Privacy Policy

This Privacy Policy was last updated on July 23, 2023.

Welcome to MOGUL! MOGUL Inc. (“MOGUL,” “we,” “us” and/or “our”) operates the websites located at,, and related mobile applications, extensions and services (the “Service”) to enable users (“users,” “you,” “your”) to connect to share information and access content related to and in support of women, minorities, veterans, and people with disabilities and their lifestyles. This Privacy Policy describes how MOGUL collects, uses and discloses information from users of our Service, including personally identifiable data (“Personal Data”). Please note that the use of information received from Google APIs will adhere to the Chrome Web Store User Data Policy, including the Limited Use requirements.

Please be sure to read this entire Privacy Policy before using or submitting information through our Service. By using or submitting information through our Service, you are indicating that you agree to be bound by the terms of this Privacy Policy. This Privacy Policy is incorporated by reference into MOGUL’s Terms of Service.

Information We Collect:

When you interact with us through the Service, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Service: We collect Personal Data from you when you voluntarily provide such information to us, such as when you contact us with inquiries; respond to one of our surveys; register for an account with or access to the Service; request to be placed on mailing lists or receive newsletters; participate in promotions, sweepstakes or contests; become a MOGUL Influencer; purchase products or services from us; or otherwise use certain features of the Service. When you register for an account with MOGUL, you must provide us with a username, email address and password. You also have the option of providing additional information in your account profile or in connection with certain features of the Service, including but not limited to your name, interests, biographical and career information, geographic location, age, gender, payment method information, address, mobile telephone number and links to your social media pages. Wherever MOGUL collects Personal Data, we make an effort to provide a link to this Privacy Policy.

User Content: We collect and store information that you and other users upload, post, submit, publish, transmit, display or otherwise share through the Service (“User Content”). You acknowledge and agree that, to the extent that you include Personal Data in User Content, such Personal Data will be public, and we are not responsible for how others may use it. Please use caution and common sense when sharing or posting User Content.

You can remove User Content that you have previously posted from publicly viewable areas of the Service by deleting it. If you have difficulty deleting any of your User Content for any reason, please contact us at [email protected] so that we may remove the applicable content at your request. You understand that such content may remain on publicly viewable areas of the Service if other users have posted or reposted it, and that your User Content may remain on our servers or in our records after it is no longer viewable by other users of the Service.

Data You Provide about Others: We may also collect and store information about others that you provide to us through your use of the Service, such as when you share User Content with others through email or social media websites and services. For more information on the data we share with and receive from social media websites and services, see the section titled “Social Networking Services” below.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. You represent that the Personal Data you provide is true, accurate, current and complete, and that you have the authorization to provide it to us. If you provide Personal Data to the Service, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of MOGUL and the authorized third parties referred to herein located in the United States.

IP Addresses; Device ID Information: The requests you make to MOGUL may contain your IP address (the Internet address of your computer). We may use users’ IP addresses for various purposes, including to display customized content and analyze and report upon usage of the Service; to diagnose and prevent service or technology problems affecting the Service; and to monitor and prevent fraud and abuse. We do not link your IP address to any Personal Data unless you are logged in to your MOGUL account. If you access our Service on a mobile device, we may also collect your device identification number and request access to settings and location information for similar purposes and to personalize your experience with the Service.

Location Information: We may collect, use and share your location information to provide certain functionality, content or promotional material with location-based components. Location information includes, but is not limited to, any information we derive in order to identify your geographic position. We collect location information when you provide it to us directly in your account profile or in connection with purchases you make on or through the Service; we may also collect location information from the computer or mobile device you use to access the Service or through connected Social Networking Services, your wireless carrier or certain third-party service providers. The collection and tracking of your location information may occur even when the Service, including any mobile application, is not actively open and running.

We may also use your location information in an aggregate way, as described below in the “Aggregated Personal Data” section.

You can control the location information that is displayed and shared with other MOGUL users by changing your account’s privacy settings. You can also change the privacy settings of your mobile device to turn off the functionality to share location information with the Service. Please note that turning off location sharing may affect certain features of the Service. If you have any questions about the privacy settings of your mobile device, we recommend that you contact the manufacturer or your mobile service provider for assistance.

Non-Identifiable Data: When you interact with MOGUL through the Service, we and third parties that may provide certain functionality on the Service, such as social media or advertising networks, use various technologies to passively collect information that cannot by itself be used to specifically identify you (“non-identifiable data”). MOGUL may store such information itself or such information may be included in databases owned and maintained by MOGUL affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of users on the Service, the number of users on each page of our website and the domain names of our users' Internet service providers.

