| Undertaking internal research for technological development and demonstration |
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| Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us |
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- Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.
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- Sources of Personal Information
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We may have obtained personal information about you from various sources, as described below.
| Categories of Sources of Data Collection | Categories of Personal Information |
| Directly from you, such as information you may provide to us via our websites
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| From your devices, such as your desktop computer, laptop computer(s), or mobile device(s) when you visit our websites |
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| Vendors who provide services on our behalf |
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| Social networks and other online sources |
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| Online advertising services |
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- Sharing of Personal Information
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We may have shared your personal information with certain categories of third parties, as described below.
| Categories of Third Parties | Categories of Personal Information |
| Our affiliates |
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| Vendors who provide services on our behalf |
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| Professional services organizations, such as auditors and law firms |
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| Online advertising services |
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| Government entities |
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| Advertising networks |
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| Data analytics providers |
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- Sale of Personal Information
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We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Sites in exchange for non-monetary consideration. We share the categories of personal information listed below for online advertising purposes as described in our Privacy Policy. You have the right to opt out of this disclosure of your information, as detailed below.
During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:
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- Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, and other similar identifiers
- Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.
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- Disclosure of Personal Information for a Business Purpose
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We may have disclosed to third parties for a business purpose the following categories of personal information:
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- Identifiers
- Online Activity
- Geolocation Data
- Inferences
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- California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Correction: You have the right to request correction of inaccurate information we have collected about you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
Sensitive Personal Information: You have the right to request limitations of the use of certain sensitive personal information beyond specified, disclosed purposes. MPA does not use or disclose sensitive personal information for purposes other than those described above.
Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
How to Submit a Request. To submit a request for access, deletion, or correction, click here for our webform or call us toll-free at 877-968-3334. To submit a Shine the Light request, email us at [email protected]. To opt-out of the sale of your personal information, click here or submit a request via our webform here.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide your name, email address, and two or more of the following: mailing address, telephone number, online identifier, internet protocol address, or other similar identifiers. In addition, since we do not have consumer accounts, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact [email protected] or call us toll-free at 877-968-3334 during regular business hours (9:00am – 5:00pm Pacific Time) to request this Statement in an alternative form.