Privacy Policy
Last Updated: 26/06/20
Thank you for choosing to be part of our community at MarkosMarketing.  We are committed to protecting your personal information and your right to privacy.  If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at contact@markosim.com

When you visit out website at www.markosim.com and use our services, you trust us with your personal information.  We take your privacy very seriously.  In this privacy notice, we describer our privacy policy.  We seek to explain to you in the clearest way possible what information we collect, how we use it and what right you have in relation to it.  We hope you take some time to read through it carefully, as it is important.  If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as www.markosim.com and/or any other related websites, services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").
Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.
Table of Contents
01.  What Information Do We Collect?
02.  How Do We Use Your Information?
03.  Will Your Information Be Shared With Anyone?
04.  Do We Use Cookies & Other Tracking Technologies?
05.  What Is Our Stance On Third-Party Websites?
06.  How Long Do We Keep Your Information?
07.  How Do We Keep Your Information Safe?
08.  Do We Collect Information From Minors?
09.  What Are Your Privacy Right?
10.  Controls For Do-Not-Track Features
11.  Do California Residents Have Specific Privacy Rights?
12.  Do We Make Updates To This Policy?
13.  How Can You Contact Use About This Policy?
01.  What Information Do We Collect?
Personal Information You Disclose To Us:

In short: We collect personal information that you provide to use such as name, address, contact information, passwords and security data and payment information.

We collect personal information that you voluntarily provide to use when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use.  The personal information we collect can include the following:

Name and Contact Data.  We collect your first name, last name, email address postal address, phone number and other similar contact data.

Credentials.  We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data.  We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.  All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to use must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected:

In short: Some information - such as IP address and/or browser and device characteristics - is collected automatically when you visit our Sites.

We automatically collect certain information when you visit, use or navigate the Sites.  This information does not reveal your specific identity (like your name or contact information) but may include device usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information.  This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many business, we also collect information trough cookies and similar technologies.

Information Collected From Other Sources:

In short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties.  Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
02.  How Do We Use Your Information?
In short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below.  We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.  We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:
  • To facilitate account creation and logon process. If you choose to link your account with us to a third party account* (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
  • To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.  You can opt-out of our marketing emails at any time (see the "What Are Your Privacy Rights?" below).
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies.
  • Fulfill and manage your orders.  We may use your information to fulfill and manage your orders, payments, returns and exchanges made through the Sites.
  • To post testimonials.  We post testimonials on our Sites that may contain personal information.  Prior to posting a testimonial, we will obtain your consent to use your name and testimonial.  If you wish to update, or delete your testimonial, please contact us at [INSERT YOUR CUSTOM EMAIL ADDRESS HERE] and be sure to include your name, testimonial location, and contact information.
  • Deliver targeted advertising to you.  We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  • Administer prize draws and competitions.  We may use your information to administer prize draws and competitions when you elect to participate in competitions.
  • Request feedback.  We may use your information to request feedback and to contact you about your use of our Sites.
  • To protect our Sites.  We may use your information to request feedback and to contact you about your use of our Sites.
  • To enable user-to-user communications.  We may use your information in order to enable user-to-user communications with each user's content.
  • To enforce our terms, conditions and policies.
  •  To respond to legal requests and prevent harm.​ If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • For other business purposes.  We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our  Sites, products, services, marketing and your experience.
03.  Will Your Information Be Shared With Anyone?
In short: We only share information with your consent, to comply with laws, to protect your rights or to fulfill business obligations.

We may process or share data based on the following legal basis:
  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
  • Vendors, Consultants and Other Third-Party Service Providers: We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.  Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.  We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time.  This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.  Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Third-Party Advertisers: We may use third-party advertising companies to serve ads when you visit the Sites.  These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
  • Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.
  • Other Users: When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Sites, such personal information may be viewed by all users and may be publicly distributed outside the Sites in perpetuity.  Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.
04.  Do We Use Cookies & Other Tracking Technologies?
In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.  Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
05.  What Is Our Stance On Third-Party Websites?
In short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with our websites.

The Sites may contain advertisements from third-parties that are not affiliated with us and which may link to other websites, online services or mobile applications.  We cannot guarantee the safety and privacy of data you provide to third-parties.  Any data collected by third parties is not covered by this privacy policy.  We are not responsible for the content or privacy and security practices and polices of any third parties, including other websites, services or applications that may be linked to or from the Sites.  You should review the policies of such third parties and contact them directly to respond to your questions.
06.  How Long Do We Keep Your Information Safe?
In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).  No purpose in this policy will require us keeping your personal information for longer than 2 years past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
07.  How Do We Keep Your Information Safe?
In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process.  However, please also remember that we cannot guarantee that the internet itself is 100% secure.  Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk.  You should only access the services within a secure environment.
08.  Do We Collect Information From Minors?
In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age.  By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Sites.  If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you become aware of any data we have collected from children under age 18, please contact us at contact@markosim.com
09.  What Are Your Privacy Rights?
In short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.  You may review, change or terminate your account at any time.

