Privacy Policy

Effective Date: January 1, 2025

Mbira Technologies LLC respects the privacy of our website visitors and customers. We believe it is important that you understand the kinds of data we collect about you, how we protect that data, and how it is used. We recognize the need for appropriate safeguards and management of Personal Information you provide to us. This Privacy Policy (“Policy”) sets forth the privacy principles Mbira Technologies follows with respect to your Personal Information we collect from or about you, either online through this website, or any of the products, services, interactive features, forms, social media pages offered, owned, or operated by Mbira Technologies, or its affiliates, or your interaction with Mbira Technologies service providers, contractors or employees (collectively “Services”), whether accessed online via computer, tablet, mobile device or any other technology or device now known or hereafter developed, or offline, and how your Personal Information will be used. The Services are intended for use by individuals residing and located in the United States.

When we reference “Personal Information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly. Personal Information does not include information that cannot be reasonably linked to you.

This Policy covers all Personal Information (information that relates to or that can be used to identify you) by Mbira Technologies at its website https://www.mbira.com (the “Site”). This Policy does not describe information collection policies and practices of websites and platforms that we do not provide, own, or control, including those linked to or integrated with our Site. It also does not cover information you may choose to share with other users of the Site. We encourage you to review this Policy periodically. Your use of the Site constitutes your consent to the terms contained herein. We will periodically update this Policy, and any changes will be reflected here. We will notify existing customers of any material changes by email or via your account.

If you have any questions about this Policy or how we use your Personal Information, please feel free to contact us at contact@mbira.com.

Contents

What Personal Information Do We Collect and Why?

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When you use the Mbira Technologies Site, we may collect Personal Information you voluntarily share with us, including:

Please be aware we may also use your Personal Information:

The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The retention duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations for rights. Please see Your California Privacy Rights below for more information.

Your Choices

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You may choose not to provide us with any Personal Information. In such an event, you may still be able to access and use some portion of the Site; however, you may not be able to access and use those portions that require your Personal Information.

Children’s Information

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The Site is not directed to children under the age of 18. We do not knowingly collect any personal information from children under the age of 18. If we learn that a child under the age of 18 has provided us with personal information, or that such personal information has otherwise been inadvertently collected, we will delete it in accordance with applicable law.

Who Do We Share Your Information with?

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We will not share your Personal Information with anyone outside Mbira Technologies. However, we may disclose information about you to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion our assets. The successor organization’s use and disclosure of your personally-identifiable information will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your Personal Information will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use our Services). If you submit Personal Information after such a transfer, that information may be subject to the successor entity’s policy.

Third-Party Sites

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The Mbira Technologies Site may contain links to other sites, such as LinkedIn. Please be aware that Mbira Technologies is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave the Site and to read the privacy statements of each and every website. This Privacy Policy applies solely to information collected by the Mbira Technologies Site.

Security

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To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Personal Information, we utilize industry standard physical, technical, and administrative controls and procedures to safeguard the information we collect. However, you should recognize there is always some risk involved in the transmission of information over the internet or in a method of electronic storage.

Consent to Transfer

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The Mbira Technologies Site is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our Site, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

U.S. State Privacy Rights

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Disclosure of Personal Information

We disclose personal information to our service providers and contractors, as described in this Privacy Policy.

Mbira Technologies does not and will not sell the Personal Information of consumers. In the preceding twelve (12) months, Mbira Technologies has not sold Personal Information.

Your Rights and Choices

This United States (U.S.) Privacy Notice (“Notice”) is for people living in the United States and supplements our Mbira Technologies Privacy Policy, which explains how we collect, use, and disclose your Personal Information.

This Notice describes your privacy rights and how to exercise your rights under the U.S. state privacy laws (including, but not limited to the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Delaware Personal Data Privacy Act (“DPDPA”), Iowa Consumer Data Protection Act (“ICDPA”), Maryland Online Data Privacy Act (“MODPA”), Minnesota Consumer Data Privacy Act (“MCPA”), Montana Consumer Data Privacy Act (“MCDPA”), Nebraska Data Privacy Act (“NDPA”), New Hampshire Privacy Act (“NHPA”), New Jersey Data Privacy Act (“NJDPA”), Oregon Consumer Privacy Act (“OCPA”), Tennessee Information Protection Act (“TIPA”), Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (“UCPA”), and Virginia Consumer Data Protection Act (“VCDPA”)). We call those laws collectively the “U.S. Privacy Laws.” For California Privacy Rights, please refer to Your California Privacy Rights below.

