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MRGinnovations Privacy Policy

MRGinnovations' Privacy Policy describes how MRGinnovations collects, uses, and shares your personal data.

Updated July25 , 2022

In addition to this Privacy Policy, we provide data and privacy information embedded in our products and certain features that ask to use your personal information. This product-specific information is accompanied by our Data & Privacy Icon.

You will be given an opportunity to review this product-specific information before using these features. You also can view this information at any time, either in settings related to those features and/or online at apple.com/legal/privacy/data .

Please take a moment to familiarize yourself with our privacy practices, accessible via the headings below, and contact us if you have questions.

Your California Privacy Disclosures

Information Regarding Commercial Electronic Messages in Canada MRGinnovations Health Study Apps Privacy Policy

What Is Personal Data at MRGinnovations ?

Your Privacy Rights at MRGinnovations

Personal Data MRGinnovations Collects from You

Personal Data MRGinnovations Receives from Other Sources

MRGinnovations' Use of Personal Data

MRGinnovations' Sharing of Personal Data

Protection of Personal Data at MRGinnovations

Children and Personal Data

Cookies and Other Technologies

Transfer of Personal Data Between Countries

Our Companywide Commitment to Your Privacy

Privacy Questions

What Is Personal Data at MRGinnovations ?

At MRGinnovations , we believe strongly in fundamental privacy rights — and that those fundamental rights should not differ depending on where you live in the world. That’s why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by MRGinnovations as “personal data,” no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the serial number of your device — is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

This Privacy Policy covers how MRGinnovations or an MRGinnovations -affiliated company (collectively, “ MRGinnovations ”) handles personal data whether you interact with us on our websites, through MRGinnovations apps (such as MRGinnovations Music or Wallet), or in person (including by phone or when visiting our retail stores). MRGinnovations may also link to third parties on our services or make third-party apps available for download in our App Store. MRGinnovations' Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

Your Privacy Rights at MRGinnovations

At MRGinnovations , we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from MRGinnovations . MRGinnovations does not sell your data including as “sale” is defined in Nevada and California.

To exercise your privacy rights and choices including where a third-party service provider is acting on MRGinnovations' behalf, visit the MRGinnovations Data and Privacy page at privacy. mrginnovations .com for MRGinnovations .

There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and MRGinnovations is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.

If you live in California, if you cannot access MRGinnovations' Data and Privacy page, you or your authorized agent can make a request at support@mrginnovations.com .

Personal Data MRGinnovations Collects from You

At MRGinnovations , we believe that you can have great products and great privacy. This means that we strive to collect only the personal data that we need . The personal data MRGinnovations collects depends on how you interact with MRGinnovations . Descriptions of how MRGinnovations handles personal data for certain individual services are available either in settings related to those features or upon request.

When you create an MRGinnovations account , apply for services , purchase and/or activate a subscription or inquiry , Suspicious activity on any domain owned by MRGInnovations, download any materials , register for any of MRGInnovations services , connect to our services, use our services, contact us (including by social media), participate in an online survey, or otherwise interact with MRGinnovations , we may collect a variety of information, including:

• Account Information. Your MRGinnovations account information and related account details, including email address , devices registered, account status, and age , gender.

• Device Information. Data from which your device could be identified, such as device serial number, geolocation of requests, or other information about your device, such as browser type.

• Contact Information . Data such as name, email address, physical address, phone number, or other contact information

• Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information .

• Transaction Information. Data about purchases of MRGinnovations products and services or transactions facilitated by MRGinnovations , including purchases on MRGinnovations platforms

• Fraud Prevention Information. Data used to help identify and prevent fraud, including a device trust score .

• Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; user preference; crash data, performance and other diagnostic data; and other usage data .

• Location Information . Geo location for account security.

• Health Information. Data relating to the health status of an individual, including data related to one’s physical or mental health or condition. Personal health data also includes data that can be used to make inferences about or detect the health status of an individual. If you participate in a study using an MRGinnovations Health Research Study app, the policy governing the privacy of your personal data is described in the MRGinnovations Health Study Apps Privacy Policy .

