GDPR Privacy Policy
Effective date: April 05, 2024
Mark Zupo International, LLC (“us”, “we”, or “our”) operates the
http://www.markzupo.com website and the Mark Zupo Coaching mobile application
(The “Service”).
This page informs you of our policies regarding the collection, use, and
disclosure of personal data when you use our Service and the choices you have
associated with that data.
We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy-Policy have the same meanings as in our Terms and Conditions.

Definitions

• Service
  Service means the http://www.markzupo.com website, Mark Zupo Brands, Company, and the Mark Zupo
  Coaching mobile application operated by Mark Zupo International, LLC
• Personal Data
  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).
• Usage Data
  Usage Data is data collected automatically either generated by the use of
  the Service or from the Service infrastructure itself (for example, the
  duration of a page visit).
• Cookies
  Cookies are small pieces of data stored on your device (computer or mobile
  device).
• Data Controller
  Data Controller means the 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 any personal information are, or are to be,
  processed.
  For the purpose of this Privacy Policy, we are a Data Controller of your
  Personal Data.
• Data Processors (or Service Providers)
  Data Processor (or Service Provider) 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.
• Data Subject (or User)
  Data Subject is any living individual who is using our Service and is the
  subject of Personal Data.
  Information Collection and Use
  We collect several different types of information for various purposes to
  provide and improve our Service to you.
  Types of Data Collected
  Name, Address, Phone, Email Addresses, Passwords
  Personal Data
  Name and Address
  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:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City, Country
• Cookies and Usage Data

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 or instructions provided in any email we send.
Usage Data
Time, entry, click-through, opt-in, tracking and usage, cookies
We may also collect information that your browser sends whenever you visit our
Service or when you access the Service by or through a mobile device (“Usage
Data”).
This Usage Data may include information such as your computer’s Internet
Protocol address (e.g. IP address), browser type, browser version, the pages
of our Service that you visit, the time and date of your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may
include information such as the type of mobile device you use, your mobile
device unique ID, the IP address of your mobile device, your mobile operating
system, the type of mobile Internet browser you use, unique device identifiers
and other diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our
Service and hold certain information.
Cookies are files with 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. Tracking technologies also used are beacons, tags, and scripts
to collect and track information and to improve and analyze our Service.
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 Service.

Examples of Cookies We Use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences
  and various settings.
• Security Cookies. We use Security Cookies for security purposes.
  Use of Data
  Mark Zupo International, LLC uses the collected data for various purposes:
• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when
  you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our
  Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• 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
  Legal Basis for Processing Personal Data Under General Data Protection
  Regulation (GDPR)
  If you are from the European Economic Area (EEA), Mark Zupo International, LLC
  legal basis for collecting and using the personal information described in
  this Privacy Policy depends on the Personal Data we collect and the specific
  context in which we collect it.
  Mark Zupo International, LLC may process your Personal Data because:
• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests, and it’s not overridden by
  your rights
• For payment processing purposes
• To comply with the law
  Retention of Data
  Mark Zupo International, LLC will retain your Personal Data only for as long
  as is 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.
  Mark Zupo International, LLC will also retain Usage Data for internal analysis
  purposes. Usage Data is generally retained for a shorter period of time,
  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.
  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 than
  those from your jurisdiction.
  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 United
  States and process it there.
  Your consent to this Privacy Policy followed by your submission of such
  information represents your agreement to that transfer.
  Mark Zupo International, LLC will take all 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.

Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Mark Zupo International, LLC may be required to
disclose your Personal Data if required to do so by law or in response to
valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
Mark Zupo International, LLC may disclose your Personal Data in the good faith
belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Mark Zupo International,
  LLC
• To prevent or investigate possible wrongdoing in connection with the
  Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
  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.
  “Do Not Track” Signals Under California Online Privacy Protection Act
  (CalOPPA)
  We do not support Do Not Track (“DNT”). 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.
  You’re Data Protection Rights Under General Data Protection Regulation (GDPR)
  If you are a resident of the European Economic Area (EEA), you have certain
  data protection rights. Mark Zupo International, LLC aims to take reasonable
  steps to allow you to correct, amend, delete, or limit the use of your
  Personal Data.

