Privacy Policy

Introduction

My Favorite Things, Inc. d/b/a Mavely (“Mavely,” “Company,” “we” or “us”) is committed to protecting your privacy. The following policy (“Privacy Policy”) describes our practices for collecting, using, maintaining, and disclosing information that we collect from you or that you provide to us when you visit our website (our “Site”), use our mobile application (“App”), or use any other products and services made available by us (collectively with the Site, the “Services”).

We ask that you read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. The use of information collected through our Services will be limited to the purposes described under this Privacy Policy and our Terms of Use (or other relevant customer contracts). By accessing or using the Services, you agree to this Privacy Policy. Please be aware that if you are using the Services on behalf of an entity, you are agreeing to this Privacy Policy for that entity and are representing to us that you have the authority to do so (in which case “you” will refer to that entity). If you do not agree with our policies and practices, your choice is not to use the Services.

This Privacy Policy may change from time to time. If we make any changes, we will post the changes on this page and indicate at the top of this page the date the policy was last revised. We will also notify you of any material changes either through a pop-up notice, email or through other reasonable means. Any such changes are effective immediately when we post them, and apply to all access to and use of the Services thereafter. Your continued use of the Services after the date any such changes become effective constitutes your acceptance of the new policy.

Information We Collect and How We Collect Information

Information You Provide.

We may collect information you provide directly via the Services. We may ask you for some or all of the following types of information when you register with our Services, submit comments and other content, order products, or directly contact us with questions or feedback:

Your name
Your telephone number
Your address
Your email address
Your company name
Your company address

The information you provide may include Personal Information. “Personal Information” is information that identifies you personally (whether alone or in combination).

If you purchase our Services, you may be required to provide financial information, such as your credit card or bank account number, to a third-party payment processor. We do not collect or store such financial information and we are not responsible for the collection or storage of such information by third parties. We will, however, have access to certain information associated with your account should you purchase the Services, including the amount and date of the purchase.

Information We Automatically Collect

We may also collect certain information automatically when you visit the Services, including:

Your browser type and operating system
Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area
Geolocation information
Other unique identifiers, including mobile device identification numbers
Sites you visited before and after visiting the Services
Pages you view and links you click on within the Services
Information collected through cookies, web beacons, and other technologies
Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded
Standard Server Log Information

We collect the above information in a variety of ways, including by using “pixel tags,” “web beacons,” and “cookies.”

Cookies are small bits of information that are stored by your computer’s browser. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Services.
Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

Third-Party Information Collection

We may allow third parties to place and read their own cookies, web beacons, and other technologies to collect information through the Services. For example, our third-party service providers may use these technologies to collect information (i) that helps us with traffic measurement, research, and analytics, and (ii) that is used to serve advertisements on our Services and across the Internet tailored to your apparent interests.

The information collected and stored by third parties remains subject to their policies and practices. We do not control these third parties’ tracking technologies or how they may be used.

We currently use the services of the following third-party vendors, who may collect your information. You can click on the hyperlinks below to view their privacy policies.

How We Use Your Information

We may use information that we collect about you or that you provide to us, including Personal Information, to measure usage of the Services, to analyze the effectiveness of our Services, to conduct research, to improve and enhance functionality of the Services, to provide support for the Services and respond to requests and inquiries, to provide you with notices, such as updates or changes that we may make to the Services, and to market and advertise the Services, including through promotional e-mail messages, directly or in partnership with other parties, and by displaying our advertisements on other websites that you visit or use. We may also use this information to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising).

We may from time to time aggregate information in certain data analysis, reports, or other interpretations of trends for both internal and external purposes.

Choices About How We Collect, Use and Disclose Your Information

We strive to provide you with choices regarding our collection, use and disclosure of the information you provide to us. The mechanisms listed below aim to provide you with control over such collection, use and disclosure:

Marketing Communications. If you do not want us to send you marketing or promotional communications, you can opt-out by clicking the “unsubscribe” link in any such promotional emails, checking the relevant box located on the form on which we collect your data or email us at hello@joinmavely.com.
Cookies. You have the option to accept or disable cookies at any time through your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. If you choose to disable your cookies, your user experience may be limited.
Google Analytics. You can opt out of tracking by Google Analytics by using Google’s Ads Settings or going to https://tools.google.com/dlpage/gaoptout/ . You may also opt out of Google marketing products, but please note that this does not opt you out of being served generic ads.
Mobile Analytics. If you are using our App, we use Mobile Device IDs, instead of cookies, to recognize you. We use the Mobile Device IDs and other mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. These Mobile Device IDs are only tracking and collecting Non-Personal Information. The software may record information such as how often you use the Services, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from.
Third-Party Advertising. If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web advertisements, you may visit the following websites: http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/ . These opt-out tools are provided by third parties. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

