Privacy Policy for TMOE

Last Updated: September 15, 2025

1. Introduction

This Privacy Policy describes how TMOE ("we," "us," or "our") collects, uses, stores, and protects the personal information of users ("you" or "your") who access or use our services, products, and website (collectively, the "Service"). We are committed to protecting your privacy and handling your data in a transparent and secure manner. By using the Service, you agree to the collection and use of information in accordance with this policy.

2. Data Protection Officer and Contact Information

TMOE is committed to protecting your privacy. If you have any questions or concerns about your personal data or this Privacy Policy or our data practices, please contact our Data Protection Officer at dpo@marvelof.com.

3. The Categories of Data We Collect

We may collect various types of personal information from and about users of our Service. The categories of data we may collect include, but are not limited to:

  • Personal Identifiers: Such as your name, email address, postal address, phone number, unique personal identifier, online identifier, Internet Protocol (IP) address, account name, or other similar identifiers.
  • Geolocation Data: Information about your physical location, which may be collected when you use location-enabled services.
  • Demographic Data: Such as your age, gender, or other demographic characteristics.
  • Internet Activity Data: Information regarding your interaction with our Service, including browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
  • Commercial Information: If applicable, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Professional or Employment-Related Information: If applicable, information related to your profession or employment.
  • Inferences: Derived from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

4. The Purposes for Which We Collect Data

We collect your personal information for various purposes, including:

  • To Provide and Maintain the Service: To operate, maintain, and provide all features of the Service, such as creating and managing user accounts, processing transactions, and delivering requested services.
  • To Improve and Personalize the Service: To understand how users interact with our Service, analyze usage patterns, and develop new features, functionality, and content that enhance your experience.
  • To Communicate with You: To send you important notices, updates, security alerts, and administrative messages related to your use of the Service. We may also send you marketing and promotional communications if you have opted in to receive them.
  • For Security and Fraud Prevention: To protect the security and integrity of our Service, prevent fraud, and enforce our Terms and Conditions.
  • For Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
  • For Research and Analytics: To conduct research, perform data analysis, and generate aggregated or anonymized statistics to understand market trends and improve our business operations.

5. How We Use and Share Data

We may use and share your personal information with third parties in the following ways:

  • With Service Providers: We may share your information with third-party service providers who perform services on our behalf, such as hosting, data analysis, payment processing, customer service, and marketing assistance. These service providers are obligated to protect your information and use it only for the purposes for which it was disclosed.
  • For Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity.
  • For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency request).
  • With Your Consent: We may share your information with third parties when we have your explicit consent to do so.
  • Aggregated or Anonymized Data: We may share aggregated or anonymized data that cannot reasonably be used to identify you with third parties for various purposes, including analytics, research, and marketing.

6. Your Data Retention Policy

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Your Security Measures

We implement reasonable technical and organizational measures designed to protect your personal information from unauthorized access, use, alteration, or destruction. While we strive to safeguard your information, please note that no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee the absolute security of your personal information.

8. User Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

  • Right to Withdraw Consent: You may withdraw your consent for the collection, use or disclosure of your personal data at any time by contacting our DPO. You can also manage cookie consent via our cookie banner. Withdrawing consent may affect our ability to provide certain services to you.
  • Right to Access: The right to request access to your personal data we hold about you and information about how we have used or disclosed it within the past year.
  • Right to Rectification: The right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • Right to Erasure: The right to request that we erase your personal data, under certain conditions.
  • Right to Restrict Processing: The right to request that we restrict the processing of your personal data, under certain conditions.
  • Right to Object to Processing: The right to object to our processing of your personal data, under certain conditions.
  • Right to Data Portability: The right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

9. How Users Can Exercise Their Rights

To exercise any of your rights described above, please submit a request to our DPO at dpo@marvelof.com. We will respond to your request within a reasonable timeframe and in accordance with applicable laws. We may need to verify your identity before processing your request.

If you are in a jurisdiction with other specific rights, please contact our DPO and we will do our best to accommodate your request in accordance with the applicable laws.

10. Information About Cookies and Other Tracking Technologies

We use cookies and similar tracking technologies (like web beacons and pixels) to track the activity on our Service and hold certain information. Cookies are files with a 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. 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.

12. Changes to the Privacy Policy

We may update our Privacy Policy from time to time. Any changes in the Privacy Policy will be effective immediately upon posting on this page and updating the "Last Updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

13. Children's Privacy

Our Service is not intended for use by children under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact our DPO. 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.

14. International Data Transfers

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 from those of your jurisdiction. We will achieve this by using appropriate safeguards such as binding contractual clauses. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

15. Opt-Out Options

You may opt-out of receiving promotional communications from us by following the unsubscribe link or instructions provided in any email we send. Please note that even if you opt-out of receiving marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

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