Date Last Revised: January 1, 2021

MPOWR COMMUNITY PRIVACY POLICY

MPOWR is committed to protecting the privacy of Our customers and developing technology that provides a secure and satisfying online experience. This MPOWR Community Privacy Policy (the “Policy”) applies to MPOWR Community (the “System”), which is owned and operated by MPOWR Group, LLC (referred to as “MPOWR,” “We”, “Us”, or “Our”). This Policy explains the collection, use and disclosure of personally identifiable information about individual users of the System and the authorized users of Community Organizations (all of whom are collectively referred to as “You” and “Your”).

By using the System, you consent to the privacy and data practices described in this Policy. Your use of the System is also controlled by the MPOWR Community User Terms of Service or the MPOWR Community Organization Terms of Service, as applicable, which You agreed to follow when creating Your MPOWR Community Account or Community Organization profile (collectively, the “Terms of Service”).

We will collect personally identifiable information (“Personal Information”) that You submit or which We collect through Your use of the System. We also disclose Personal Information as described in this Policy and in the applicable Terms of Service. If You have questions or concerns about this Policy, please contact Us using the contact information set forth below.

Please read through all sections of this Policy. Your access to and use of the System is subject to this Policy and all applicable laws. By creating an MPOWR Community Account, submitting Personal Information through the System, accessing and/or otherwise using the System, You consent to MPOWR’s use of the Personal Information as set forth in this Policy. If You do not agree to this Policy, then You may not use the System and You should not create an MPOWR Community Account or submit Your Personal Information to the System.

We reserve the right, at any time, to add to, change, update or modify this Policy. MPOWR will post any changes We make on this page. The date the Policy was last revised is identified at the top of the page. If We make a change to the Policy that We, in good faith, determine is not material, or if We intend to only apply the change prospectively, We will notify You of the change by email and give You a reasonable time to opt-out of the change. If We make a change to the Policy that We, in good faith, determine is both material and retroactive, We will seek Your affirmative express consent to the change.

About Community Organizations, Authorizations, and Referral Transactions

MPOWR Community is designed to allow individuals who need services to connect with providers who may provide those services. Throughout this Policy, and within the System itself, We refer to service providers as “Community Organizations.” For example, a Community Organization could be an employer, medical provider, social services organization, homeless shelter, religious organization, counselor, or any other service provider organization who has created an MPOWR Community Organization profile in order to provide information or assistance to  individual users of the System.

A critical function of the System is to provide individuals and Community Organizations with the ability to connect and communicate. One of the main ways MPOWR Community does this is by allowing individuals to designate certain Community Organizations as “authorized” to view and copy the Personal Information in their MPOWR Community Accounts. Another important function of MPOWR Community is helping individuals get referred to the Community Organizations who can best provide the services they need. We refer to these communications as “Referral Transactions” and they are described in more detail within the applicable MPOWR Terms of Service.

What this Policy Covers

This Policy covers the types of information We may collect or that You may provide when You create an MPOWR Community Account or Community Organization profile. This Policy also describes Our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy applies only to information We collect through the System, and in email, text, and other electronic communications sent through or in connection with the System.

This Policy applies only to the MPOWR Community website and System, and it DOES NOT apply to:

(i) information that We collect on any other MPOWR apps or websites;
(ii) any services, Community Organizations, websites, or other resources that You may access through the System; or
(ii) information You provide to or that is collected by any third party, including a Community Organization.

Our websites and apps may have their own privacy policies, which We encourage You to read before providing information on or through them. The System may contain links to third-party sites not owned or controlled by MPOWR. MPOWR is not responsible for the privacy policies of any third-party site which users may access through a third-party link. Further, these third-party sites may have privacy policies that differ from this Policy. MPOWR disclaims all responsibility for the privacy practices of such other third-party sites. You should read the privacy policies of each site You visit to determine what information that site may be collecting about You and how they intend to use such information.

MPOWR is not responsible for how Community Organizations collect, use, maintain, or disclose Personal Information. Individuals should review the privacy policies for each Community Organization with which he or she creates a relationship and directly manage the relationship with those Community Organizations.

Individuals Under the Age of 13

The System is not intended for individuals under 13 years of age, and We do not knowingly collect personal information from individuals under 13. If We learn We have collected or received Personal Information from an individual under 13 without verification of parental consent, We will conduct a review of applicable law, and We may delete that information without notice. If You believe We might have any information from or about an individual under 13, please contact Us using the contact information provided at the end of this Policy.