Disclosure of Your Information

We want you to understand when and with whom we may share the information we collect. We may disclose information that we collect through the Services with third parties as follows:

Service Providers. We may share your information with our agents and service providers that perform certain functions or services on our behalf, such as to host the Services, manage databases, host a store or other e-commerce platform, perform analyses, or conduct surveys.
Select Business Partners. We may share your information with select business partners so that they can provide you with special offers, promotional materials, advertisements and other materials that may be of interest to you. However, we are not responsible for the privacy practices of these business partners, which may use your information for their own purposes.
Other Parties When Required By Law or as Necessary to Protect the Services. We may disclose your information to third parties in order to protect the legal rights, safety, and security of Mavely and the users of our Services; enforce our Terms of Use; prevent fraud; and comply with or respond to law enforcement or a legal process or a request for cooperation by a government or other entity, whether or not legally required.
In Connection With a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
Other Parties With Your Consent. We may share information about you with other third parties when you consent to such sharing.
Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.

You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Social Networking Services

The Services may allow you to post information to various third-party services or platforms, such as social networking services like Instagram, Twitter and Facebook. You acknowledge that if you choose to use this feature, your friends, followers and subscribers on these third-party services or platforms will be able to view such activity. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data.

Links to Third-Party Sites and Services

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by Mavely. Such links do not constitute an endorsement by Mavely of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

Do Not Track Signals

Third parties may keep track of your browsing activities across third party websites. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know whether we respond to “Do Not Track” browser signals. Certain web browsers enable users to activate a “Do Not Track” signal but we do not currently respond to the “Do Not Track” signal or other similar mechanisms.

Data Retention

We strive to keep your information only as long as we need it for legitimate business purposes and as permitted by applicable legal requirements. If you close your account, we will retain certain data for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Services or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

You acknowledge that Mavely may establish general practices and limits concerning use of the Services, including without limitation the maximum period of time that data or other content will be retained by the Services and the maximum storage space that will be allotted on Mavely’s servers on your behalf. You further acknowledge that Mavely reserves the right to change these general practices and limits at any time, in its sole discretion. We will endeavor to give you notice of any such change where required by applicable law.

Accessing and Correcting Your Information

If you wish to access, update, correct or delete any Personal Information in our possession that you have previously submitted via the Services, you may log into your account and make updates. If you wish to make changes not available through your account settings, please contact us at hello@joinmavely.com.

Security

We take reasonable steps to protect the Personal Information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to us via the Internet. In the event that personal information is compromised as a breach of security, Mavely will promptly notify our customers in compliance with applicable law.

Notice to California Residents.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a calendar year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please send an email to hello@joinmavely.com.

You have the right to know whether your personal information is being sold. Your personal information is “sold” when it is provided with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the California Consumer Privacy Act of 2018 (CCPA) or other U.S. state data privacy laws. Please note a “sale” does not include when we disclose your personal information at your direction, or when otherwise permitted under law. Mavely does not sell your personal information.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided and include the email address associated with your account and a statement that you reside in California. We will make sure that the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

To request any other changes or information about our collection, use or disclosure of your information, please email us at hello@joinmavely.com .

Children Under the Age of 13

Our Services are intended for users who are 13 years of age and older. If you are under the age of 13, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child under 13, please contact us at hello@joinmavely.com.

International Users

Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. Some of these countries may not offer the same level of privacy protection as your own.

Global Privacy Notice

Introduction
At Later we are committed to the legal processing, confidentiality, and security of all personal information that we handle in connection with the provision of our social media and marketing technology and services, in accordance with all applicable laws and as described in this Privacy Notice (“Notice”).

This Notice describes the personal information that we collect, how that information is processed, and your rights and choices in relation to it.

This Notice applies where we are the entity that decides on the purposes of processing of personal information and the ways in which it is processed within our products and services, also referred to as the “data controller” or “business”. In some circumstances we may process personal information on behalf of our customers and on their instructions (e.g., where we measure and analyze end users’ interactions with their posts and campaigns). There, we act only as a “data processor”, “service provider”, or “contractor”, and, while we will assist as far as we reasonably can, you should submit any questions and requests to the customer in question, as the relevant data controller or business.

Later may change this Notice from time to time, due to changes in our business, technology, applicable laws, or any other reason. Please check this page from time to time to be informed of the latest changes.
Who We Are

The “data controller” or “business” in relation to the processing of the personal information as described in this Notice is: Mavrck LLC d.b.a. Later.

