Legal Terms

Last updated: October 9,2024

We – MGL Global Solutions Limited and our affiliates (“MGL”, “we”, “us”, “our”) – provide you with this Privacy Policy to inform you about how and when we process personal information that we collect through our websites, microsites, and mobile sites (collectively, “Services”) operated by us from which you are accessing this Privacy Policy.

1. Collection of Personal Information

“Personal Information” is information that relates to an identified or identifiable individual, including as such term is defined in the applicable law. We collect Personal Information through your use of our Services and in certain instances from third parties. We also use and combine data to infer insights about you, for example, your product preferences, characteristics, predispositions, or behaviors.

1.1 Personal Information We Collect from You

We collect Personal Information through your use of our Services, for example, when you register an account to access our Services, register your products, interact with our customer support or our franchisees or licensees, when you participate in contests or competitions, when you sign up for marketing communications, make inquiries regarding product warranties, navigate the Services, utilize one of our connected devices, participate in an event, make a purchase, communicate with us, or become a partner or vendor.

Depending on how you use our Services, we collect different types of Personal Information from you:

• Contact Information: such as your name, email address, phone number, address, and country of residence;
• Account Information: such as login credentials, consumer profile, username, browsing history, cart contents, and purchase history;
• Audio, Electronic, Visual Information: such as images and audio, video or call recordings created in connection with our business activities.
• Transaction Information: such as purchase details, payment details including credit card or bank account details, including debit or credit card details, bank account details, and billing address;
• Device Information:technical information associated with the device you use, such as the device type and model, system language, browser type, geographical location, and operating system, and technical identifiers that identify the device you use, such as IP address, IDFA (identifier for advertisers), and other unique identifiers;
• Connected Products Information: usage information while you use any of our connected products;
• User Content: such as information related to customer satisfaction surveys, customer requests or queries, and other content you may create, such as posts on our Social Media Pages, along with any related name, username, alias, or other account information;
• Images and Videos: such as photos and videos submitted by you (for example, as part of a redemption campaign) or taken at one of our events;
• Physical Location: your physical location including your precise geolocation that can be derived from your IP address, GPS coordinates, use of our connected products, your interactions with our emails, or your manually selected location, zip code or postal code, depending on your preferences;
• Professional Characteristics: such as your trade, industry, employment status, profession, work or trade skill levels, and experience;
• Demographic Characteristics: such as the number of household members, country of residence, age, birthdate, ethnicity, affiliation, industry, income, education, employment status, profession, trade, trade union membership and gender;
• Usage Information: such as information concerning your browsing behavior, your purchasing patterns and trends, and engagement, such as how long you visit a page, what links you click on, what pages you visit, how many times you visit a page and how long it takes for you to come back;
• Preferences: your preferences, either based on purchasing habits or on information about your preferences, including your preferred payment method, your purchased, viewed and recommended products, your preferred language, and your preferences regarding marketing communications and use of cookies;
• Social Media Information: your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account;
• Relationship History: details of your contact with us, as well as order history;
• Other Personal Information: that you provide to us.

1.2 Personal Information Provided by Third Parties

In certain cases, we also receive Personal Information about you from other sources, for example:

• Publicly Available Information, from publicly available databases, such as LinkedIn, product review websites, or local trade or industry associations’ registries, or following the monitoring of social media channels for feedback and direct mentions of MGL or following web data extraction;
• Purchase Information from associated dealers or retailers of MGL products or our service providers;
• Contact Information, Professional Characteristics and Other Information from data brokers, business partners, including for joint marketing and promotion events, and from event managers, influencers, and privately-owned marketing or survey/enquiry databases.

Like many other website owners and operators, we use automated data collection tools such as cookies and web beacons to collect certain information.

If you disclose any Personal Information relating to other people to us or to our vendors in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy and our Terms of Use available on the brand site you access.

1.3 Sensitive Information

We may collect and process information that may be interpreted as sensitive information. We will do so only when permitted by Applicable Law and will follow all applicable processing restrictions associated with processing of such data. Where applicable, we will obtain your express permission when any of your sensitive Personal Information is processed.

Depending on applicable law, sensitive information may include: race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, veteran status, background check information, judicial data such as criminal records, financial and bank account data, personal identification information, or precise geolocation information.

If the information that you voluntarily provide to us does include sensitive information, as defined by applicable law, you expressly authorize MGL to process such personal information in accordance with this Privacy Policy.

