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Mirabela Inc.

www.mirabela.net

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PRIVACY POLICY

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1. Introduction

Welcome to Mirabela Inc. [

Mirabela Inc. (“us”, “we”, or “our”) operates www.mirabela.net (hereinafter referred to as our “Website” or “Service”).

Our Privacy Policy governs your visit to mirabela.net, and explains how we collect, safeguard and disclose information that results from your use of our Service.

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We use your data to provide and improve our Website. By using our Website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service, found elsewhere on our Website.

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Our Terms of Service (“Terms”) govern all use of our Service and together with this Privacy Policy constitutes your agreement with us (“Agreement”).

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2. Definitions

“SERVICE” or “Website” means the mirabela.net website operated by Mirabela Inc.

“PERSONAL DATA” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

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“USAGE DATA” is data collected automatically, either generated by your use of Service or from Service infrastructure itself (for example, the duration of a page visit).

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“COOKIES” are small files stored on your device (computer or mobile device).

“DATA CONTROLLER” means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, Personal Data are, or are to be, processed. For this Privacy Policy, we are a Data Controller of your data.

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“DATA PROCESSORS” (or “SERVICE PROVIDERS”) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

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“DATA SUBJECT” is any living individual who is the subject of Personal Data.

The “USER” is the individual using our Service. The User corresponds to the Data Subject who is the subject of Personal Data.

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3. Information Collection and Use

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We collect several different types of information for various purposes to provide and improve our Service to you.

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4. Types of Data Collected

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Personal Data

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While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

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-- 0.1. Email address

-- 0.2. First name and last name

-- 0.3. Phone number

-- 0.4. Address, Country, State, Province, ZIP/Postal code, City

-- 0.5. Cookies and Usage Data

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We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the “Unsubscribe” link at admin@mirabela.net.

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Usage Data

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We may collect information that your browser sends whenever you visit our Website or when you access our Service by or through any device (“Usage Data”).

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This Usage Data may include information such as your computer’s Internet Protocol address (i.e., IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

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When you access our Website with your device, this Usage Data may include information such as the type of device you use, your device’s unique ID, the IP address of your device, your device’s operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

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Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, and to improve and customize our Website.

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You can enable or disable location services when you use our Service at any time by using your particular device’s settings.

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Tracking Cookies Data

We use cookies and similar tracking technologies to track your activity on our Website, and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

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You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

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Examples of Cookies we use:

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-- 0.1. Session Cookies: We use Session Cookies to track your activity on our Website.

-- 0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

-- 0.3. Security Cookies: We use Security Cookies for security purposes.

-- 0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

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Other Data

While you are using our Website, we may also collect the following information about you: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security number (or other taxpayer identification), office location and other data.

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5. Use of Data

Mirabela Inc. uses the collected data for various purposes:

-- 0.1. to provide and maintain our Website;

-- 0.2. to notify you about changes to our Website;

-- 0.3. to allow you to participate in interactive features of our Service when you choose to do so;

-- 0.4. to provide customer support;

-- 0.5. to gather analysis or valuable information so that we can improve our Website;

-- 0.6. to monitor the usage of our Website;

-- 0.7. to detect, prevent and address technical issues;

-- 0.8. to fulfil any other purpose for which you provide it;

-- 0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

-- 0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

-- 0.11. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information;

-- 0.12. in any other way we may describe when you provide the information;

-- 0.13. for any other purpose with your consent.

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6. Retention of Data

We will retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

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7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

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If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

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Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Mirabela Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy; and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

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8. Disclosure of Data

We may disclose personal information that we collect or you provide, as follows:

  • 0.1. Disclosure for Law Enforcement. -- Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

 

  • 0.2. Business Transaction. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

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We may also disclose your information:

-- 0.3.1. to our subsidiaries and affiliates;

-- 0.3.2. to contractors, service providers, and other third parties we use to support our business;

-- 0.3.3. to fulfill the purpose for which you provide it;

-- 0.3.4. for any other purpose disclosed by us when you provide the information;

-- 0.3.5. with your consent in any other cases;

-- 0.3.6. if we believe in our business discretion that disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

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9. Security of Data

The security of your data is important to us; but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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10. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a Privacy Policy like this. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably anywhere in the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous Privacy Policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

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Pursuant to CalOPPA, Mirabela Inc. agrees to the following:

-- 0.1. users can visit our Website anonymously;

-- 0.2. our Privacy Policy link includes the word “Privacy”, and can easily be found from the home page of our Website;

-- 0.3. users will be notified of any privacy policy changes on our Privacy Policy page;

-- 0.4. users are able to change their personal information by emailing us at admin@mirabela.net.

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Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.

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11. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us the following:

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What personal information we have about you. If you make this request, we will return to you:

-- 0.0.1. The categories of personal information we have collected about you.

-- 0.0.2. The categories of sources from which we collect your personal information.

-- 0.0.3. The business or commercial purpose for collecting or selling your personal information.

-- 0.0.4. The categories of third parties with whom we share personal information.

-- 0.0.5. The specific pieces of personal information we have collected about you.

-- 0.0.6. A list of categories of your personal information that we have sold, along with the category of any entity we sold it to. If we have not sold your personal information, we will inform you of that fact.

-- 0.0.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any entity we shared it with.

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[Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.]

You may also request:

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-- 0.1. To delete your personal information. If you make this request, we will delete your personal information from our records as of the date of your request and direct any of our service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

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-- 0.2. To stop selling your personal information. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary compensation. However, under some circumstances, a transfer of personal information to a third party without monetary compensation, or within our family of companies and/or affiliates, may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time. If you submit a request to stop “selling” your personal information, we will stop making such transfers.

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Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances will we discriminate against you for exercising your rights.

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To exercise your California data protection rights described above, please send your request(s) by email: admin@mirabela.net.

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

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12. Service Providers

We may engage third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

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These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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13. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

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14. CI/CD tools

We may use third-party Service Providers to automate the development process of our Website.

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15. Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Websites.

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16. Behavioral Remarketing

We may use remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Website.

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17. Payments

We may provide paid products and/or services within our Website. In that case, we use third-party services for payment processing (e.g. payment processors).

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We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

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18. Accounts

When you create an account with us, you guarantee that you are above the age of 18, and that the information you provide us with is accurate, complete and current. You are responsible for maintaining and the confidentiality of your account and password. Inaccurate information or action may result in the termination of your account.

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19. Links to Other Sites

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every website you visit.

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We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

 

20. Children’s Privacy

Our Services are not intended for use by minors under the age of 18 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

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21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Website, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

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You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page, and your continued use of our Website after we post these changes signifies your agreement with our revised Policy.

 

22. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: admin@mirabela.net.

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