In operating and providing the Service, we use technologies called "cookies" and “web beacons.” A cookie is a piece of information that the computer that hosts our Service gives to your browser when you access the Service. Our cookies help us provide additional functionality to the Service; personalize your experience with the Service; and analyze Service usage more accurately for research, advertising and marketing purposes. For instance, we may set a cookie on your browser that allows you to access our website without needing to remember and then enter a password more than once during a visit to the website. We use web beacons (also known as “clear GIFs”) to measure site traffic and related browsing behavior and to improve your experience when using our Service. We may also use customized links or other similar technologies to track hyperlinks that you click and associate that information with your Personal Data in order to provide you with more focused communications. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service’s features.

We may collect certain data in order to enable recognition and provide faster search response time. We may also use Google Analytics and similar tools to help analyze how users use our Service. Google Analytics uses cookies to collect standard Internet log-in information and user behavior information. The information generated by the cookie about your use of our Service (including IP address) is transmitted to and stored by Google. This information is then used to evaluate users' engagement of our Service, compile statistical reports on activity on the Service and enhance your experience when you use the Service. Google will not associate your IP address with any other data held by Google. For more information on how Google uses this data, go to

Response to “Do Not Track” Signals: At present, we do not respond to “do not track” signals sent from web browsers. If we do so in the future, we will provide all relevant information in this policy.

This Privacy Policy covers the use of cookies, web beacons, and similar files by MOGUL only. Uses of these technologies by any third-party advertiser or website linked from the Service, including third parties with which we partner, are governed by each such advertiser or website’s privacy policy.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Service, MOGUL conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and MOGUL may share this aggregate data with its affiliates, agents and business partners or otherwise use it for any lawful purpose. This aggregate information does not identify you personally. MOGUL may also disclose aggregated user statistics in order to describe our Service to current and prospective business partners and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information: MOGUL uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email to ask us a question or report an issue with the Service, we will use the Personal Data you provide to answer your question or resolve the issue. If you provide us with payment, billing and shipping information in connection with your purchase of products or services on or through MOGUL, we will use and store your payment, billing and shipping information to facilitate current and future transactions. We are use a third party payment processor to process payment transactions. If you provide Personal Data in order to obtain access to the Service, we will use your Personal Data to provide you with access to and monitor your use of the Service. MOGUL and its subsidiaries and affiliates (the “MOGUL Related Companies”) may also use your Personal Data and non-identifiable data collected through the Service to help us improve the content and functionality of the Service, to better understand our users and to improve the Service.

Marketing: MOGUL and its affiliates and partners may use your Personal Data and other information to communicate with you by email, text message or push notification to provide you with information about content, features, opportunities, and promotions available through the Service that we think may be of interest to you. We will send such messages only with your consent, which we will ask you for when you register for your MOGUL account. You may opt out of marketing emails or messages from us at any time by following the instructions in the email or message describing how to "opt-out" of receiving future communications or sending an “UNSUBSCRIBE” message in reply.

CAN-SPAM Act: The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will: (a) not use false or misleading subjects or email addresses; (b) identify the email message as an advertisement in some reasonable way; (c) include the physical address of MOGUL Inc., which is 163 Amsterdam Avenue #1424, New York, NY 10023; (d) monitor third-party email marketing services for compliance, if one is used; (e) honor opt-out/unsubscribe requests quickly; and (f) give an “opt-out” or “unsubscribe” option.

If MOGUL intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information:

We consider your information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Certain Business Partners: When we partner with other businesses to provide content or services, offer promotions, sponsor sweepstakes or contests or display advertisements related to your interests through the Service, we may share relevant Personal Data with these partners in connection with providing such services or features. For example, we may share your contact information with a business partner that is hosting a networking event in your area if you have indicated interest in participating in such events.

Recruiters: We may develop a recruiter service to enable our users to gain valuable exposure in their career searches. Recruiters will be able to export limited information from users’ account profiles, such as users’ name, title and general geographic location, in order to manage candidate sourcing effectively. We will not provide contact information or resumés of Mogul Members (whether Free, Premium or Board Memberships) directly to recruiters unless you upload or submit such information in response to a job posting or otherwise indicate that you would like for us to do so. Any information from or about you obtained independently by a recruiter is governed by the privacy policy of such recruiter.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We cannot control how an acquiring or surviving entity may use or disclose such information.

Related Companies: We may also share your Personal Data with the MOGUL Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants, Vendors and Service Providers: MOGUL, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, providing marketing assistance, providing search results and links (including paid listings and links), processing payments and performing customer service. When we employ another company to perform a function of this nature, we only provide such company with the information needed to perform its specific function. In addition, we require such companies to whom we disclose your information to be under contractual obligations to keep such information confidential and to use such information only for the purposes for which we disclose it. MOGUL will take commercially reasonable measures to ensure that such companies do not use your information for any other purposes.

