Last revised: April 28, 2018
I. Information MTL Collects
A. Personal Information and Non-Identifying Information We may ask you for personally identifiable information when using the Platform, for example, when registering as a User. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your full name, email address, and any other information that could be used to personally identify you. We also collect other information that you provide as part of registration and the administration and personalization of your account with us that does not identify you (“Non-Identifying Information”). Non-Identifying Information includes, but is not limited to, your zip code (on its own) and individual preferences. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your gender only or your viewing preferences). We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the features and functionality of the Platform, to facilitate and complete transactions for you (including transactions with Vendors that you initiate), and to communicate with you. We may also use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, and for targeting on Facebook. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your account information. We may also combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the quality and value of the Platform, and to analyze and understand how the Platform is used.
B. Usage Data When you visit the Platform, whether you are logged in or just visiting without logging in, our servers automatically record information that your browser or device may send whenever you visit a website or use a similar application or online service. The information sent automatically by your device is referred to as “Usage Data.” This Usage Data may include information such as the manufacturer and model of your device; your Internet Service Provider (ISP); your device’s Internet Protocol (“IP”) address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; Platform access times and dates, pages or areas of the Platform that you visit, the time spent on those pages, and information you search for on the Platform; and other statistics. Usage Data also includes geolocation data. The Platform collects and uses geolocation data to provide you with a better experience, to improve the quality and value of the Platform, and to analyze and understand how the Platform is used. . We use this information for technical administration of the Platform, including to monitor and analyze use of the Platform, to increase the functionality and user-friendliness of the Platform, and to better tailor the Platform to Users’ needs. 2 Usage Data may be non-identifying or it may be associated with you. Whenever we associate Usage Data with Personal Information, we will treat it as Personal Information.
A. Forms We request certain information from you through the use of forms when you register as a User, complete your User profile, initiate a transaction with a Vendor, or communicate with other Users, Vendors, or MTL through the Platform.
C. Usage Data Usage Data are collected automatically by the Platform’s servers and software. For example, because the Platform automatically collects Usage Data for all Users that visit the Platform, your Platform session will be tracked. You agree that we may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to maintain and support the Platform generally. 3 Additionally, in some of our email messages, MTL may use a “click-through URL” linked to content on the Platform. When an User clicks onto one of these URLs, the User will pass through our server before arriving at the destination Web page. MTL tracks this click-through data to help us determine User interest in certain subject matter and measure the effectiveness of these User communications. You can avoid being tracked in this way by not clicking text or graphic links in emails from MTL. Finally, we may use clear gifs or pixel tags, which are tiny graphic images, in order: (i) to advise us of what parts of the Platform Users have visited, (ii) to measure the effectiveness of any searches Users perform, and (iii) to enable us to send emails in a format that Users can read and tell us whether such emails have been opened in order to ensure us that we are sending messages that are of interest to Users.
D. Tracking Some Web browsers may be configured to send Do Not Track signals to Platforms, or Users may use similar mechanisms, to indicate a User’s preference that certain web technologies not be used to track the User’s online activity. The Platform does not accept or process such Do Not Track signals or similar mechanisms.
E. Public Communications Please note that if you use any bulletin board, chat room, comment posting feature, or other public communication service, forum, or feature offered through the Platform, or post any information available for viewing by other Users, any of the information that you share will be visible to other Users. The information that you make available can be read, used, and collected by other Users to send you unsolicited messages outside of the Platform. MTL is not responsible for the manner in which the Personal Information that you decide to share will be used by other Users.
III. Use and Sharing of Information by MTL The User information that MTL collects may be added to our databases and used for business purposes, including for marketing and promotional purposes, for a statistical analysis of Users’ behavior, for product development, for content improvement, or to customize the content and layout of the Platform. In addition, MTL will, on occasion, send emails to you about the Platform or third-party products. If you do not want to receive email from us, visit the “Opt Out” or “Unsubscribe” link at the bottom of any MTL email to remove yourself from continued receipt of such email messages. MTL’ policy is not to share the User information it collects with third parties other than as specified below, or where an User expressly consents to our sharing of certain information with a third party. We may share User information with third parties under the following circumstances:
C. Business Transfers As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about Users generally is often a transferred business asset. In the event that MTL itself or substantially all of MTL’ assets are acquired, information about our Users may be one of the transferred assets.
D. Compliance with Law and Protection of MTL and Others We may release User information when we believe, in our sole discretion, that release is appropriate: to comply with the law, including but not limited to, in response to a subpoena served on MTL; to enforce or apply the Agreement, including the Platform Terms and Conditions and other applicable agreements, rules, and policies; to protect the rights, property, or safety of MTL, our Users, or others; or to prevent activity that we believe, in our sole discretion, may be or may become illegal, unethical, or legally actionable (including exchanging User information with other companies and organizations for fraud protection).
E. Aggregate Site Use Information We may release aggregate User information (without revealing any Personal Information about you) to advertisers and other third parties in order to promote or describe use of the Platform.
V. Changing or Deleting Your Information All Users who have created an account on the Platform may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law or for legitimate business purposes.
VI. Security We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. For example, we use commercially reasonable security measures such as encryption and firewalls to protect User information. Please note that no security system is impenetrable. Accordingly, we do not guarantee the security of our databases, nor that information you supply won't be intercepted while being transmitted to us over the Internet or other network. Any information you transmit to MTL, you do at your own risk. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting through the Platform in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
VII. Children’s Privacy We are committed to protecting the privacy of children. Users must be at least thirteen (13) years of age to access and use the Platform. Any access to or use of the Platform by anyone under the age of thirteen (13) is unauthorized, unlicensed, and in violation of the Agreement. By using the Platform, you represent and warrant that you are thirteen (13) years of age or older and 6 that you agree to and agree to abide by all of the terms and conditions of the Agreement. If MTL believes that you are under the age of thirteen (13) or that you are not old enough to consent to and be legally bound by the Agreement, MTL may, at any time, in its sole discretion, and with or without notice: (i) terminate your access to or use of the Platform (or any portion, aspect, or feature of them), or (ii) delete any content or information that you have posted through the Platform.