Welcome to MOGUL! MOGUL Inc. (“MOGUL,” “we,” “us” and/or “our”) operates the websites located at www.onmogul.com, recruiter.onmogul.com, and related mobile applications, extensions and services (the “Service”) to enable users (“users,” “you,” “your”) to connect to share information and access content related to and in support of women, minorities, veterans, and people with disabilities and their lifestyles. This Privacy Policy describes how MOGUL collects, uses and discloses information from users of our Service, including personally identifiable data (“Personal Data”). Please note that the use of information received from Google APIs will adhere to the Chrome Web Store User Data Policy, including the Limited Use requirements.
Please be sure to read this entire Privacy Policy before using or submitting information through our Service. By using or submitting information through our Service, you are indicating that you agree to be bound by the terms of this Privacy Policy. This Privacy Policy is incorporated by reference into MOGUL’s Terms of Service.
When you interact with us through the Service, we may collect Personal Data and other information from you, as further described below:
Personal Data That You Provide Through the Service: We collect Personal Data from you when you voluntarily provide such information to us, such as when you contact us with inquiries; respond to one of our surveys; register for an account with or access to the Service; request to be placed on mailing lists or receive newsletters; participate in promotions, sweepstakes or contests; become a MOGUL Influencer; purchase products or services from us; or otherwise use certain features of the Service. When you register for an account with MOGUL, you must provide us with a username, email address and password. You also have the option of providing additional information in your account profile or in connection with certain features of the Service, including but not limited to your name, interests, biographical and career information, geographic location, age, gender, payment method information, address, mobile telephone number and links to your social media pages. Wherever MOGUL collects Personal Data, we make an effort to provide a link to this Privacy Policy.
User Content: We collect and store information that you and other users upload, post, submit, publish, transmit, display or otherwise share through the Service (“User Content”). You acknowledge and agree that, to the extent that you include Personal Data in User Content, such Personal Data will be public, and we are not responsible for how others may use it. Please use caution and common sense when sharing or posting User Content.
You can remove User Content that you have previously posted from publicly viewable areas of the Service by deleting it. If you have difficulty deleting any of your User Content for any reason, please contact us at legal@onmogul.com so that we may remove the applicable content at your request. You understand that such content may remain on publicly viewable areas of the Service if other users have posted or reposted it, and that your User Content may remain on our servers or in our records after it is no longer viewable by other users of the Service.
Data You Provide about Others: We may also collect and store information about others that you provide to us through your use of the Service, such as when you share User Content with others through email or social media websites and services. For more information on the data we share with and receive from social media websites and services, see the section titled “Social Networking Services” below.
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. You represent that the Personal Data you provide is true, accurate, current and complete, and that you have the authorization to provide it to us. If you provide Personal Data to the Service, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of MOGUL and the authorized third parties referred to herein located in the United States.
IP Addresses; Device ID Information: The requests you make to MOGUL may contain your IP address (the Internet address of your computer). We may use users’ IP addresses for various purposes, including to display customized content and analyze and report upon usage of the Service; to diagnose and prevent service or technology problems affecting the Service; and to monitor and prevent fraud and abuse. We do not link your IP address to any Personal Data unless you are logged in to your MOGUL account. If you access our Service on a mobile device, we may also collect your device identification number and request access to settings and location information for similar purposes and to personalize your experience with the Service.
Location Information: We may collect, use and share your location information to provide certain functionality, content or promotional material with location-based components. Location information includes, but is not limited to, any information we derive in order to identify your geographic position. We collect location information when you provide it to us directly in your account profile or in connection with purchases you make on or through the Service; we may also collect location information from the computer or mobile device you use to access the Service or through connected Social Networking Services, your wireless carrier or certain third-party service providers. The collection and tracking of your location information may occur even when the Service, including any mobile application, is not actively open and running.
We may also use your location information in an aggregate way, as described below in the “Aggregated Personal Data” section.
You can control the location information that is displayed and shared with other MOGUL users by changing your account’s privacy settings. You can also change the privacy settings of your mobile device to turn off the functionality to share location information with the Service. Please note that turning off location sharing may affect certain features of the Service. If you have any questions about the privacy settings of your mobile device, we recommend that you contact the manufacturer or your mobile service provider for assistance.
Non-Identifiable Data: When you interact with MOGUL through the Service, we and third parties that may provide certain functionality on the Service, such as social media or advertising networks, use various technologies to passively collect information that cannot by itself be used to specifically identify you (“non-identifiable data”). MOGUL may store such information itself or such information may be included in databases owned and maintained by MOGUL affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of users on the Service, the number of users on each page of our website and the domain names of our users' Internet service providers.