2. Use of Personal Information

We use your Personal Information to the extent necessary to achieve the purposes described below.

2.1 Process Orders and Returns

We process your Contact Information, Account Information, Transaction Information, Device Information, Location, Preferences, Relationship History, Publicly Available Information, and other Personal Information you provide us with, in order to process your orders and returns, including warranty and product registration, related payments, exchanges or refund requests.

2.2 Provide Services

We process your Contact Information, Account Information, Device Information, User Content, Location, Preferences, Social Media Information, Relationship History, Publicly Available Information, and other Personal Information you provide us with, in order to provide you with the Services you request from us in a personalized and efficient way, including: 1) opening and arranging access to your registered account, and updating and maintaining the information in your account; 2) utilizing the functionality of any smart devices, including geolocation-based requests (such as local weather or proximity to a specific location) or device pairing; and 3) sending you administrative information related to your account, such as changes in our terms, conditions and policies.

2.3 Provide Customer Service

We process your Contact Information, Account Information, Device Information, User Content, Location, Preferences, Relationship History, and other Personal Information you provide us with, in order to follow-up on your customer service requests, such as to provide you with assistance, and handle your enquiries and complaints.

2.4 Send You Marketing Communications, Tailor Our Content for You, and Organize and Communicate Promotions and Contests

We use your Contact Information, Account Information, User Content, Professional Characteristics, Preferences, Social Media Information, Relationship History, Purchase Information, and other Personal Information you provided us with, including any inferences we infer about you using such information, to identify your preferences and tailor our content and recommendations for you, send you personalized advertising and marketing related communications about our Services, new products and other news about our company.

If we have a prior relationship, we may send you communications about products and Services that are similar to products and Services you requested information about or purchased before. You will be able to opt out from marketing communications at all times.

We may obtain your consent in certain instances, including when legally required, to send you marketing emails using the information described above. We may also obtain your consent if we do not have a prior relationship with you. If you provide your consent, we will use the Personal Information outlined above to ensure that the marketing content is tailored to your interests. If you no longer wish to receive these marketing communications, you are free to unsubscribe at any time.

Where applicable, we have a legitimate business interest to send you marketing communications, and to organize and communicate promotions and contests.

2.5 Facilitate and Host Visits, Conferences, and Events

We use your Contact Information, Account Information, Professional Characteristics, Preferences, Relationship History, Purchase Information, Photographs and Videos, and other Personal Information you provided, to facilitate and host conferences and events, such as trade shows, and to welcome visitors at our premises.

2.6 Improve Our Products and Services

We use your Account Information, Professional Characteristics, Demographic Characteristics, Usage Information, Purchase Information, Relationship History, and other Personal Information you provide us with to conduct data analyses and customer surveys and studies, for example, to improve the efficiency of our Services, to develop new products and Services, to identify usage trends (e.g., which parts of our Services are of most interest to users), and to determine the effectiveness of our marketing campaigns. Similarly, we may use your Personal Information for quality and training purposes.

Where applicable, if we process your Personal Information to improve our products and Services, we do this for the preservation of our legitimate interests to continuously improve our products and Services to ensure that you have the best experience possible. Where legally required, we will obtain your consent for such processing activities.

2.7 Advertisements

We use your Personal Information obtained by cookies and similar technologies to help us select advertising to serve to you and where to serve it based on your experience on our Services and other sites that you visit.

2.8 Build New and Maintain Existing Partner Relationships

We use your Contact Information, Account Information, Professional Characteristics, Relationship History, and other Personal Information you provide us with, to build new partner relationships with vendors, suppliers and distributors, to facilitate bids, proposals and contracting, to onboard partners, to facilitate performance of Services, to provide feedback and manage relationships, and to facilitate contract renewals and termination.

Where applicable, if we process your Personal Information to build and maintain partner relationships, we rely on our legitimate interests and the legitimate interests of our partners or of a third party to conduct business and to ensure that you have the best experience possible. Where legally required, we will obtain your consent for such processing activities.

2.9 Inform a Third Party in the Context of a Sale or Business Transaction

We may process your Personal Information for disclosing or transferring some or all of the Personal Information collected about you to a third party if MGL were ever merged with or acquired, or involved in a corporate reorganization, joint venture, assignment, sale, or transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

Where applicable, we would process your Personal Information in the context of such a sale or business transaction based on our legitimate interest to conduct business.

