MSX International LMS
PRIVACY POLICY

 Last Updated 10/27/2022

Your privacy is important to MSXI, Inc. ("MSXI", “we”, “us” or “our”). This Privacy Policy explains how MSXI collects, uses, shares and endeavors to protect your information. MSXI reserves the right to change this Privacy Policy from time to time, and such changes will be effective immediately upon posting to this website. We suggest periodically visiting this page to review our policy.

This Privacy Policy applies when information from and about individuals is collected from any user of or visitor to the MSXI LMS.

This Privacy Policy explains the privacy practices of MSXI including: (1) the personal information we collect and how it is used; (2) how MSXI uses “cookies” and automatic information gathering technologies; (3) what kind of security measures MSXI takes to protect your information; (4) your rights and choices; and (5) additional information for residents of California, Nevada, or Canada.

INFORMATION WE COLLECT AND HOW WE USE IT

CONSENT TO COLLECTION OF PERSONAL INFORMATION

By accessing or using the LMS, you consent to our collection and use of your Personal Information (as defined below) in a manner that is consistent within applicable law and this Privacy Policy, as well as our User Agreement. Your continued use of the LMS indicates you consent to the Privacy Policy posted, if you do not agree, you agree to not access or use the LMS. Information gathered through the LMS may be transferred, used, and stored in the United States or in other countries where our service providers or MSXI is located. If you use the LMS, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the LMS or MSXI are deemed to occur in the United States, where MSXI’s servers are located.

COLLECTION OF USER’S PERSONAL INFORMATION AND OTHER INFORMATION

When you register for, or use the LMS, MSXI collects Personal Information. By “Personal Information,” this means information that can identify or reasonable be linked to an individual, such as:

• Names;
• Business addresses;
• Email addresses; and
• Phone numbers

You may choose not to provide Personal Information, but this will prevent you from receiving access to certain features of the LMS.

MSXI also collects non-Personal Information relating to the LMS, that is, information that does not personally identify an individual (“Non-Personal Information”). The Non-Personal Information MSXI collects include how you interact with the LMS, information generally collected or “logged” by internet websites or internet service you have access or used, and information about your web browser or device accessing or using the LMS.

Examples of the Non-Personal Information that MSXI collects are:

• The pages of our website that you viewed during a visit;
• What information, content or advertisements that you view or interact with using the LMS;
• Language preferences;
• The city and state in which you are located (but not your precise geographic location); and
• Unique identifiers that are not connected and cannot reasonably be connected to your identity.

MSXI will not use Non-Personal Information to try to identify you, and if MSXI associates any Non-Personal Information with information that personally identifies you, then MSXI will treat it as Personal Information. As discussed in more detail below, MSXI sometimes uses cookies and other automatic information gathering technologies to collect Non-Personal Information.

Information collected by the LMS may be collected by MSXI or one of MSXI’s Service Providers (as defined below) or Online Tool Providers (as defined below).

USE OF USERS INFORMATION

MSXI may use the information it collects to

• Assist MSXI in providing, maintaining, and protecting the LMS;
• Setup, maintain and protect accounts to use the LMS;
• Improve MSXI’s online operations;
• Process transactions;
• Provide customer service;
• Communicate with you, such as provide you with account or transaction related communications, or other newsletters, RSS feeds, and/or other communications relating to the LMS;
• Send or display offers and other content that is customized to your interests or preferences;
• Perform research and analysis aimed at improving MSXI’s products and services and developing new products or services; and
• Manage and maintain the systems that provide the LMS.

DISCLOSURE OF USER’S INFORMATION

MSXI may disclose Personal Information to provide the LMS, or when you authorize or instruct MSXI to do so. For example, when you use the LMS to submit content or profile information. MSXI may also disclose Personal Information and Non-Personal Information to Service Providers. By “Service Providers,” this means companies, agents, contractors, service providers, or others engaged to perform functions on MSXI’s behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, and conducting audits). When MSXI uses a Service Provider, MSXI requires that the Service Provider use and disclose the Personal Information and Non-Personal Information received from MSXI only to provide their services to MSXI or as required by applicable law.

MSXI may also disclose Personal Information and Non-Personal Information to Online Tool Providers. By “Online Tool Provider,” this means a licensor of software that MSXI includes in, or uses with, the LMS, including an API or SDK, that provides a specialized function or service to MSXI and that requires the transmission of Personal Information and/or Non-Personal Information to the Online Tool Provider. Online Tool Providers may have the right to use Personal Information and Non-Personal Information about you for their own business purposes. Use and disclosure of Personal Information and Non-Personal Information by an Online Tool Provider is described in its privacy policy. See Cookies and Automatic Information Gathering Technologies section below for some of the key Online Tool Providers that MSXI uses.

We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the LMS, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.

We reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the LMS, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.

Lastly, we may also disclose Non-Personal Information, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES

Every time you use the LMS (e.g., access a Service webpage, navigate to a specific location within the Service mobile app), we collect Personal Information and Non-Personal Information (discussed above in the Collection of User’s Personal Information and Other Information section) regarding that use. For example, to improve the LMS, we collect how, when, and which parts of the LMS or its features you use. Also, we may use your unique device identifiers (UDID) or other unique identifiers to assist MSXI in collecting and analyzing this data.

To assist MSXI in collecting and storing this Non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags.” A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. A web beacon, pixel or tag is a small, usually transparent, image or script placed on a web page. This allows the operator of that image or script, which may be the operator of the website you visit or a third party, to read or write a Cookie.

Your operating system and web browser may allow you to erase information stored in Cookies and local browser storage. If you do so, you may be forced to login to the LMS again and you may lose some preferences or settings. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of the LMS may not function properly without it. MSXI may use Cookies to keep you logged in, save your preferences for the LMS, and to collect information about how you use the LMS. To learn how to manage privacy and storage setting for your local browser storage, you can refer to the end user documentation for your browser.

