Last updated: March 7, 2024

Last Reviewed: March 7, 2024

MPL Brands NV, Inc. d/b/a Patco Brands

3960 Howard Hughes Parkway, Suite 500-6001

Las Vegas, NV 89169

 

MPL Brands NV, Inc. Detailed US Privacy Notice

 

Information for US Residents

MPL Brands NV, Inc. (the “Company” “we” “us”) collect Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”). In addition to our general Privacy Notice available at https://www.patcobrands.com/privacy-policy/, this Detailed US Privacy Notice applies to US residents (“users,” “you,” or “your”).

For the purposes of this Detailed US Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

  • Publicly available information;
  • Deidentified or aggregated data; or
  • Information otherwise excluded from the scope of US Privacy Laws.

This Privacy Notice provides the following information to US residents:

  • Categories of Personal Data we collect;
  • Purposes for which we use Personal Data;
  • Categories of Personal Data we disclose to third parties;
  • Categories of third parties to which we disclose Personal Data; and
  • How US residents can exercise their rights under US Privacy Laws:
    • The rights to access, correct, or delete Personal Data;
    • The right to obtain a portable copy of Personal Data;
    • The right to limit the use of sensitive Personal Data in certain circumstances;
    • The rights to opt out of targeted advertising, sales of Personal Data, or profiling; and
    • The right to appeal our decisions about your requests.

Categories of Non-Sensitive Personal Data

The table below outlines the non-sensitive categories of Personal Data MPL Brands NV, Inc. collects about US residents and whether and how they are disclosed to third parties.

We collect Non-Sensitive Personal Data from the following sources: 

  • Directly from our users
  • From our affiliates (“affiliates” are businesses that share common ownership with MPL Brands NV, Inc.)
  • From our business partners (“business partners” are companies that we have a commercial relationship with)
  • From our advertising partners
  • From our processors 

Category of Personal Data:

Identifiers

Examples

Identifiers may contain the following: Name, address, social security number, date of birth (age), cookie ID, IP Address, browser type, operating system, email address, phone number, social media handle, and other similar identifiers

Purpose(s) for Collection

Targeted advertising and marketing;

Website optimization and personalization;

To facilitate use of our services, including to facilitate transactions, provide support, and otherwise improve and provide our services;

Verifying identity, age and eligibility requirements;

To comply with statutory and legal obligations, security, fraud prevention, and to monitor use of services and electronic communication for unauthorized, unlawful, or inappropriate use;

To comply with law, legal process, investigations, internal policies and other requirements; 

To maintain the quality and integrity of our business operations, enforcement of internal company policies, record-keeping and financial purposes, and other similar purposes 

To debug our services and identify errors that may impair functionality;

To conduct research and development to improve our existing services, conduct internal audits and investigations, and to administer and maintain the Company’s operations; 

Obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business

Targeted Advertising

We may disclose this information with advertising partners for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors, Affiliates, and Business Partners. 

Category of Personal Data:

Personal Characteristics

Examples

Personal Characteristics may contain the following: gender and age

Purpose(s) for Collection

Targeted advertising and marketing;

To facilitate use of our websites and services, and website optimization and personalization;

To facilitate transactions, provide support, including for account creation, and otherwise improve and provide our services;

Verifying identity, age and eligibility requirements;

To monitor use of services and electronic communication for unauthorized, unlawful, or inappropriate use and for security and fraud prevention purposes;

To maintain the quality and integrity of our business operations, enforcement of internal company policies, record-keeping and financial purposes, and other similar purposes 

To comply with law, legal process, investigations, internal policies and other requirements, 

To debug our services and identify errors that may impair functionality;

To conduct research and development to improve our existing services, conduct internal audits and investigations, and to administer and maintain the Company’s operations, including for safety purposes; 

To obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business

Targeted Advertising

We may disclose this information with advertising partners for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors, Affiliates, and Business Partners. 

Category of Personal Data:

Internet/Electronic Activity

Examples

Internet/Electronic Activity may contain the following: browsing history, click through activity and device ID

Purpose(s) for Collection

Targeted advertising and marketing and website optimization and personalization;

To facilitate use of our websites and services, including for account creation, and to facilitate transactions and provide support;

To verify eligibility, and for security and fraud prevention purposes and otherwise improve and provide our services;

To monitor use of services and electronic communication for unauthorized, unlawful, or inappropriate use;

To maintain the quality and integrity of our business operations, enforcement of internal company policies, record-keeping and financial purposes, and other similar purposes 

To comply with law, legal process, investigations, internal policies and other requirements;

To debug our services and identify errors that may impair functionality;

To conduct research and development to improve our existing services, conduct internal audits and investigations, and to administer and maintain the Company’s operations;

To obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business

Targeted Advertising

We may disclose this information with advertising partners for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors, Affiliates, and Business Partners. 