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• Financial Information. Details including salary, income, and assets information where collected, and information related to MRGinnovations -branded financial offerings .

• Government ID Data. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances, including when setting up on-premise equipment and activating your devices, for the purpose of extending commercial use , managing reservations, or as required by law

• Other Information You Provide to Us. Details such as the content of your communications with MRGinnovations , including interactions with customer support and contacts through social media channels .

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

Personal Data MRGinnovations Receives from Other Sources

MRGinnovations may receive personal data about you from other individuals , from businesses or third parties acting at your direction , from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.

• Individuals. MRGinnovations may collect data about you from other individuals — for example, if that individual has sent you a product or gift card, invited you to participate in an MRGinnovations service or forum, or shared content with you.

• At Your Direction. You may direct other individuals or third parties to share data with MRGinnovations . For example, you may direct your mobile carrier to share data about your carrier account with MRGinnovations for account activation, or for your loyalty program to share information about your participation so that you can earn rewards for MRGinnovations purchases.

• MRGinnovations Partners. We may also validate the information you provide — for example, when creating an MRGinnovations account , with a third party for security, and for fraud-prevention purposes.

For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

MRGinnovations' Use of Personal Data

MRGinnovations uses personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

MRGinnovations uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, MRGinnovations may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. If you have questions about the legal basis, you can contact the Data Protection Officer at support@mrginnovations.com.

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• Power Our Services. MRGinnovations collects personal data necessary to power our services, which may include personal data collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting. For example, if you would like to access a song through an MRGinnovations Music subscription, we collect data on what songs you play in order to provide you with the content requested and for royalty purposes.

• Process Your Transactions. To process transactions, MRGinnovations must collect data such as your name, purchase, and payment information.

• Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with MRGinnovations , you may not opt out of receiving these important notices.

• Security and Fraud Prevention. To protect individuals, employees, and MRGinnovations and for loss prevention and to prevent fraud, including to protect individuals, employees, and MRGinnovations for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.

• Personal Data Used for Personalization. If you choose to personalize your services or communications where such options are available, MRGinnovations will use information that we collect so that we can offer you those personalized services or communications. You can learn more about how relevant services use information to personalize your experience by reviewing the privacy information presented when you first use a service that asks to use your personal data.

• Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.

MRGinnovations does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.

MRGinnovations retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

MRGinnovations' Sharing of Personal Data

MRGinnovations may share personal data with MRGinnovations -affiliated companies , service providers who act on our behalf, our partners , developers, and publishers , or others at your direction . Further, MRGinnovations does not share personal data with third parties for their own marketing purposes.

• Service Providers. MRGinnovations may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. MRGinnovations service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the

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personal data we share for their own purposes and must delete or return the personal data once they've fulfilled our request.

• Partners. At times, MRGinnovations may partner with third parties to provide services or other offerings. For example, MRGinnovations financial offerings like MRGinnovations Account Balance and MRGinnovations Rewards are offered by MRGinnovations and our partners. MRGinnovations requires its partners to protect your personal dat a.

• Others. MRGinnovations may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful

basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

Protection of Personal Data at MRGinnovations

At MRGinnovations , we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. For more information , for more information please reach us at privacy@mrginnovations.com .

Children and Personal Data

MRGinnovations understands the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 13 or the equivalent age as specified by law in your jurisdiction . That is why MRGinnovations has implemented additional processes and protections to help keep children's personal data safe.

To access certain MRGinnovations services, a child must have a child MRGinnovations Account . A child MRGinnovations Account may be created by the parent or, in the case of a Managed MRGinnovations Account , by the child's educational institution .

• Parents. To create a child account, parents must review the Family Privacy Disclosure for Children Agreement , which describes how MRGinnovations handles children's personal data. If they agree, the parent must provide MRGinnovations with a verifiable parental consent.

• Educational Institutions. Educational institutions that participate in the MRGinnovations School Manager Program may also create MRGinnovations Account s for students, called “Managed MRGinnovations Account s.” These schools are required to agree to the Managed MRGinnovations Account s for Students Disclosure which is included as Exhibit A to the MRGinnovations School Manager Agreement.