An Online Tool Provider may collect information automatically, in which case Personal Information and Non-Personal Information it receives are subject to the Online Tool Provider’s privacy policy. Some Online Tool Providers may allow you to opt out of certain collection and/or uses of User’s information. You can read more here:

 Google Analytics

SECURITY

MSXI utilizes reasonable information security measures to safeguard your Personal Information against unauthorized access, modification, or destruction. For example, MSXI utilizes Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet and uses firewalls to help prevent external access into MSXI’s network. However, no data transmission over the internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while MSXI strives to use commercially acceptable means to protect your Personal Information, MSXI cannot guarantee its security.

MSXI restricts access to Personal Information in its possession to employees, Service Providers, and Online Tool Providers who need to know that information in order to operate, develop, improve or support the LMS. If MSXI shares Personal Information with Service Providers or Online Tool Providers, MSXI requires in writing that they also use reasonable information security measures to safeguard your Personal Information, comply with any applicable laws or regulations with respect to information security.

THIRD PARTY WEBSITES

The LMS may link or integrate with third-party sites, services or apps. MSXI is not responsible for the privacy or security polices, practices, or the content of such third parties. Accordingly, MSXI encourages you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share and protect your information.

YOUR RIGHTS AND CHOICES

You may request access to your Personal Information by contacting [1-800-SOA-STAR (762-7827)]. MSXI will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, MSXI may need to retain it for legal reasons or for legitimate business purposes.

MSXI asks individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such request. MSXI may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where MSXI provides information access and correction, MSXI performs this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you ask MSXI to delete your Personal Information, you may not be able to continue to use the LMS. Also, even if you request that MSXI deletes your Personal Information, MSXI may need to retain certain information for a limited period of time to satisfy MSXI’s legal, audit and/or dispute resolution requirements.

MSXI supports the development and implementation of a standard "do not track" browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized "do not track" feature is released, MSXI intends to adhere to the browser settings accordingly.

You can opt out of receiving marketing e-mails from MSXI by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Even if you opt-out of marketing e-mails, MSXI may continue to send you certain account related e-mails, such as notices about your account and confirmations of transactions you have requested.

ADDITIONAL DISCLOSURES

CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information including right to know, right to delete, right to opt-out and right to non-discrimination. The CCPA also requires businesses collecting or disclosing personal information to provide notice of rights California residents have and can exercise. This section describes the CCPA rights of California residents and explains how to exercise those rights.

Right to KnoW

You have the right to request that we disclose certain information to you about our collection of your personal information over the past 12 months, including: (i) the categories of personal information collected; (ii) specific pieces of personal information collected; (iii) the categories of sources from which we collected personal information; (iv) the purposes for which we uses the personal information; (v) the categories of third parties with whom we share that personal information; (vi) the categories of information that we sell or disclose to third parties. If we sold, or disclosed your personal information for a business purpose, you have the right to request that we disclose to you the personal information, by category, for each type of third party to whom such information was sold or disclosed.

Within the past twelve (12) months, MSXI has collected the following Personal Information from its consumers:

• Personal Information:
• Names;
• Business addresses;
• Email addresses; and
• Phone numbers

• Non-Personal Information:
• The pages of our website that you viewed during a visit;
• What information, content or advertisements that you view or interact with using the LMS;
• Language preferences;
• The city and state in which you are located (but not your precise geographic location); and
• Unique identifiers that are not connected and cannot reasonably be connected to your identity. 

For further details on information we collect, including the sources we receive information from, review the Information We Collect and How We Use It section. We collect and use these categories of Personal Information for the business purpose described in the Use of Users Information section, including to provide and manage our Services.

Disclosure of Personal Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose as outlined in the Disclosure of User’s Information section and Cookies and Automatic Information Gathering Technologies section.

In the preceding twelve (12) months, MSXI has disclosed the above mentioned Personal and Non-Personal information for a business purpose. The information has been disclosed for a business purpose to the following categories of third parties: 

• Service Providers;
• Online Tool Providers; and
• Legal service providers and entities as required to comply with the law.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. To exercise the access and deletion rights under the California Consumer Protection Act, please submit a request by:

• Calling us at [1-800-SOA-STAR (762-7827)].

We may require specific information from you to help us verify your identity and process your request. If we ask for personal information to verify your identity, it will only be used for verification purposes.

Right to Opt-Out of Sale

To the extent “sale” under the CCPA is interpreted to include any of our transfers and/or other data sharing describe above as a “sale,” we will comply with applicable law as to such activity.

In the preceding twelve (12) months, we have not sold or otherwise disclosed the above-mentioned personal information for commercial purposes.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

CANADA RESIDENTS

If you have an objection to the use of your Personal Data as described in this Privacy Policy, you may file a complaint contacting 1-800-SOA-STAR (762-7827)]. We will attempt to accommodate your objection or complaint, but you understand that, to the extent you object to our processing of Personal Data that is necessary for us to provide the LMS to you, certain features and functionalities of the LMS may no longer be available to you. Nothing in this Privacy Policy prejudices your rights to file a complaint with the Office of the Privacy Commissioner of Canada, and/or with any other applicable data protection authorities.

NEVADA RESIDENTS

We do not sell your Personal Information. However, you may contact us at [1-800-SOA-STAR (762-7827)] with questions.

QUESTIONS?

We are committed to protecting your privacy and to being transparent about how we use your information. If you have any questions or concerns about our Privacy Policy, please contact use at [1800-SOA-STAR (762-7827)] and we’ll be happy to help in any way we can.