In operating and providing the Service, we use technologies called "cookies" and “web beacons.” A cookie is a piece of information that the computer that hosts our Service gives to your browser when you access the Service. Our cookies help us provide additional functionality to the Service; personalize your experience with the Service; and analyze Service usage more accurately for research, advertising and marketing purposes. For instance, we may set a cookie on your browser that allows you to access our website without needing to remember and then enter a password more than once during a visit to the website. We use web beacons (also known as “clear GIFs”) to measure site traffic and related browsing behavior and to improve your experience when using our Service. We may also use customized links or other similar technologies to track hyperlinks that you click and associate that information with your Personal Data in order to provide you with more focused communications. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service’s features.
We may collect certain data in order to enable recognition and provide faster search response time. We may also use Google Analytics and similar tools to help analyze how users use our Service. Google Analytics uses cookies to collect standard Internet log-in information and user behavior information. The information generated by the cookie about your use of our Service (including IP address) is transmitted to and stored by Google. This information is then used to evaluate users' engagement of our Service, compile statistical reports on activity on the Service and enhance your experience when you use the Service. Google will not associate your IP address with any other data held by Google. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
Response to “Do Not Track” Signals: At present, we do not respond to “do not track” signals sent from web browsers. If we do so in the future, we will provide all relevant information in this policy.
This Privacy Policy covers the use of cookies, web beacons, and similar files by MOGUL only. Uses of these technologies by any third-party advertiser or website linked from the Service, including third parties with which we partner, are governed by each such advertiser or website’s privacy policy.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Service, MOGUL conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and MOGUL may share this aggregate data with its affiliates, agents and business partners or otherwise use it for any lawful purpose. This aggregate information does not identify you personally. MOGUL may also disclose aggregated user statistics in order to describe our Service to current and prospective business partners and to other third parties for other lawful purposes.
Our Use of Your Personal Data and Other Information: MOGUL uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email to ask us a question or report an issue with the Service, we will use the Personal Data you provide to answer your question or resolve the issue. If you provide us with payment, billing and shipping information in connection with your purchase of products or services on or through MOGUL, we will use and store your payment, billing and shipping information to facilitate current and future transactions. We are use a third party payment processor to process payment transactions. If you provide Personal Data in order to obtain access to the Service, we will use your Personal Data to provide you with access to and monitor your use of the Service. MOGUL and its subsidiaries and affiliates (the “MOGUL Related Companies”) may also use your Personal Data and non-identifiable data collected through the Service to help us improve the content and functionality of the Service, to better understand our users and to improve the Service.
Marketing: MOGUL and its affiliates and partners may use your Personal Data and other information to communicate with you by email, text message or push notification to provide you with information about content, features, opportunities, and promotions available through the Service that we think may be of interest to you. We will send such messages only with your consent, which we will ask you for when you register for your MOGUL account. You may opt out of marketing emails or messages from us at any time by following the instructions in the email or message describing how to "opt-out" of receiving future communications or sending an “UNSUBSCRIBE” message in reply.
CAN-SPAM Act: The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will: (a) not use false or misleading subjects or email addresses; (b) identify the email message as an advertisement in some reasonable way; (c) include the physical address of MOGUL Inc., which is 163 Amsterdam Avenue #1424, New York, NY 10023; (d) monitor third-party email marketing services for compliance, if one is used; (e) honor opt-out/unsubscribe requests quickly; and (f) give an “opt-out” or “unsubscribe” option.
If MOGUL intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.
We consider your information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Certain Business Partners: When we partner with other businesses to provide content or services, offer promotions, sponsor sweepstakes or contests or display advertisements related to your interests through the Service, we may share relevant Personal Data with these partners in connection with providing such services or features. For example, we may share your contact information with a business partner that is hosting a networking event in your area if you have indicated interest in participating in such events.
Recruiters: We may develop a recruiter service to enable our users to gain valuable exposure in their career searches. Recruiters will be able to export limited information from users’ account profiles, such as users’ name, title and general geographic location, in order to manage candidate sourcing effectively. We will not provide contact information or resumés of Mogul Members (whether Free, Premium or Board Memberships) directly to recruiters unless you upload or submit such information in response to a job posting or otherwise indicate that you would like for us to do so. Any information from or about you obtained independently by a recruiter is governed by the privacy policy of such recruiter.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We cannot control how an acquiring or surviving entity may use or disclose such information.
Related Companies: We may also share your Personal Data with the MOGUL Related Companies for purposes consistent with this Privacy Policy.
Agents, Consultants, Vendors and Service Providers: MOGUL, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, providing marketing assistance, providing search results and links (including paid listings and links), processing payments and performing customer service. When we employ another company to perform a function of this nature, we only provide such company with the information needed to perform its specific function. In addition, we require such companies to whom we disclose your information to be under contractual obligations to keep such information confidential and to use such information only for the purposes for which we disclose it. MOGUL will take commercially reasonable measures to ensure that such companies do not use your information for any other purposes.
As Required by Law and Similar Disclosures: MOGUL may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of MOGUL, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public or (iv) protect against legal liability.
With Your Consent: We may also disclose your Personal Data with your permission.
