Last updated: September 4, 2021

Mirror Technologies Inc. (“Mirror”, “we”, “us” or “our”) takes your privacy seriously. We recognize that privacy is an important issue, so we design and operate our website, applications and services with the protection of your privacy in mind. This Privacy Policy (“Privacy Policy”) describes the collection of your personal information from our applications or our website located at https://mirror.me, including without limitation all sub-domains thereof on which this Privacy Policy is posted (collectively, the “Mirror Service” or “Service”) and through your use of our products and functionality made available through the Service. This Privacy Policy also describes our use and disclosure of such information.

The term “Personal Information” as used in this Privacy Policy refers to personally identifiable information that specifically identifies an individual (such as an individual’s first and last name, address, telephone number, e-mail address, credit card or other account number), and information about that individual or such individual’s activities or preferences when such information is directly linked to personally identifying information.

Mirror is an online business service platform.  We provide the Mirror Service to our clients with whom we have contractual relationships (“Customers”).  The terms “you” and “your” refer to our Customers accessing or using the Service, and visitors to our sites.  By accessing the Service or using the products or functionality made available through the Service, you consent to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy.

The users, visitors and clients of our Customers are “End Users”, and the collection, use, transfer and retention of End User data are governed by our Customer’s privacy policies, not this Privacy Policy.

1 HOW WE COLLECT PERSONAL INFORMATION

We collect Personal Information from you in the following ways.

Via Registration.  We collect the Personal Information you provide to us when you register for an account on the Service.

Via Correspondence.  If you contact us by e-mail or contact form on the Service, or by mail, fax, or other means, we collect the Personal Information contained within, and associated with, your correspondence.

Via E-mail Newsletters.  We may offer e-mail newsletters from time to time on the Service.  If you sign up to receive a newsletter from us, we collect your e-mail address.

Via Interactive Service Features. The Service may contain interactive functionality that allows you to engage with other users, to participate in livestream sessions or voice conversations. If you use any interactive functionality on the Service that requests or permits you to provide us with Personal Information (including, for example, your phone number or e-mail address), we collect the Personal Information that you provide to us in the course of using these interactive features.

Via Passive Means Through the Service and Correspondence.  When you use the Service, some information is collected automatically. For example, when you access the Service, we may automatically collect (a) your browser’s Internet Protocol (IP) address, (b) your browser type, (c) the nature of the device from which you are using the Service (e.g., a personal computer or a mobile device), (d) the identifier for any handheld or mobile device that you may be using, (e) the website that you visited immediately prior to accessing the Service, (f) the actions you take on the Service, (g) your location (if enabled), and (h) the content, features, and activities that you access and participate in on the Service.  We also may collect information regarding your interaction with e-mail messages, such as whether you opened, clicked on, or forwarded a message.  We may collect this information passively using technologies such as standard server logs, cookies and clear GIFs (also known as “web beacons”).  We may use information passively-collected from the Service to administer, operate and improve the Service and our other programs, services, products, websites and other systems, to improve the effectiveness of advertising on the Service, and to provide advertisements and other content and an experience on the Service that is tailored to you.  If we link or associate any information gathered through passive means from the Service with your Personal Information, or if applicable laws require us to treat any information gathered through passive means from the Service as Personal Information, we treat the combined information as Personal Information under this Privacy Policy.  Otherwise, we use and disclose information collected by passive means from the Service in aggregate form or otherwise in a non-personally identifiable form.

Via Other Sources.  We may receive information about you, including Personal Information, from third parties, and we may combine this information with other Personal Information we maintain about you. If we do so, this Privacy Policy governs any combined information that we maintain in personally identifiable format.

2 HOW WE USE PERSONAL INFORMATION

We use Personal Information (a) to provide product, services and information that you request, (b) to enhance, improve, operate, and maintain our products, services, websites and other systems, (c) to prevent fraudulent use of our products, services, websites and other systems, (d) to prevent or take action against activities that are, or may be, in violation of our Terms of Use or applicable law, (e) to tailor content and other aspects of your experience on and in connection with the Service, (f) to maintain a record of our dealings with you, (g) for other administrative purposes and (h) for any other purposes that we may disclose to you at the point at which we request your Personal Information, and pursuant to your consent.  We may also use Personal Information you provide to contact you regarding products, services, and offers that we believe you may find of interest.

3 HOW WE DISCLOSE PERSONAL INFORMATION TO THIRD PARTIES

Except as described in this Privacy Policy, we do not disclose or transfer Personal Information about you to any third party unless we have your express permission.

Protecting our Interests.  We disclose Personal Information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of the Service and other users of the Service.