As Required by Law and Similar Disclosures: MOGUL may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of MOGUL, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public or (iv) protect against legal liability.

With Your Consent: We may also disclose your Personal Data with your permission.

Non-Personally Identifiable Information: We may disclose depersonalized, aggregated information about our users that does not identify any individual without restriction.

We do not sell, trade, or otherwise transfer your Personal Data to outside parties except as set forth in this Privacy Policy, unless we provide you with advance notice.

Your Choices: You can use the Service without providing any Personal Data or registering for an account. If you choose not to provide any Personal Data, you may not be able to use certain features of the Service.

Exclusions: This Privacy Policy shall not apply to any unsolicited information you provide to MOGUL through the Service or through any other means. This includes, but is not limited to, information posted to any public areas of the Service, such as comment sections (collectively, “Public Areas”), any ideas for new products or services or modifications to existing products or services, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and MOGUL shall be free to reproduce, use, disclose and distribute such Unsolicited Information to others without limitation or attribution.

Children: The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Site and Service are not meant for use by children under 13 years old. In addition, our Site and Service do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13 years of age. MOGUL does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Site or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on the Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to MOGUL through the Service, please contact us at [email protected], and we will endeavor to delete that information from our databases.

Links to Other Websites: This Privacy Policy applies only to the Service. The Service may contain links to other websites not operated or controlled by MOGUL (the “Third-Party Sites”). The policies and procedures we describe here do not apply to the Third-Party Sites. The links from the Service do not imply that MOGUL endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Social Networking Services: Through the Service, we may offer you the opportunity to access certain social media and social networking websites and services that are owned and/or controlled by third parties (including, without limitation, Facebook and Twitter) (such websites and services, collectively, the “Social Networking Services”). When you elect to access and use the Social Networking Services, you will be sharing your information (which will include Personal Data, if you elect to provide us with such information) with those Social Networking Services. As with other Third-Party Sites, the information that you share with each Social Networking Service will be governed by the privacy policies and terms of service of the providers of such Social Networking Services and not by the policies and procedures we describe here. You may also be able to modify your privacy settings with the Social Networking Services to, for example, control what information the Social Networking Services disclose to other entities, including MOGUL. When you log into the Service using a Social Networking Service account or otherwise link your MOGUL account with a Social Networking Service account, we will collect relevant information necessary to enable the Service to access that Social Networking Service; however, you will provide any login information, like your password, directly to such Social Networking Service (and not to MOGUL). As part of such integration, the Social Networking Service will provide MOGUL with access to certain information that you have provided to such Social Networking Service and information about your use of such Social Networking Service, such as your profile picture and friends list. We will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Networking Service. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of the applicable Social Networking Service provider, and, as a result, MOGUL shall not have any liability or responsibility for the privacy practices or other actions of Social Networking Services that may be enabled within and/or otherwise accessible through the Service.

Security: MOGUL takes reasonable steps to protect the Personal Data you provide via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Specifically, we use Secured Sockets Layer (SSL) encryption and a web application firewall (WAF) when collecting, storing, or transferring Personal Data. Our Site also receives regular security scans, penetration tests, and malware scans. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register on our Site, or (d) access our Site. Personal Data is stored in password-controlled servers with limited access. However, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to MOGUL via the Internet. We do not accept liability for unintentional disclosure.

By using the Service or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we will notify you electronically by posting a notice on the Service or by sending an email to you within 48 hours of MOGUL becoming aware of such breach. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at [email protected].

Fair Information Practice Principles: We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

International Users: All Personal Data is stored on servers in the United States and is subject to United States law. Our servers are currently hosted by Heroku. We reserve the right to use any reputable hosting service at our sole discretion. By choosing to use the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with MOGUL or the Service be in accordance with the Terms of Service.

If you are accessing from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and the global processing of such information. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

Other Terms and Conditions: Your access to and use of the Service is subject to the Terms of Service .

Changes to MOGUL’s Privacy Policy: The Service and our business may change from time to time. As a result, at times it may be necessary for MOGUL to make changes to this Privacy Policy. MOGUL reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. The updated Privacy Policy will be provided on our Site. Please review our Privacy Policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Service after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

New Uses of Personal Data: From time to time, we may desire to use Personal Data for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Your California Privacy Rights: Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us at [email protected]. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

California Consumer Privacy Act: This Section supplements the information contained in our Privacy Policy above and applies solely to all users, and others who may access our Site, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section.

  1. Right to Request Personal Information. Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we sell your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. A consumer can make such a request only twice in a 12-month period.