Category of Personal Data:

Imprecise Geolocational Data

Examples

Imprecise Geolocational Data may contain the following: Users in a general geographic area that clicked on an ad or visited our website

Purpose(s) for Collection

Targeted advertising and marketing and website optimization and personalization;

To facilitate use of our websites and services, including for remembering your response to age gate, and to facilitate transactions and provide support;

To verify eligibility, and for security and fraud prevention purposes and otherwise improve and provide our services;

To monitor use of services and electronic communication for unauthorized, unlawful, or inappropriate use;

To comply with law, legal process, investigations, internal policies and other requirements;

To debug our services and identify errors that may impair functionality;

To conduct research and development to improve our existing services, conduct internal audits and investigations, and to administer and maintain the Company’s operations, 

To obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business

Targeted Advertising

We may disclose this information with advertising partners for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors, Affiliates, and Business Partners. 

Category of Personal Data:

Commercial Data

Examples

Commercial Data may contain the following: history and records of transactions between you and the Company, history and records of products purchased, and other similar information

Purpose(s) for Collection

To facilitate transactions, provide support, and to facilitate and improve our services and business operations;

To comply with legal obligations, and for security purposes; 

To detect, prevent and protect against fraud or other illegal, deceptive or malicious activities;

To maintain the quality and integrity of our business operations, enforcement of internal company policies, record-keeping and financial purposes, and other similar purposes; 

Targeted advertising and marketing, and website optimization and personalization;

Verify eligibility and identity, to facilitate transactions, and provide support;

To comply with legal obligations, security and fraud prevention and otherwise improve and provide our services;

To monitor use of services and electronic communication for unauthorized, unlawful, or inappropriate use, comply with law, legal process, investigations, internal policies and other requirements;

To debug our services and identify errors that may impair functionality;

To conduct research and development to improve our existing services;

To conduct internal audits and investigations, and to administer and maintain the Company’s operations, including for safety purposes; 

To obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors and Affiliates. 

Category of Personal Data:

Professional Data

Examples

Professional Data may contain the following: professional and employment history, salary and compensation

Purpose(s) for Collection

To facilitate use of our websites and services, website optimization and personalization and otherwise improve and provide our services; 

To verify eligibility, account creation, facilitate transactions, provide support;

To comply with legal obligations, legal process, investigations, internal policies and other requirements;

For security and fraud prevention;

Verifying identity, age and eligibility requirements; 

Monitor use of services and electronic communication for unauthorized, unlawful, or inappropriate use; 

To conduct research and development to improve our existing services, and to conduct internal audits and investigations;

To obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors and Affiliates. 

Categories of Sensitive Personal Data

The table below outlines the categories of Sensitive Personal Data MPL Brands NV, Inc. collects about US residents and whether they are disclosed to third parties. MPL Brands NV, Inc. obtains affirmative consent from US residents to process Sensitive Personal Data to the extent required by US Privacy Laws. 

We collect Sensitive Personal Data from the following sources: 

  • Directly from our users
  • From our affiliates (“affiliates” are businesses that share common ownership with MPL Brands NV, Inc.)
  • From our business partners (“business partners” are companies that we have a pre-existing commercial relationship with)
  • From our advertising partners

Category of Sensitive Personal Data:

Government ID Data

Examples

Government ID Data may contain the following: Social Security Number, Driver’s License, State Identification Card, Passport Number or similar government ID

Purpose(s) for Collection

Verifying identity, age and eligibility requirements; 

Complying with statutory and other legal obligations;

Security and fraud prevention and for compliance verification;

To administer and maintain the Company’s records, operations and services and to facilitate transactions and other operations; 

To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted information; 

To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions; 

To perform services on behalf of the business; 

Obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors, Affiliates, and Business Partners. 

Category of Sensitive Personal Data:

Sensitive Category Data

Examples

Sensitive Category Data may contain the following: Citizenship and immigration status

Purpose(s) for Collection

Verifying identity and eligibility requirements and to facilitate transactions and other operations; 

Complying with statutory and other legal obligations; 

Security and fraud prevention, and for compliance verification; 

To administer and maintain the Company’s records, operations and services;

To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted information; 

To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions; 

To improve, upgrade, or enhance our services;

Obtain legal advice and establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 

Otherwise for legal, security and compliance purposes, or managing our business.

Targeted Advertising

We do not engage in targeted advertising or disclose this information for targeted advertising purposes

Sale

This information is not sold to third parties

Other Disclosures

This information may be disclosed to Processors, Affiliates, and Business Partners. 

Retention Periods

We retain the information we collect about you for as long as the legal or business purpose for which we originally collected it exists, or until you request deletion (if applicable) of your information. However, information may be retained longer if required for compliance and legal purposes or if required by law, after which it is retained only to the extent required for purposes of preventing fraud and security purposes. 