Later’s social media and marketing technology and services are provided by Mavrck LLC d.b.a. Later (operating Later Influence and Later Social Enterprise), and/or through our group companies such as MyFavoriteThings, Inc. d.b.a. Mavely (affiliate marketing services for influencers), and Victory Square Media, Inc. (Later Social and Link in Bio). In this Notice, any and all of these Later group entities are collectively referred to as “we” or “Later”.

For any question or request relating to processing of personal information, we can be contacted as set out in Section 9.
Categories of Data, Sources of Data, Purposes of the Processing, and Legal Bases for the Processing

Later is a provider of social media and influencer marketing technology and services. Most personal information we process relates to individuals acting in the context of their trade or profession, e.g., creators and influencers on social media (“Creators”) active in a professional capacity, and staff of our brand and agency customers. Some users of our services may be consumers, e.g., non-professional Creators who use Mavely services to earn commissions.

Our principal services currently comprise the following:

- Managed Campaign Services – we manage Creator marketing campaigns for brand customers, including strategy, Creator sourcing, content production, and performance reporting.

- The Later Platform – we provide a self-serve Creator marketing platform that enables our customers to independently manage campaigns, communicate with Creators, and access the Later Influencer Index (Creator database).

- Later Creator Program – we manage this program to enable individual Creators to join our Creator network to be discovered and matched with brand campaigns.

- Later Social – we provide a SaaS social media management tool for social media managers, agencies, and brands that enables scheduling, publishing, analytics, and content management across major social platforms, including our linkin.bio tools.

- Later for Creator (formerly Mavely)– we provide an affiliate marketing platform that allows brands to run performance-based affiliate campaigns, and Creators to generate shoppable SmartLinks for products from participating brands and earn commissions on resulting sales.

In order to provide our services and manage our business, we collect and/or process personal information relating to: (1) Creators; (2) our customers and potential customers; (3) visitors to our websites and social media channels, and users of our mobile applications; and (4) our other business partners. Our services and tools enable our customers to review our Creator databases, but Later does not sell personal information and is not a data broker.

In accordance with applicable laws, we may freely process and share anonymized, aggregated, or de-identified information that does not identify you or your household.

Creators

Individuals	Categories	Source	Purpose of Processing	Legal Basis	Comments
Creators engaged for managed campaigns	Name, social media account data, content classifications, demographics, email, phone, contractual/campaign information, payment data, login credentials	Directly from creator, social media platforms, analytics tools	Account creation, creator matching, campaign management, reporting, payments, support, analytics, fraud prevention, legal compliance	Legitimate interests, legal obligations, explicit consent (for sensitive data)	Data is necessary for service provision; payment details are generally handled by third-party payment providers.
Creators who sign up for Later or Mavely	Name, email, login credentials, settings, preferences, social media account data, demographics, affiliate links, payment data	Directly from creator	Account management, influencer index participation, communications, payments, subscriptions, analytics, fraud prevention	Contract performance, legitimate interests, legal obligations	Information is necessary for providing services.
Other Creators	Name/handle, social media profile data, email, content classifications	Social media platforms and third-party data providers	Discovery through Influencer Index, communications, analytics, support	Legitimate interests, legal obligations	Information is publicly available and used for service functionality.

Customers and Potential Customers

Individuals	Categories	Source	Purpose of Processing	Legal Basis	Comments
Staff of customers and potential customers	Name, employer, work address, work email, work phone, title, qualifications, business interests, campaign information, contractual information, login credentials	Directly from the individual, employer, public sources, trade shows, networking events	Service delivery, training, support, contract administration, invoicing, business development, analytics, compliance	Legitimate interests, legal obligations	Information relates primarily to professional activities.

Visitors to or websites and social media channels / App users

Individuals	Categories	Source	Purpose of Processing	Legal Basis	Comments
Website visitors, social media visitors, app users	IP address, device information, browser data, location, browsing activity, searches, contact details, feedback	Browser/device data, contact forms, inquiries submitted by users	Account access, support, marketing, analytics, service improvement	Consent where required, legitimate interests	Typical website/app processing; users can manage cookie preferences.
Subscribers to email offers and updates	Email, interests, preferences	Provided directly by subscriber	Marketing communications, product and service updates	Consent where required, legitimate interests	Preferences can be updated or communications unsubscribed from.

Other Business Partners

Individuals	Categories	Source	Purpose of Processing	Legal Basis	Comments
Commercial Contacts Data	Name, employer, work address, work email, work phone, title, qualifications, business interests, contractual information	Directly from individual, employer, trade shows, networking events, public sources	Partner support, procurement, contract management, invoicing, business development, compliance	Contract performance, legitimate interests, legal obligations	Information relates primarily to professional activities.