Information We Collect

We collect information from and about users of Our System. As described in more detail below, We collect the following types of information about You:

  • We collect information directly from You when You provide it to Us.
  • We collect information about individual users of the System that We receive from or store on behalf of Community Organizations and their authorized users.
  • We automatically collect certain information when You use the System.

Information You Provide Directly

When You create an MPOWR Community Account, We may collect and store Your name, postal address, email address, telephone number, social security number, and other Personal Information that We use to uniquely identify You as a user of the System.

As You use the System, We collect and store information that You provide by filling in fields or forms within the System. If You are an individual, We call this information “Profile Detail Information,” and it may include information about Your financial or medical condition, relationships or experiences with Community Organizations, or the list of Community Organizations You may follow or authorize. For Community Organizations, We call this information “Community Organization Data,” and this is defined in more detail within the Terms of Service.

We also collect and store information that individuals send directly to Community Organizations through the System, such as information provided on a Community Organization’s custom fields, forms, templates and similar tools.

Information We Receive from Community Organizations

We collect and store information relating to Referral Transactions that individuals self-initiate or that Community Organizations initiate, such as the Community Organizations who are named in the Referral Transaction, the type of service for which an individual is being referred, and other information that is specifically related to facilitating the Referral Transaction.

An important feature of the System is to permit Community Organizations and their authorized users to use the System to create, manage, and store information about the individuals they serve, including individuals who are users of the System. Thus, We collect and store information about individuals that Community Organizations enter into the System.

Automatic Information Collection and Tracking Technology

User Identifier. We may log all connections to Our web servers. Those log files may include a unique user identifier, including, but not limited to Your IP address and/or Your mobile operating system (OS), Our embedded, or other commonly used mobile device identifier (a “User Identifier”). A User Identifier is general information about Your location, connection to the Internet, and Your Internet or mobile phone service provider. We use Your User Identifier to help diagnose problems with Our server and to administer the System. Additionally, We may use Your User Identifier to track Your navigation of the System.

Cookies. We may use a standard feature in browser software called “cookies” to enhance Your experience with Our System. Cookies are small files that Your web browser places on Your hard drive for record-keeping purposes. By showing how and when visitors use the System, cookies help Us identify how many unique users visit the System and track user trends and patterns. Cookies also benefit Your use of the System and save You time by storing and making easily available information required to use the System. Please note that deleting Our cookies or disabling future cookies may negatively affect the continuity and user experience when You use the System.

Clear Gifs. We may also employ a software technology called clear gifs (also known as web beacons) that help Us better manage content on the System by informing Us what content is effective and of interest to Our users. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of System users. Clear gifs and cookies may be used to improve Your user experience when using the System.

Other Tracking Technologies. We may also employ other tracking technologies common in the mobile industries, including UDID, Open UDID, ODIN, MAC Address, device fingerprinting, or other technology. These technologies help Us better manage content on the System by informing Us what content is effective and of interest to Our users. These technologies are similar in function to cookies, and are used to track the online movements of System users.

Log Files. Like most standard website servers, We may use log files. Information collected in log files may include internet protocol (IP) addresses, Your User Identifier, browser type, internet service provider, mobile network provider, referring/exit pages, platform type, date/timestamp, and number of clicks. We utilize this information to analyze trends, administer the System, track Your movement in the aggregate, and gather broad demographic information for aggregate use. This information may be used to improve Your experience with the System.

The System does not treat browsers with a DNT signal differently from those without one.

Information Sharing and Disclosure

We may disclose de-identified, anonymous, pseudonymized and/or aggregate information about Our users without restriction. We will not sell Your Personal Information, but We may sell de-identified, anonymous, pseudonymized and/or aggregate information that was created from Your Personal Information if it cannot reasonably be used to identify You.

You grant MPOWR certain licenses to disclose Your Personal Information pursuant to the Terms of Service to which all users of the System agree when they establish an MPOWR Community Account.