In some regions (like the European Economic Area, or EEA), you have certain rights under applicable data protection laws.  These may include the right to (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability.  In certain circumstances, you may also have the right to object to the processing of your personal information.  To make such a request, please use the contact details provided below.  We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.  Please note however that this will not affect the lawfulness of processing before its withdrawal.

If you are a resident in the EEA and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.  You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can do so in one of two ways:

 1. Log into your account setting and update your user account
 2. Send a request to contact@markosim.com

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.  However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and Similar Technologies: Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.  If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites.  To opt-out of interest-based advertising by advertisers on our Sites, visit: http://www.aboutads.info/choices.

Opting Out of Email Marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.  You will then be removed from the marketing email list - however, we will still need to send you service-related emails that are necessary for the administration and use of your account.  To otherwise opt-out, you may:

 - Contact Us using the contact information provided.
10.  Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized.  As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
11.  Do California Residents Have Specific Privacy Rights?
In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning. For example, the definition of “personal information” under the CCPA includes your name, but also more general information such as age. 

Notice of Collection

Although the information we collect is described in greater detail in Sections 1-6 above, the categories of personal information that we have collected – as described by the CCPA – in the past 12 months are:

 - Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.

 - Customer records, billing and shipping address, and credit or debit card information.

 - Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.

 - Commercial information, including purchases and engagement with the Services.

 - Internet activity, including your interactions with our Service. 

 - Audio or visual data, including pictures or videos you post on our Service.

 - Geolocation data, including location enabled services such as WiFi and GPS.

 - Employment and education data, including information you provide when you apply for a job with us.

 - Inferences, including information about your interests, preferences and favorites.

For more information on our collection practices, including the sources we receive information from, please review the different forms of information collected through various means as described in more detail in Sections 1 – 6 above. We collect and use these categories of personal information for the business purposes also described in Sections 1 – 6, as well as our sharing practices described in Section 7.

Right to Know and Delete 

If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

 - The categories of personal information we have collected about you;
 - The categories of sources from which the personal information was collected;
 - The categories of personal information about you we disclosed for a business purpose or sold;
 - The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
 - The business or commercial purpose for collecting or selling the personal information; and
 - The specific pieces of personal information we have collected about you.

To exercise any of these rights, please submit a request through our online form or email us at contact@markosim.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. 

We have a duty as the holder of certain personal information to verify your identity when making requests to know or delete personal information and to ensure that dissemination of that information would not cause harm to you if it were distributed to another person. 

To verify your identity, we will request and collect additional personal information from you to match it against our records. We may ask for additional information or documentation if we feel it is necessary to confirm your identity with the necessary degree of certainty. We may communicate with you through email, a secure message center, or other reasonably necessary and appropriate means. 

We do have the right to deny requests under certain circumstances. In such cases, we will notify you of the reasons for denial. We will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks. In no event will we disclose, if we have collected it, your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

Right to Opt-Out

To the extent we sell your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out of by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by emailing us at contact@markosim.com
Authorized Agent

You may submit a request through a designated agent. You must instruct that agent that they will need to state that they are acting on your behalf when making the request, have reasonably necessary documentation, and be prepared to provide the necessary personal information to identify you in our database.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

Financial Incentives

Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.

We may offer discounted prices to consumers who sign up to be on our mailing lists or join our loyalty programs. Such programs will have additional terms that require your review and agreement. Please review those terms for the details of those programs, how to withdraw or cancel, or to assert your rights specific to those programs.
We generally do not treat consumers differently if they exercise a right under California law. However, in certain circumstances, discounted prices will require you to be on our mailing list or a member of our loyalty program. In such circumstances, we may offer a price difference because the price is reasonably related to the value of your data. The value of your data will be explained in the terms of such incentivized programs.

Shine the Light

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing.

To exercise a Shine the Light request, please contact us at contact@markosim.com or markosmarketing c/o Legal Department , You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via the telephone, email, or by facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information. 

Important Information for Nevada Residents - Your Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us here or email us at [INSERT CUSTOM EMAIL ADDRESS HERE] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
12.  Do We Make Updates To This Policy?
In short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time.  The updated version will be indicated by an updated "Revised" date an the updated version will be effective as soon as it is accessible.  If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
13.  How Can You Contact Us About This Policy?
If you have questions or comments about this policy, you may email us at contact@markosim.com 


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