4. Recipients and International Transfers of Personal information

We may disclose personal information to the following categories of third parties:

Our group companies involved with the provision of our products and services;
Our customers as part of our services;
Social media platforms, in order to provide integrations and features you request;
In the event of merger, reorganization, reincorporation, recapitalization, acquisition, or any form of sale of some or all of our assets, personal information held by us may be shared with the buyer.
Other organizations that provide services in support of our services and business such as:
providers of IT-related services (e.g., cloud hosting and storage, database management, search engine, CRM services, business tools, ID and authentication, IT infrastructure and management, trouble ticketing, customer support and communications);
data analytics and reporting providers;
security, fraud prevention, and risk auditing services;
website development, hosting, management, and maintenance providers;
AI and machine learning providers (but we do not use AI to take decisions with legal or other significant impacts and never allow third party AI systems to use personal information for training models or algorithms – please see separate Section below);
advertising, marketing, and communications service providers (e.g., email and lead management, customer satisfaction surveys); or
tax processing, accounting, legal, insurance, or payment service providers;

These organizations process personal information and other data on Later’s behalf, but our contracts with them oblige them to meet data protection standards as strict as those that apply to us, and not to use your personal information for any other purpose.

We store personal information in the USA. Your personal information may also be processed on our behalf in any country where we operate or have engaged data processors, e.g., for data hosting or analysis.

Where such disclosures result in a transfer of personal information to places outside the EU/EEA, the UK, Switzerland, or other countries that are officially regarded by EU or UK authorities as having adequate data protection laws, then this will be done only on the basis of legal safeguards aimed at ensuring that your data is kept as secure as under applicable laws. These may include the standard contractual clauses for data exports as issued by the European Commission or another supervisory authority. A copy of such safeguards may be available from us if we receive a valid request.

If Later receives a request for personal information from a government, national security, or law enforcement agency, or other regulator, we would normally comply with such request without notifying affected individuals.

5. AI and Machine Learning

We may use your content, engagement data, and platform interactions to train and improve our AI models, including for content analysis, trend prediction, and service enhancement. This includes analyzing text, images, and video content you upload or link to our platforms. We use artificial intelligence and machine learning technologies (“AI”) to:

Analyze content performance and recommend optimal posting strategies;
Match influencers with relevant brand campaigns based on audience demographics and engagement patterns;
Detect fraudulent activity and fake engagement metrics;
Personalize platform experiences and suggest relevant features;
Suggest captions for your scheduled posts;
Recommend trending topics; or
Optimize campaign performance.

Automated Decision-Making: Some of our AI systems may make automated decisions, such as campaign eligibility, or content recommendations, however, such decisions do not produce legal or other significant effects, as defined by applicable laws.

6. Storage Period

We only retain personal information for as long as necessary for the purpose for which it was collected.

We may retain data for at least the time that you or your organization has an account, agreement, or other relationship with us. If you have subscribed for an account with us, or to receive a newsletter or other information, we will keep your details until you unsubscribe.

If you unsubscribe or ask for your personal information to be deleted, then we may retain some data with a view to preventing it from being collected or processed again. If we have excluded you from any of our services for any reason (e.g., breach of our terms of service), then we may also retain data in order to prevent repeated signups. We will also keep records of requests that we receive for exercise of individual rights under applicable privacy laws for the legally required period or in line with our recordkeeping policies.

We keep data relating to Creator, customer, or supplier contracts for at least the applicable limitation period for bringing legal claims, in order to be in a position to resolve any such claims. We may also keep data for longer periods where required for accounting, tax or legal reasons (in which case data use will be limited to such purposes).

We may retain and use anonymized, aggregated, or de-identified data indefinitely for analytics, research, and business purposes, including creation, development, and improvement of our products, algorithms, and models, provided that such data does not identify any individual or customer.

7. Your Rights

Depending on your location and the privacy laws that apply to you, you may have all or some of the following rights under those laws:

To access your personal information;
To have your personal information corrected or updated;
To object to processing of your personal information for direct marketing or for certain other purposes;
To restrict our processing of your personal information in certain circumstances;
To receive notice of what categories of personal information will be collected and the purposes for which it will be used;
To receive confirmation of whether or not your personal is being processed, plus information on how it is used, sold or shared;
To receive a copy in a portable format for transmission to another organization;
To opt out of sales or sharing, and in some states to opt out of data processing for targeted advertising and/or profiling for significant purposes;
To request deletion of your personal information (“the right to be forgotten”) (subject to some exceptions e.g. where required for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumers’ expectations);
To limit use of sensitive information to necessary uses;
To request human review and receive explanations of certain specific automated decisions; and
Not to be discriminated against based upon your exercise of any of your legal rights relating to your personal information.