Use of Personal Data

We use Personal Data for the purposes described in our general Privacy Notice (see https://www.patcobrands.com/privacy-policy/). Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.

Disclosing Personal Data

We share Personal Data with the following categories of third parties:

  • Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes.
  • Affiliates: We may disclose your information to our affiliates, subsidiaries, and representatives as part of providing our services. 
  • Our Analytics and Advertising Partners: We use analytics services to collect and process certain data and to provide you with relevant advertising. These services may also collect information about your use of certain other websites, apps, and online resources. 
  • Our Business Partners: We may disclose relevant personal data to our business partners to provide you with exclusive offers for products and services that may interest you. 

We disclose Personal Data for the following purposes:

  • To enable our Processors, Affiliates, Analytics and Advertising Partners, and Business Partners to provide services and facilitate transactions on our behalf; 
  • To comply with statutory and other legal obligations, and to facilitate and administer transactions, investigations, and ensure compliance with internal, external and legal policies;
  • Administer and maintain the Company’s operations, including for safety, security and fraud prevention purposes, and to conduct research, audits and investigations, to debug our services and identify errors that may impair functionality, and to resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions; 
  • To ensure the physical safety of natural persons;
  • To obtain legal advice and for establishing, exercising or defending legal rights, acting on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; or 
  • Otherwise for legal, security and compliance purposes, or for purposes of managing or maintaining our business and operations, and performing services on behalf of our business. This includes to verifying or maintaining the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by our business, or to enhance a service or product that is owned, manufactured by, manufactured for, or controlled by our business, and/or prevent, detect, and investigate cybersecurity incidents or data breaches that compromise the availability, authenticity, integrity, or confidentiality of any of our products, services, data or other information maintained by our business. 

We do not sell Personal Data to anyone.

Exercising Your Personal Data Rights

US residents have the following rights under US Privacy Laws:

  • The rights to access, correct, or delete Personal Data;
  • The right to obtain a portable copy of Personal Data; 
  • The right to limit the use of Sensitive Personal Data in certain circumstances;
  • The rights to opt out of targeted advertising, sales of personal data, or profiling; 
  • The right not to receive discriminatory treatment for exercising your privacy rights; and
  • The right to appeal our decisions about your requests if you disagree with them.

If you are a US resident, you can submit a request to exercise your personal data rights under US Privacy Laws by sending an email to privacy@patcobrands.com with the subject line “Privacy Rights Request”, or calling our toll-free number at 855-726-2460. To submit an opt-out request, you may do so by visiting our Online Portal, by sending an email to privacy@patcobrands.com with the subject line “Privacy Rights Request”, or by calling our toll-free number at 855-726-2460.

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by sending an email to your email address on file with a link to click, or by matching two or more data points provided by you to data points maintained by the Company and requiring a signed declaration under penalty of perjury verifying your identity. We may ask you for additional information as part of this process, including the phone number, home address, social security number or other identifying information. We may also require you to sign a declaration under penalty of perjury verifying your identity. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept or process rights requests submitted through other means.

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.

Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising

US privacy laws give US residents the right to direct a business that “sells” or “shares” their Personal Information to stop selling and/or sharing their Personal Information at any time. As used here, “selling” means exchanging Personal Data with a third party for money or anything of value, and “sharing” means disclosing Personal Data to a third party for use in conducting “cross-context behavioral advertising,” also referred to as “targeted advertising.” An example of targeted advertising is displaying advertisements to a person where the advertisement is selected based on Personal Data obtained from their activities over time and across non-affiliated websites or applications to predict their preferences or interests. In certain situations and as detailed above, we share for targeted advertising Personal Data with third parties. You can opt out of the sharing of your Personal Data by do so by visiting our Online Portal, by sending an email to privacy@patcobrands.com with the subject line “Privacy Rights Request”, or by calling our toll-free number at 855-726-2460.

Notice of Right to Limit the Use of Sensitive Personal Information

You have the right to limit some uses of Sensitive Personal Data. In general, you may direct companies not to use Sensitive Personal Data except as necessary to provide goods or services you have requested or other exempt purposes. 

However, we only use Sensitive Personal Data for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes are specified in California Code of Regulations, Title 11, Section 7027(m). 

Children’s Data

We do not knowingly collect or use the Personal Information of children under 16. If you believe that we have collected the Personal Information of a child under 16, please contact us at privacy@patcobrands.com.

Authorized Agent Requests

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above in the section titled Exercising Your Personal Data Rights. We may require verification of your authorized agent’s authority in addition to the information we require for verification of your identity.

Contact Us

If you have any questions or concerns regarding this Detailed US Privacy Notice, contact us at privacy@patcobrands.com.

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