2.10 Keep Our Services Safe from Misuse and Illegal Activity

We use your Personal Information to keep our Services safe from misuse and illegal activity. This includes conducting security audits, verification that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements, monitoring for and prevention of fraud, and verification that your registration with or use of our Services is compliant with our terms and conditions of purchase and Terms of Use and is in no other way inappropriate or illegal. For example, we will review the public reviews you provide on a relevant store website in order to verify compliance with our Terms of Use available on the brand site you access.

Where this is the case, we process your Personal Information as necessary for the fulfillment of our statutory duties and obligations and, where applicable for the preservation of our legitimate interests or the legitimate interests of our partners or of a third party to prevent misuse and illegal activity, such as fraudulent transactions.

2.11 Comply with Legal Obligations

We use your Personal Information as necessary to comply with our legal obligations. This may include instances where we have received a reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities. For example, we may be required to collect and transfer your Personal Information to our financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.

Similarly, we may share your Personal Information, after considering your privacy interests and other factors, with law enforcement or judicial authorities, as evidence or if there are justified suspicions of any unlawful act or crime committed by you through our Services or other interaction with us. Such action may be necessary, for example, to conform to legal requirements or comply with legal processes, including laws outside of your country of residence; to enforce or apply our terms of use and other agreements, including for billing and collections purposes; to protect our property rights and safety or property rights and safety of a third party, our affiliated companies, or the public in general; or to stop any activity that we consider illegal, unethical or legally actionable. Where we process or share your Personal Information for these purposes, we do this to comply with our legal obligation.

3. Recipients

We will only share your Personal Information with third parties as described in this Privacy Policy.

3.1 Information We Share in Order to Provide Our Services

You understand that if you purchase or use our products or Services, your Personal Information may also be processed by third parties, who process your Personal Information on our behalf in order to provide you with our products and Services and to improve them. This includes, but is not limited to, product registrations, providing website hosting, data analysis, information technology and related infrastructure provision, advertising and analytic services.

We will only engage third parties for the processing of your Personal Information to the extent this is necessary to achieve the purposes as set out in Section 2 - Use of Personal Information. Our third-party processors are only allowed to process your Personal Information on our behalf and upon our written instructions. We select our processors with due care and contractually oblige them to observe the safety and integrity of your Personal Information. Some of these third-party processors may be located in a country whose data protection legislation is different from your country, and they will have access to your Personal Information as necessary to perform their functions, but they may not share your Personal Information with any other third party or use that data for any other purpose.

3.2 Information We Share with Our Affiliates and Licensees

We may share your Personal Information with our affiliates and our licensees for their use in relation to the marketing, distribution, advertising sale, and servicing of products sold under license from us.

3.3 Information We Share with Business Partners to Market Their Products or Services

Consistent with your choices, we may disclose your Personal Information to third parties to market their products or services to you.

3.4 Information We Share with Other Third Parties

We may disclose your Personal Information as necessary to comply with our legal obligations, in the context of a sale or business transaction, or to keep our Services safe from misuse and illegal activity.

We contract with third party advertising companies to tailor online advertising to be directed to you on other websites and online services. These third-party advertising companies place, use, or rely on technology, such as cookies and pixel tags, to obtain information about your interactions with our Services. In addition to information the companies receive from your access to and use of other websites or online services on any of your devices, and information received from third parties, this information helps us select relevant advertising for you. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.

We process your Personal Information in accordance with this Privacy Policy and such processing is limited to what is necessary to achieve the purposes set out in this Privacy Policy.

3.5 Information You Choose to Share via the Services

By using the Services, you may elect to disclose Personal Information:

On message boards, public chat rooms, profile pages, blogs, research panels and communities, surveys, product review pages, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

4. Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage vendors, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.

Several countries require that organizations put in special protections when information is shared cross border. We comply with those obligations and have implemented intercompany mechanisms to meet those requirements.

If the applicable law requires your prior consent for the cross-border transfer of your Personal Information, we will ask you for such consent.

5. Your Choices and Data Subject Rights

5.1 Consent and Opt-Out

You have choices about your Personal Information that we collect about you and how we use and disclose your Personal Information, according to the applicable law.

Where legally required, we will obtain opt-in consent prior to collecting or processing your Personal Information. You have the right to withdraw your earlier given consent for processing your Personal Information. Note that withdrawal of your consent may mean that certain functionalities within our Services are not accessible to you.