If our data processing is based on your consent, then you can always withdraw that consent (but any processing that took place before withdrawal will still be legal).

As a subscriber or customer of one or more of our products and services, a Creator whose details we have obtained from public sources or third party data providers, or in general a potential customer who we believe may be interested in our products and services, we may send you marketing communications in respect of any Later product and service. We will do this only in accordance with applicable laws, any consents that may be required, and this Notice. You can decline such communications at any time by contacting us as set out in Section 9 below or as explained in each communication.

If your information is visible through our services because it is legally and publicly available (e.g., on social media platforms), then such information is normally excluded from the scope of most US state privacy laws and these rights may not apply to you in relation to such data. Please contact us as set out below in case of any doubt.

If you wish to exercise any of the above legal rights, you (or your authorized agent) can write to us using the contact details in Section 9 below, and we will respond within 45 days or as required by applicable laws. If you make such a request, including through an authorized agent, we reserve the right to verify your identity and the agent’s authorization. However, we may not be able to respond to your request if it is not permitted or foreseen under applicable laws. If you believe that we or any customer have not respected your rights, then you also have a right to make a complaint to the data protection supervisory authority in your country.

If we refuse a request to exercise your rights, then you are entitled to an internal appeal. You can exercise this right by contacting us, indicating the decision you wish to appeal and the reasons for the appeal. The decision will then be reviewed by one or more of our executives or legal counsel (who were not involved in making the original decision) and we will inform you of the result of the review.

Our products and services are not intended for children. We do not knowingly collect personal information from or about children. If you believe that we might have any information from or about a child, please contact us as indicated below.

8. Additional Information for California Residents

To supplement the details provided in Sections 3 and 4 of this Notice, we inform you that, during the 12 months before the publication of this Notice, Later collected:

(1) the following categories of personal information:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, or other similar identifiers;
Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information;
Characteristics of protected classifications under California or federal law;
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement;
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment-related information; and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

These categories of information were disclosed to our providers of IT-related services (e.g., data storage, websites development, hosting, management, maintenance, or analytics services), and/or marketing, advertising, and communications services, for our business purposes, as referred to in Section 3.

(2) the following categories of sensitive personal information:

A consumer’s social security number (used where we need to make payments to you);
A consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to an account;
A consumer’s racial or ethnic origin, religious or philosophical beliefs (where you have voluntarily provided this);
The contents of a consumer’s mail, email, and text messages (where you correspond with a brand or agency through our services); and
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation (where you have voluntarily provided this).

These categories of information were disclosed to our providers of IT-related services (e.g., data storage, websites development, hosting, management, maintenance, or analytics services) for our business purposes, as referred to in Section 3.

The business purposes referred to in this Section include:

Auditing related to counting ad impressions to unique visitors, and auditing compliance with this specification and other standards;
Helping to ensure security and integrity;
Debugging to identify and repair errors that impair existing intended functionality;
Short-term, transient use as part of your current interaction with us;
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
Providing advertising and marketing services;
Undertaking internal research for technological development and demonstration; or
Undertaking activities to verify or maintain the quality or safety of, and to improve, upgrade, or enhance our services or devices.

During the 12 months before the publication of this Notice, no personal information was sold.

During the 12 months before the publication of this Notice, Later shared the following categories of personal information:

Internet or other electronic network activity information (information regarding website visitors and potential customers, used for marketing and business development purposes).

9. Contacting Us

If you wish to exercise any of your legal rights or have any other inquiry in relation to this Notice, please contact us at the addresses below:

Mavrck LLC d.b.a. Later

60 State Street
8^th Floor – Suite 810
Boston, MA 02109
United States
Website: later.com
Email: privacy@later.com

Our representatives in Europe are:

EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Cookies Policy

A cookie is a small piece of data sent from a website or application and stored in a user’s web browser. Every time the user loads the website or application, the browser sends cookie information back to the server to notify the websites that it recognizes the user.

You can find more information about different types of cookies here.

Use of cookies helps us to improve our products and services and our websites and applications and to deliver a better and more personalized service by enabling us to:

Measure numbers of visitors and usage patterns;
Monitor whether our services are working correctly;
Store information about your preferences; and
Recognize you when you use the services or our websites or applications.

You may refuse to accept cookies by activating the appropriate setting on your device. You can also remove cookies from your web browser by following the directions provided in your browser’s “help” section. Some cookies are essential for securing access to and using features of our products and services or websites or applications, so if you clear all cookies then those features may not work as expected or at all, or you may need to accept some cookies on your next visit.

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