Privacy Policy

Privacy Policy

Effective Date: January 1, 2024.

Introduction

This Privacy Policy describes how Magellan Distribution Corp. (collectively, “Magellan”) collects, uses, and shares information about you through our websites or mobile apps operated by us from which you are accessing this Privacy Policy (“Magellan websites”), through Magellan’s social media pages (“Social Media Pages”), as well as through email messages, and text messages that Magellan may send to you that link to this Privacy Policy (collectively, including Magellan websites and Social Media Pages, the “Services”).

This Privacy Policy does not apply to Magellan’s data collection activities offline or otherwise outside of the Services (except as described in Section 14 or unless otherwise stated below or at the time of collection). By using the Services, you agree to Magellan’s Terms and Conditions. By consenting to and/or acknowledging this Privacy Policy, you consent to and/or acknowledge Magellan’s collection, use and disclosure practices, and other activities described in this Privacy Policy. If you do not agree and/or do not consent, discontinue use of the Services, and uninstall Service downloads and applications.

“Personal Information” is information that identifies you as an individual and may include:

  • Name
  • E-mail address
  • Postal Address (including billing and shipping address)
  • Geolocation information
  • Telephone number
  • Bank information and credit references (if applicable)
  • Magellan Account Number
  • Credit or debit card number

1. Changes to This Privacy Policy

Magellan reserves the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of Magellan’s Services may indicate your consent and/or acknowledgment to the privacy policy posted. If the changes are material, Magellan may provide additional notice to your e-mail address where applicable. Where required to do so by applicable law, Magellan will obtain your consent to such changes.

2. How Magellan Collects Information

A. Information You Give Us

Magellan may (with your consent, where required by applicable law) collect Personal Information you provide directly to Magellan via the Services. For example, Personal Information may be collected when you use or register for Magellan’s Services, subscribe to Magellan’s notifications, post on Magellan’s Services, participate in promotional activities, apply for a job, communicate with Magellan through the Services, or use an app installed on a device. You may choose to voluntarily submit certain other information to us through the Services, including Personal Information, but you are solely responsible for your own Personal Information in instances where Magellan has not collected such information or requested that you submit such information to us. De-Identified Data or Personal Information once “de-identified” may not be subject to this Privacy Policy and Magellan and Magellan’s Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

B. Information Magellan Collects Automatically from Your Use of Magellan’s Services

Magellan and Magellan’s Service Providers collect information about the Services that you use and how you use them. Magellan does this with your consent where required by applicable law. Certain information is collected automatically through your device, such as your: IP address; device identifier, Ad ID, browser type; operating system characteristics; information about your use of Magellan’s Services; and data regarding network connected hardware (e.g., computer or mobile device) (“Usage Information”). To the extent that Usage Information is Personal Information under applicable law or is combined with Personal Information, Magellan will treat that information as Personal Information under this Privacy Policy.

The methods that Magellan and Magellan’s Service Providers may use to collect Usage Information include:

  • Log Information: Magellan collects information about your use of Magellan’s Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, and related data, and store it in log files.
  • Information Collected by Cookies and Other Tracking Technologies: Magellan and Magellan’s Service Providers may use cookies or other tracking technologies (“Tracking Technologies”) to collect and store information about interactions with Magellan’s Services, including information about your browsing and purchasing behavior. Further information about how Magellan uses cookies is set out in Magellan’s Cookie Policy. Magellan is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 13 so that your consent and/or acknowledgment to encountering them is meaningfully informed.

C. Personal Information Collected from Other Sources

Magellan may (with your consent, where required by applicable law) receive your Personal Information from other sources, such as public databases, joint marketing partners, and social media platforms, and combine that with information Magellan collects about you. To the extent Magellan combines such third-party sourced information with Personal Information Magellan collects directly from you, Magellan will treat the combined information as Personal Information. Subject to applicable law, Magellan is not responsible for the accuracy of the information obtained from third parties or third-party practices.

3. How Magellan Uses Personal Information Magellan Collects

  • A. To provide, maintain, protect and improve Magellan’s Services, develop new services, and protect Magellan and Magellan’s users;
  • B. To facilitate, manage, personalize, and improve your online experience;
  • C. To respond to your inquiries and fulfill your requests, such as to send you newsletters, brochures, catalogs, virtual event invitations, and e-mails;
  • D. For Magellan’s business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving, or modifying Magellan’s Services, identifying usage trends, and operating and expanding Magellan’s business activities; and
  • E. To send you advertisements and communicate with you about products, services, offers, promotions, rewards, and events Magellan believes may be of interest to you (for information about how to manage these communications, see Section 13).
  • F. To contact you regarding your job application status including sending application instructions and/or interview scheduling options, if you have voluntarily applied for an employment position at Magellan.
  • G. To send you employment recruiting information where you have affirmatively demonstrated an interest in employment with Magellan.

Where required by applicable law, Magellan will obtain your additional or separate consent if Magellan processes your Personal Information for purposes other than those stipulated in this Privacy Policy.

Marketing Purposes

If you are a user from the United States, Magellan may use your Personal Information for direct marketing purposes. If you are a user from outside the U.S., Magellan will not use your Personal Information for direct marketing purposes unless Magellan has received your affirmative consent where required by application law. All users, regardless of geographic location, have the right to opt-out from direct marketing and can require Magellan to cease using the data at any time for direct marketing purpose at no cost to you.

4. How Magellan Shares Information

With your consent (where required by applicable law), Magellan’s agents, vendors, consultants, marketing service providers, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on Magellan’s behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance on Magellan’s behalf, although Magellan may permit them to use de-identified data or aggregated information, which does not personally identify you or any other user of the Services (for example, Magellan may aggregate Personal Information to calculate the percentage of Magellan’s users who have a particular telephone area code). Magellan may also (with your consent, where required by applicable law) share information about you as follows:

  • A. As necessary, for the following purposes: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence to meet national security or law enforcement requirements; (c) to enforce Magellan’s terms and conditions; (d) to protect Magellan’s operations and protect Magellan’s rights, privacy, safety or property, and/or that of you or others; and (e) to allow Magellan to pursue available remedies or limit the damages that Magellan may sustain;
  • B. With Magellan’s affiliates for internal business purposes. For example, processing your orders, fulfilling your requests, providing customer service, and improving Magellan’s products and services to better serve you;
  • C. With Magellan’s subsidiaries, affiliates, business partners, and other third parties for their own business purposes. For example, improving their products and services; and
  • D. To a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Magellan’s business, assets or stock (including in connection with any bankruptcy or similar proceedings).

When Magellan engages Service Providers and when disclosure of Personal Information to such providers is necessary for the provision of such service, Magellan ensures that such providers will protect Personal Information in a manner consistent with this Privacy Policy and all applicable data privacy laws.

Aggregated Information

Without limiting the foregoing, in Magellan’s sole discretion, Magellan may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

Sharing for Marketing Purposes

If you are a user from the U.S., Magellan may share your Personal Information with third parties for direct marketing purposes.