If we learn that a child's personal data was collected without appropriate authorization, it will be deleted as soon as possible.

To exercise privacy rights for your child's information, visit the MRGinnovations clients page at clients.mrginnovations.com and sign in to their account.

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Cookies and Other Technologies

MRGinnovations' websites, online services, interactive applications, and advertisements may use “cookies” and other technologies such as web beacons. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

• Communications Cookies. These cookies are used to enable network traffic to and from MRGinnovations' systems, including by helping us detect any errors.

• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your transactions, and to preserve the contents of your Bag when shopping online at apple.com.

• Other Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. MRGinnovations also uses these cookies to remember choices you make while browsing, so we can provide you with a customized experience.

If you prefer that MRGinnovations not use cookies, we provide you with the means to disable their use. If you want to disable cookies and you’re using the Safari web browser, choose “Block all cookies” in Safari’s privacy settings. If you are using a different browser, check with your provider to find out how to disable cookies. Certain features of the MRGinnovations website may not be available if all cookies are disabled.

In addition to cookies, MRGinnovations uses other technologies that help us achieve similar objectives.

In some email messages MRGinnovations sends to you, we provide a “click-through URL” that links you to content on the MRGinnovations website. When you click one of these URLs, they pass through a separate server before arriving at the destination page on our website. We track this click-through to help us determine interest in particular topics and measure whether we are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

MRGinnovations generally treats data we collect using these cookies and similar technologies as nonpersonal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data in those regions. In addition, MRGinnovations sometimes combines nonpersonal data collected from these technologies with other personal data MRGinnovations holds. When we combine data in this way, we treat the combined data as personal data for purposes of this Privacy Policy.

Ads that are delivered by MRGinnovations' advertising platform may appear in News mediums, digital medi ums, 3rd party advertising platforms , or within products sold or in relation to MRGInnovations . If you do not want to receive ads targeted to your interests from MRGinnovations 's advertising platform in those apps, you can choose to disable Personalized Ads, which will opt your MRGinnovations Account out of receiving such ads regardless of what device you are using. Y ou can disable Personalized Ads by choosing t o email us at privacy@mrginnovations.com . You may still see ads in News mediums, digital mediums, 3rd party advertising platforms, or within products sold or in relation to MRGInnovations based on context like your search query or the channel you are reading.

Transfer of Personal Data Between Countries

MRGinnovations products and offerings connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world, including MRGinnovations -affiliated companies, to perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services. MRGinnovations complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.

The MRGinnovations entity that controls your personal data may differ depending on where you live. For example, retail store information is controlled by individual retail entities in each country and MRGinnovations cloud s ervices-related personal data may be controlled by various MRGinnovations entities as reflected in the terms of service. If you do not reside in the U.S., your personal data may be processed by MRGinnovations Inc. and other MRGinnovations -affiliated companies on behalf of the MRGinnovations entity controlling personal data for your jurisdiction.

Personal data relating to individuals in China mainland may be processed by MRGinnovations in countries outside of China mainland. Where this occurs, it will be done in compliance with local laws, including the Personal Information Protection Law. As outlined in this Privacy Policy, MRGinnovations may also transfer such personal data to third parties, who may in turn store or transfer the data outside of China mainland.

Our Company Wide Commitment to Your Privacy

To make sure your personal data is secure, we communicate our privacy and security guidelines to MRGinnovations employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have questions about MRGinnovations' Privacy Policy or privacy practices including where a third-party service provider is acting on our behalf, would like to contact our Data Protection Officer, or would like to submit a complaint, you can contact us at MRGInnovations.com/connect/ or call the MRGinnovations Support number for your country or region. You can also ask us questions about how to submit a privacy complaint and we will endeavor to help.

MRGinnovations takes your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to your question or concern, including those inquiries received in response to an access or download request. In most cases, all substantive contacts receive a response within seven days. In other cases, we may require additional information or let you know that we need more time to respond.

Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity.

When there is a material change to this Privacy Policy, we’ll post a notice on this website at least a week in advance of doing so.