We require such Personal Information to be able to provide you with our Services.

Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.

  1. Disclosure of Personal Information. We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.

  2. Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. In the event you ask that we delete all of this Personal Information, you will no longer be able to use our Services. Please note that your request to partially erase Personal Data may impair Mogul’s ability to provide the Services.

  3. Non-Discrimination Right.We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    1. Deny you goods or services.
    2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    3. Provide you a different level or quality of goods or services.
    4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

  4. Financial Incentives. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

  5. Contact Information. You may contact us (i) at [email protected], (ii) by phone at our toll-free number 1-888-ONMOGUL, or (iii) by writing to us at Privacy Officer, 163 Amsterdam Avenue #1424, New York, NY 10023 to (a) make a Personal Information Request, (b) lodge a complaint about our use or storage of your Personal Information, (c) ask us to delete such Personal Information, and/or (d) discuss our Privacy Policy and/or anything that has to do with it. We will respond within forty-five (45) days of receiving such request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

  6. Under 16. We will not sell your Personal Information if you are under the age of 16 unless we have the consent of your parent or your guardian nor will we sell it if you ask us not to do so.

  7. Opt Out Right. Upon your request, we will stop selling your Personal Information (sometimes called your Opt-Out Right). You may send the request to Opt-Out (i) to [email protected], (ii) by phone at our toll-free number 1-888-ONMOGUL , or (iii) by writing to us at Privacy Officer, 163 Amsterdam Avenue #1424, New York, NY 10023.

  8. Personal Information that We Store. For your information, we store and collect the following Personal Information on you:
    1. First and last name
    2. Online contact information, such as an email address and username
    3. Educational, professional, employment, and business information
    4. Photographs
    5. Video or audio files

For Our European Users and Visitors

We are headquartered in the State of New York in the United States and our operations are located in the United States. Your Personal Information, which you give to us during registration or use of our Site or Services, may be accessed by or transferred to us in the United States. If you are visiting our Site or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our Site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.

  1. a. We will comply with the EU Standard Contractual Clauses with respect to the transfer of Personal Data from the EU to the US for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the EU Standard Contractual Clauses, the terms and conditions in the EU Standard Contractual Clauses will govern. For the purposes of this Privacy Policy, “EU Standard Contractual Clauses” mean the standard contractual clauses for the transfer of personal data to processors established in the US. (Commission Decision 2010/87/EC).
    1. Obligations of the data importer (processors)

The data importer agrees and warrants:

  1. to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
  2. that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
  3. that it has implemented the technical and organizational security measures before processing the personal data transferred;
  4. that it will promptly notify the data exporter about:
    • any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,
    • any accidental or unauthorized access, and
    • any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
  5. to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
  6. at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
  7. to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
  8. that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;
  9. that the processing services by the sub-processor will be carried out in accordance with Clause 11;
  10. to send promptly a copy of any sub-processor agreement it concludes under the Clauses to the data exporter.
       ii.Obligations of the data exporter

The data exporter agrees and warrants:

  1. that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
  2. that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter's behalf and in accordance with the applicable data protection law and the Clauses;
  3. that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures;
  4. that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
  5. that it will ensure compliance with the security measures;
  6. that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
  7. to make available to the data subjects upon request a copy of the Clauses, with a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information; and
  8. that, in the event of sub-processing, the processing activity is carried out in at least the same level of protection for the personal data and the rights of the data subject as the data importer under the Clauses.

  1. The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred above by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.

  2. if a data subject is not able to bring a claim for compensation in accordance with paragraph a against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations referred to above, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity.

  3. If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, (referred here as Personal Information), as defined in the GDPR.

  4. Please note that in some circumstances, we may not be able to fully comply with your request, or we may ask you to provide us with additional information in connection with your request, which may be Personal Information, for example, if we need to verify your identity or the nature of your request.

  5. In such situations, however, we will still respond to let you know of our decision. As used herein, “Personal Information” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.

  6. To make any of the following requests, please contact us (i) via email at [email protected], or (ii) by writing to us at MOGUL Inc., 163 Amsterdam Avenue #1424, New York, NY 10023.

    1. Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
    2. Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
    3. Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
    4. Erasure: You can request that we erase some or all of your Personal Information from our systems.
    5. Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
    6. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
    7. Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
    8. Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to to locate your Data Protection Authority.
    9. Response: We will respond to your inquiry within thirty (30) days of the receipt.

Access to Information; Contacting MOGUL:

You may keep your Personal Data accurate, current and complete by logging into your account and reviewing and updating your information. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Service.

Please feel free to contact us if you have any questions about MOGUL’s Privacy Policy or the information practices of the Service.

You may contact us by emailing [email protected].