Non-Personally Identifiable Information: We may disclose depersonalized, aggregated information about our users that does not identify any individual without restriction.
We do not sell, trade, or otherwise transfer your Personal Data to outside parties except as set forth in this Privacy Policy, unless we provide you with advance notice.
Your Choices: You can use the Service without providing any Personal Data or registering for an account. If you choose not to provide any Personal Data, you may not be able to use certain features of the Service.
Exclusions: This Privacy Policy shall not apply to any unsolicited information you provide to MOGUL through the Service or through any other means. This includes, but is not limited to, information posted to any public areas of the Service, such as comment sections (collectively, “Public Areas”), any ideas for new products or services or modifications to existing products or services, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and MOGUL shall be free to reproduce, use, disclose and distribute such Unsolicited Information to others without limitation or attribution.
Children: The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Site and Service are not meant for use by children under 13 years old. In addition, our Site and Service do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13 years of age. MOGUL does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Site or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on the Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to MOGUL through the Service, please contact us at legal@onmogul.com, and we will endeavor to delete that information from our databases.
Links to Other Websites: This Privacy Policy applies only to the Service. The Service may contain links to other websites not operated or controlled by MOGUL (the “Third-Party Sites”). The policies and procedures we describe here do not apply to the Third-Party Sites. The links from the Service do not imply that MOGUL endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Social Networking Services: Through the Service, we may offer you the opportunity to access certain social media and social networking websites and services that are owned and/or controlled by third parties (including, without limitation, Facebook and Twitter) (such websites and services, collectively, the “Social Networking Services”). When you elect to access and use the Social Networking Services, you will be sharing your information (which will include Personal Data, if you elect to provide us with such information) with those Social Networking Services. As with other Third-Party Sites, the information that you share with each Social Networking Service will be governed by the privacy policies and terms of service of the providers of such Social Networking Services and not by the policies and procedures we describe here. You may also be able to modify your privacy settings with the Social Networking Services to, for example, control what information the Social Networking Services disclose to other entities, including MOGUL. When you log into the Service using a Social Networking Service account or otherwise link your MOGUL account with a Social Networking Service account, we will collect relevant information necessary to enable the Service to access that Social Networking Service; however, you will provide any login information, like your password, directly to such Social Networking Service (and not to MOGUL). As part of such integration, the Social Networking Service will provide MOGUL with access to certain information that you have provided to such Social Networking Service and information about your use of such Social Networking Service, such as your profile picture and friends list. We will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Networking Service. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of the applicable Social Networking Service provider, and, as a result, MOGUL shall not have any liability or responsibility for the privacy practices or other actions of Social Networking Services that may be enabled within and/or otherwise accessible through the Service.
Security: MOGUL takes reasonable steps to protect the Personal Data you provide via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Specifically, we use Secured Sockets Layer (SSL) encryption and a web application firewall (WAF) when collecting, storing, or transferring Personal Data. Our Site also receives regular security scans, penetration tests, and malware scans. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register on our Site, or (d) access our Site. Personal Data is stored in password-controlled servers with limited access. However, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to MOGUL via the Internet. We do not accept liability for unintentional disclosure.
By using the Service or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we will notify you electronically by posting a notice on the Service or by sending an email to you within 48 hours of MOGUL becoming aware of such breach. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at legal@onmogul.com.
Fair Information Practice Principles: We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
International Users: All Personal Data is stored on servers in the United States and is subject to United States law. Our servers are currently hosted by Heroku. We reserve the right to use any reputable hosting service at our sole discretion. By choosing to use the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with MOGUL or the Service be in accordance with the Terms of Service.
If you are accessing from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and the global processing of such information. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.
Other Terms and Conditions: Your access to and use of the Service is subject to the Terms of Service .
Changes to MOGUL’s Privacy Policy: The Service and our business may change from time to time. As a result, at times it may be necessary for MOGUL to make changes to this Privacy Policy. MOGUL reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. The updated Privacy Policy will be provided on our Site. Please review our Privacy Policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Service after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
New Uses of Personal Data: From time to time, we may desire to use Personal Data for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.
Your California Privacy Rights: Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us at legal@onmogul.com. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
California Consumer Privacy Act: This Section supplements the information contained in our Privacy Policy above and applies solely to all users, and others who may access our Site, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section.
We require such Personal Information to be able to provide you with our Services.
Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.
We are headquartered in the State of New York in the United States and our operations are located in the United States. Your Personal Information, which you give to us during registration or use of our Site or Services, may be accessed by or transferred to us in the United States. If you are visiting our Site or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our Site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.
The data importer agrees and warrants:
The data exporter agrees and warrants:
You may keep your Personal Data accurate, current and complete by logging into your account and reviewing and updating your information. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Service.
Please feel free to contact us if you have any questions about MOGUL’s Privacy Policy or the information practices of the Service.
You may contact us by emailing legal@onomgul.com.