If you wish to be informed what Personal Data we hold about you and if you
want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you.
  Whenever made possible, you can access, update or request deletion of your
  Personal Data directly within your account settings section. If you are
  unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information
  rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of
  your Personal Data.
• The right of restriction. You have the right to request that we restrict
  the processing of your personal information.
• The right to data portability. You have the right to be provided with a
  copy of the information we have on you in a structured, machine-readable
  and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your
  consent at any time where Mark Zupo International, LLC relied on your
  consent to process your personal information.
  Please note that we may ask you to verify your identity before responding to
  such requests.
  You have the right to complain to a Data Protection Authority about our
  collection and use of your Personal Data. For more information, please contact
  your local data protection authority in the European Economic Area (EEA).
  Service Providers
  We may employ third party companies and individuals to facilitate our Service
  (“Service Providers”), to provide the Service on our behalf, to perform
  Service-related services or to assist us in analyzing how our Service is used.
  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.
  Analytics
  We may use third-party Service Providers to monitor and analyze the use of our
  Service.
• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks
  and reports website traffic. Google uses the data collected to track and
  monitor the use of our Service. This data is shared with other Google
  services. Google may use the collected data to contextualize and
  personalize the ads of its own advertising network.
  For more information on the privacy practices of Google, please visit the
  Google Privacy & Terms web page:
  https://policies.google.com/privacy?hl=en
  Behavioral Remarketing
  Mark Zupo International, LLC uses 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 Service.
• Twitter
  Twitter remarketing service is provided by Twitter Inc.
  You can opt-out from Twitter’s interest-based ads by following their
  instructions: https://support.twitter.com/articles/20170405
  You can learn more about the privacy practices and policies of Twitter by
  visiting their Privacy Policy page: https://twitter.com/privacy
• Facebook Facebook remarketing service is provided by Facebook Inc.
  You can learn more about interest-based advertising from Facebook by
  visiting this page: https://www.facebook.com/help/164968693837950
  To opt-out from Facebook’s interest-based ads follow these instructions
  from Facebook: <https://www.facebook.com/help/568137493302217
  Facebook adheres to the Self-Regulatory Principles for Online Behavioral
  Advertising established by the Digital Advertising Alliance. You can also
  opt-out from Facebook and other participating companies through the
  Digital Advertising Alliance in the USA
  http://www.aboutads.info/choices/, the Digital Advertising Alliance of
  Canada in Canada http://youradchoices.ca/ or the European Interactive
  Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/,
  or opt-out using your mobile device settings.
  For more information on the privacy practices of Facebook, please visit
  Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
• Pinterest
  Pinterest remarketing service is provided by Pinterest Inc.
  You can opt-out from Pinterest’s interest-based ads by enabling the “Do
  Not Track” functionality of your web browser or by following Pinterest
  instructions:
  You can learn more about the privacy practices and policies of Pinterest
  by visiting their Privacy Policy page:
  Payments
  We may provide paid products and/or services within the Service. In that case,
  we use third-party services for payment processing (e.g. payment processors).
  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 payments
  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.
  The payment processors we work with are:
• Stripe
  Their Privacy Policy can be viewed at https://stripe.com/us/privacy
• PayPal or Braintree
  Their Privacy Policy can be viewed at
  https://www.paypal.com/webapps/mpp/ua/privacy-full
• Square
  Their Privacy Policy can be viewed at
  Links to Other Sites
  Our Service may contain links to other sites 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 site you
  visit.
  We have no control over and assume no responsibility for the content, privacy
  policies or practices of any third-party sites or services.
  Children’s Privacy
  Our Service does not address anyone under the age of 18 (“Children”).
  We do not knowingly collect personally identifiable information from anyone
  under the age of 18. If you are a parent or guardian and you are aware that
  your 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.
  Changes to This Privacy Policy
  We may update our 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 Service, prior
to the change becoming effective and update the “effective date” at the top of
this Privacy Policy.
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.
Contact Us
admin@markzupo.com
If you have any questions about this Privacy Policy, please contact us:

• By email: admin@markzupo.com
• By visiting this page on our website: http://www.markzupo.com