We may disclose Your Personal Information as needed to provide the features and functionality of the System. This specifically includes the following types of disclosures:

  • Information used to uniquely identify individual users may be disclosed in response to searches that a Community Organization initiates to locate and confirm the identity of a specific user of the System.
  • Information about services individuals may request, receive, or be referred for will be disclosed to a Community Organization who refers the individual for a service and the Community Organization to whom the individual is referred.
  • All of the information in an individual’s MPOWR Community Account may be disclosed to Community Organizations which the individual designates as “authorized” using the controls within his or her MPOWR Community Account. THIS INFORMATION MAY CONTAIN HISTORY OR TREATMENT INFORMATION RELATING TO MENTAL HEALTH, ALCOHOL OR DRUG ABUSE, GENETIC TESTING RESULTS, AND/OR AIDS/HIV TEST RESULTS IF AN INDIVIDUAL HAS ENTERED THAT INFORMATION INTO HIS OR HER ACCOUNT.
  • The entire list of Community Organizations that an individual has designated as “authorized” may be disclosed to each of the Community Organizations on that list.

In addition, We may disclose Personal Information that We collect or that You provide as follows:

  • To Our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties We use to support the System.
  • To third parties as needed to support functionality that allows You to export or “share” information You find within the System to other platforms (such as Your email or social media accounts).
  • If You are the authorized user of a Community Organization, We may disclose identification and contact information about You to third parties to market their products or services to You. You may opt out of these disclosures by sending written notice using the contact information provided at the end of this Policy or by using controls which may be made available to You within the System from time to time.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MPOWR’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MPOWR about Our users is among the assets transferred.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce Our rights arising from any contracts entered into between You and Us, including the Terms of Service, and for billing and collection.
  • If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of MPOWR, Our customers or others.
  • For any other purpose disclosed by Us when You provide the information.

How We Use Personal Information

We may use Your Personal Information to:

  • Provide You with the features and functionality which comprise the System.
  • Provide the portion of the System whereby a Community Organization and its authorized users may use the System to create, manage, and store information about the individuals they serve, including individuals who maintain an MPOWR Community Account.
  • Develop marketing materials for the System and Our other products.
  • Help Community Organizations promote their products, services, events and posts through the System. We will not directly disclose Your Personal Information for this purpose, but Your Personal Information may be used to determine which users see these promotions based upon a user’s profile or browsing experience.
  • Conduct scientific research, which may be published or shared using de-identified, anonymous, pseudonymized and/or aggregate information.
  • Administer and operate the System and to conduct Our business operations related thereto.
  • Contact You and send You information about the System.
  • Derive analytics about Our System operations and Your preferences.
  • Enforce or protect Our rights or the rights of third parties under applicable contracts or laws.
  • Provide information to Our affiliates, service providers, business partners, or contractors as necessary in connection with any of the foregoing uses.

Security and Data Storage

We will maintain reasonable safeguards designed to promote the security, integrity and privacy of Your Personal Information. However, no electronic storage method, site operation or data transmission over the Internet can be guaranteed to be 100% secure. Using online information services comes with inherent risks to Your privacy and information security. Any information You transmit, view, or receive using the System could be lost or stolen if the internet connection that You use to access the System is not secure, the computer that You use to access the System has been compromised by viruses or other malicious code, or the computer You use to access the System is not properly encrypted or is shared with other people.

We provide the System and store Your Personal Information using a third-party service that We have determined to be a secure provider of data and application hosting services. We may also store portions of Your Personal Information on any device that You use to access the System.

All data that is stored within or transmitted through the System is encrypted at rest and in transit. We do not encrypt Your Personal Information that may be stored or cached on Your personal computer or device, and We strongly recommend that any device You use to access the System be properly encrypted.

The System may, only with Your permission, access the camera, photos, contacts, location services, and microphone on the device You use to access the service. You should consult the operating manual or technical support for Your device to better understand how this works and how You may disable or adjust these settings.

You may access, edit or delete any Personal Information that You have provided to Us through the System using the controls that are provided in Your MPOWR Community Account. Please refer to the support information We provide through the System for more information about how to do these things.

We maintain a written policy that controls Our response to any security incidents that may occur within the System. We also maintain a written policy that requires Us to notify You of any data breach that may occur involving Your Personal Information, and We comply with all applicable laws regarding information security and data breaches.

Data Retention 

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with you. To determine the appropriate retention period for Personal Information, We consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which We process your Personal Information and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

Questions

If You have any questions about MPOWR, the System, or this Policy, You may contact Us at:

MPOWR
Attn: Legal Counsel
303 N. Main Street, Suite 800
Rockford, IL 61101
E-Mail: privacy@mpowr.com