If you are a resident of a state that has laws that govern our processing of your Personal Information, you may have certain rights, as provided under the state law applicable to you, subject to certain exemptions, which may include the:

Additional Privacy Rights

California. California residents may have additional personal information rights. Please see Your California Privacy Rights below for more information.

Nevada. Nevada residents have certain privacy rights as specified under Nevada law. Our Privacy Policy and the privacy controls we offer to all users are in line with these laws—this notice assures we cover the Nevada-specific requirements.

Do Not Sell Notice: We do not sell your covered information, as defined under Chapter 603A of the Nevada Revised Statutes. If you still have questions about your covered information or anything else in our Privacy Policy, please contact us using the contact information below.

Your California Privacy Rights

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Effective Date: January 1, 2020

Amendment Effective Date: January 1, 2023

This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the Mbira Technologies Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA or CPRA have the same meaning when used in this Notice.

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA, as amended by the CPRA, rights and explains how to exercise those rights.

Right to Access Your Information

You have the right to request that Mbira Technologies disclose what Personal Information we have collected used or disclosed over the past 12 months.

Right to Request Deletion

You have the right to request that Mbira Technologies delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Consumer Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Right to Opt-Out

You have the right to opt-out of:

Right to Access Information About Automated Decision Making

You have the right to request that Mbira Technologies provide information about the logic involved in automated decision-making and a description of the likely outcome of the process.

Right to Correct Information

You have the right to request that Mbira Technologies correct your Personal Information if it is inaccurate.

Right to Limit Sensitive Personal Information

You have the right to limit Mbira Technologies’ use and disclosure of sensitive Personal Information to information that is necessary to perform the services or provide the goods reasonable expected by an average consumer who requests such goods and services.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA, as amended by the CPRA, rights.

Other California Privacy Rights

California’s "Shine the Light" law (Civil Code § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.

Exercising Your Rights

You or your authorized agent may submit a request to exercise your rights by going to this web form or calling us at 1-833-508-3301. For your security and to ensure unauthorized third parties do not access your Personal Information, we will require you to verify your identity before we can act on your request. If you are a current customer or still have access to your Mbira Technologies account, you will be required to authenticate through your Mbira Technologies account. If you do not have an account with us, you will be required to provide an email address and mobile phone number to start the verification process. You may also be required to provide a qualified government-issued photo identification. If you are asking for access on behalf of someone else, we will require verification of your identity, as well as proof of authorization by the individual whose Personal Information you wish to access.

Authorized Agents

If you are a resident of a state that has laws that govern our processing of your Personal Information and would like to designate an authorized agent to submit certain requests on your behalf, or if you are an authorized agent of an individual with the right to submit certain requests via an authorized agent and would like to submit a request on behalf of that individual, please send an email to the following email address: contact@mbira.com [insert mail-to link].

If you are the resident, in order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such request. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you are the authorized agent, after you submit the request, and if the request is not subject to an exemption or exception, we will require additional information to verify the identity of the resident, as well as your authority to act on behalf of the resident.

Appeals

If we did not take action on your request, and if you are a resident of a state that offers a right to an appeal, you may have the right to appeal our decision. To submit an appeal, use this web form. Please note that an appeal must be submitted within 60 days of your receipt of the notice to take action.

Right to Modify this Privacy Policy

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We reserve the right to modify this Privacy Policy at any time at our sole discretion. If we modify the Privacy Policy, we will post the revised Policy here, with an updated revision date. Changes will be effective immediately (except for material changes) upon the posting of the revised Privacy Policy on the Site. In the event we make material changes to this Privacy Policy, we will notify you through the Services prior to the changes taking effect. Please note that if you do not agree to the modified Privacy Policy, you may not use the Services. Your continued use of the Services following the posting of the changes or any applicable notice period will mean that you accept those changes.

Contact Us

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If you have any questions or comments about this Policy, the practices or use of the Site, please feel free to contact us by phone at +1 833-508-3301; by email at contact@mbira.com; or by mail to the following address:

8 Thornton Road, Oakland, NJ 07436, Attn: Privacy Office

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