Corporate Affiliates, Service Providers and Business Transfers.  Mirror may disclose or transfer your Personal Information (a) to its corporate affiliates (for example, a subsidiary or parent corporation), (b) to its service providers (like fulfillment, hosting, or payment service providers), but only for their use to provide the requested service or (c) to an acquirer or a successor or an assignee as part of any merger, acquisition, debt financing, sale of company assets or similar transaction, as well as in the event of an insolvency, bankruptcy or receivership in which Personal Information is transferred to one or more third parties as one of our business assets. Mirror requires its corporate affiliates that receive your Personal Information to limit their use and disclosure of your Personal Information in accordance with this Privacy Policy.  Mirror requires each of its service providers to agree to maintain the confidentiality of your Personal Information disclosed or transferred by Mirror to any such services provider.

4 UPDATING YOUR INFORMATION AND CONTACT PREFERENCES

You may update some of the information you provide to us as follows:

Your Information:  If you have an account on the Service, we provide mechanisms for you to review and update certain Personal Information you provided to us to obtain your account by logging into your account on the Service.

Your Contact Preferences:  If you receive commercial e-mail from us, you may unsubscribe at any time by following the instructions contained within the e-mail. You may also opt-out from receiving commercial e-mail from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by e-mail at privacy@mirror.me or by writing to us at the address given at the end of this policy.  Additionally, if you have a user account on the Service, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us.  Please be aware that if you opt-out of receiving commercial e-mail or other promotional communications from us, it may take up to ten (10) business days from the time that we receive your request for us to process your opt-out request, and you may receive commercial e-mail or promotional communications from us during that period.  Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding your use of the Service and any products or services made available through the Service.

5 HOW WE PROTECT YOUR PERSONAL INFORMATION

Mirror uses reasonable administrative, technical, and physical security controls designed to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, we cannot guarantee that your Personal Information will be absolutely protected.

Your Personal Information and data files are stored on our servers and the servers of our affiliated companies and companies we hire to provide services to us. We will retain your Personal Information for as long as necessary to provide you with the websites and Services you use, as needed to comply with our legal obligations and legal rights including to prevent fraud or enforce our agreements, and for our internal business reasons such as maintenance of our archive and backup systems for a period after your use of our websites and Services ends. We retain aggregate information beyond this time for research purposes and to help us to develop and improve our services.

6 YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

We take reasonable steps intended to ensure that the Personal Information we collect is accurate, complete, and current by using the most recent information provided to us. Our Services may allow you to review and edit your Personal Information by accessing your account or similar feature of the website or Service you are using.

The following describes your options for managing the various types of cookies used by Mirror on our websites and Services:

• Required Cookies: Required cookies are necessary to enable the basic features of this site to function, such as providing secure login or using our Services. Because required cookies are essential to operate the Mirror’s websites and the Services, there is no option to opt out of these cookies.
• Functionality Cookies: Functionality cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your login details and other information you have entered or choices you make, displaying more personal features, or providing us information about how our site is used. To learn more about how to control functionality cookies using your browser settings, please see aboutcookies.org.

If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.  Also, you may have additional rights under certain laws and circumstances to:

• Be provided with a copy of your Personal Information held by us
• Request the correction or erasure of your Personal Information held by us
• Object to the further processing of your Personal Information
• Request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example)
• Request that your Personal Information be transferred to a third party

You may submit a request to us by contacting us at the Mirror contact information provided below. Once we verify your identify, we will assist you with your request.

If you remain unhappy with a response you receive about the treatment of your Personal Information you can also refer your concerns to the relevant privacy or data protection supervisor in your jurisdiction.

7 DATA TRANSFERS ACROSS BORDERS

Our servers and data centers are located in the United States. If you choose to use the Service from outside the U.S., then you should know that you are transferring your Personal Information outside of your region and into the U.S. for storage and processing. By providing your Personal Information to us through your use of the Service, you agree to that transfer, storage and processing in the U.S.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests and operating the Service.  You should know that each region may have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region.  When we transfer your Personal Information, we will take appropriate steps to ensure your privacy rights continue to be protected.

8 CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the “Last Updated” date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current Privacy Policy. Your continued use of the Service constitutes your agreement to the Privacy Policy as modified.  If we change this Privacy Policy in a manner that is materially less restrictive of our use or disclosure of your Personal Information, we will use reasonable efforts to notify you of the change and to obtain your consent prior to applying the change to any Personal Information that we collected from you prior to the date the change becomes effective.

9 CONTACT US WITH QUESTIONS OR CONCERNS

If you have any questions regarding this Privacy Policy, please contact us at privacy@mirror.me or by mail at: Mirror Technologies Inc., Attn: Privacy Officer, 252 Nassau St, 2nd Floor, Princeton, NJ 08542.

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