You may opt out of the following:

Marketing Communications: You may opt out of our marketing communications. However, even if you opt-out, you may still receive non-marketing communications, such as order/shipping confirmation, changes to service, product registrations, product recalls, or other important customer services communications.

Text Messaging/IM Marketing: You may opt out of marketing sent by mobile text messages (e.g., SMS, MMS) and other instant messages (e.g., WhatsApp, Facebook Messenger) from us.

Direct Marketing: We may share your Personal Information with third parties for their direct marketing purposes, where allowed by applicable law. If you would prefer that we discontinue sharing your Personal Information with third parties for their direct marketing purposes, you may opt out of this sharing.

Location: You can opt-out of collection and use of your location information by checking your browser settings and your email program settings, and not allowing the app downloaded on your mobile device. Your desktop or mobile device settings may allow you to disable or block location-based services, which will prevent our Services from accessing your location information. If you choose not to provide this information, you may not be provided with content specific to your location, and we or our marketing partners may not be able to provide you with the applicable personalized services and content.

5.2 Data Subject Rights

5.2.1 Right of Access

You have the right to request access to your Personal Information processed by us.

5.2.2 Right to Rectification

You have the right to ask that Personal Information pertaining to you that is inaccurate is corrected, at no cost to you. Your request for correction must be accompanied with proof of the inaccurate nature of such data.

5.2.3 Right to Erasure

You have the right to request that your Personal Information will be deleted if it is no longer required considering the purposes outlined in this Privacy Policy, or if you withdraw your consent. Depending on your jurisdiction, this request will be evaluated in light of:

Our overriding interests or the overriding interests of any other third party; Legal or regulatory obligations or administrative or judicial orders that may prevent such deletion.

Instead of deletion, you can also ask that we limit the processing of your Personal Information if and when you contest the accuracy of your Personal Information, you consider the processing to be illegitimate, your Personal Information is no longer needed for the purposes listed in this Privacy Policy, or as otherwise allowed by applicable law.

5.2.4 Right to Object

You have the right to object to the processing on grounds relating to your particular situation. However, you can always object to processing for direct marketing purposes free of charge and without justification.

5.2.5 Right to Data Portability

When we process your Personal Information based on your consent or in order to perform a contract, you have the right to receive the Personal Information you have provided us with in a structured, commonly used, and machine-readable format, and you have the right to transmit such data to another entity.

5.2.6 Right to Not Be Subject to Automated Individual Decision-making

You have the right not to be subject to a decision that is solely based on automated processing, if that decision produces legal effects concerning you or significantly affects you, unless the decision is made as a consequence of our agreement in order to provide you with the Services you requested or when we obtained your explicit consent.

5.3 Requests

If you wish to submit a request to exercise one or more of the rights listed above, you can contact our data protection officer responsible for your country or region.

Your request should state the right you wish to exercise and, if required, the reasons or necessary proof. We may require certain Personal Information from you to verify your identity. Upon validating your request, we will try to comply with your request to the extent required by applicable law as soon as reasonably practicable.

6. Security

We want you to feel confident about using our Services, so we implement security safeguards designed to protect your data. We have implemented appropriate technical, administrative, organizational, and physical measures designed to protect your Personal Information from unauthorized access or theft, as well as accidental loss, tampering or destruction. However, we cannot warrant or guarantee the safety or security of your data.

7. Retention

Your Personal Information is only processed for as long as needed to achieve the purposes set out in this Privacy Policy (considering contextual elements, such as the length of time we have an ongoing relationship with you and provide you our Services), or up until such time where you withdraw your consent for processing them.

In such case, we will delete or de-identify your Personal Information. In certain jurisdictions, we may not delete or de-identify your Personal Information if:

We have an overriding interest in keeping your Personal Information identifiable (when retention is advisable in light of applicable statutes of limitations, litigation or regulatory investigations),

A legal or regulatory obligation or a judicial administrative order prevents us from de-identification or deletion (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them).

Please note that if you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing communications in the future.

8. Changes to This Privacy Policy

We may make changes to this Privacy Policy from time to time, so please review it periodically. We will update the effective date of the Privacy Policy at the time a change is made. We will notify you of any changes by posting the changes on our website or our Services, or notifying you by email. Your use of the Services following these changes means that you accept the revised Privacy Policy.