Privacy Policy

We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties. All of the information listed in (A)-(C) above is detailed below and hereinafter referred to as “Information.”

Information You Provide to Us:

In using our services, you may provide us with information, including, without limitation:

• Contact information such as name, email address, postal address and telephone number(s);
• Personal financial information such as account balances, income information, assets, credit score, credit history and transaction history;
• Account information and log-in credentials, including unique identifiers such as username and password;
• Payment and transaction information including credit or bank card information;
• Information about your health to the extent that it is needed for the financial planning process;
• Resumes, educational history, and other information provided in applications for employment;
• Preferences for communications and services
• Additional information as otherwise described to you at the point of collection or pursuant to your consent.

Information We May Automatically Collect About You:

Our services may automatically collect certain Information about you. We use this information to help us design our services to better suit our users’ needs. This information may include:

• IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider)
• Date and time of your visit or use of our services
• Domain server from which you are using our services
• Type of computer, web browsers, search engine used, operating system, or platform you use
• Data identifying the web pages you visited prior to and after visiting our website or use of our services
• Your movement and activity within the website, which is aggregated with other information
• Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”)
• Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from

Cookies & Technologies Used to Collect Information About You

• We collect the above Information directly and through the use of third parties. We collect this information by using certain technologies, such as cookies, web beacons, and other technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this privacy policy, except as required by law. To learn more about cookies and the tracking technologies we use on our services, please see our Cookie Notice.

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Most web browsers automatically accept cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

• Flash Cookies. We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount and type of data stored and the method of storing this data. Cookie management tools provided by your browser will not remove Flash cookies.

• Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the services. These technical methods may involve the transmission of information either directly to us or to a third party authorized by us to collect information on our behalf. Our services may use retargeting pixels from Google, Facebook, and other ad networks. We may also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

• Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. Learn more about Google’s Privacy Policy here: https://policies.google.com/privacy?hl=en-US. You can opt-out of having your activity on our services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

• Mobile Application Technologies. If you access our website and services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.

Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, LinkedIn(“Social Media Platforms”), and/or sources providing publicly-available information (e.g., from the U.S. Postal Service) to help us provide the services to you, help prevent fraud, and for marketing and advertising purposes.

Information we may access about you, with your consent, may include, but is not limited to, your basic social media platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the social Media Platform. Please keep in mind that when you provide information to us on a third-party website or platform (for example, via our applications), the information you provide may be separately collected by the third-party website or the social media platform.

The Information we collect is covered by this privacy policy, and the information the third-party website or social media platform collects is subject to the third-party website or platform’s privacy practices. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your Information.

Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

• To provide you with the services, and related products, promotions, newsletters, and information you request
• To provide you with financial services or related information
• To respond to your inquiries and provide you with requested information and other communications, including by email
• For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
• To fulfill contracts we have with you
• Maintain, improve, customize, or administer the services, perform business analyses, or other internal purposes to improve the quality of our business, the services, resolve technical problems, or improve security or develop other products and services
• Comply with our Terms & Conditions
• To assess your application for employment
• Analytics for business purposes and business intelligence
• Comply with any applicable laws and regulations and respond to lawful requests
• For any other purposes disclosed to you at the time we collect your information and/or pursuant to your consent

Sharing Your Information

We may disclose anonymized aggregated information about our users, that does not identify any individual, without any restriction.

We may share your information as set forth in the privacy policy and in the following circumstances:

• Third-Party Service Providers. We may share your information with third-party service providers or data processors that perform certain functions or services on our behalf (such as to host the services, store or manage the data, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers will process this data only for purposes specified by MSC and will be bound by contract to meeting MSC’s obligations under applicable law.
• Disclosure of Information for Legal and Administrative Reasons. We may disclose your information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our services.
• Online Communications (Chatrooms, Forums, Contests, Message Boards). If you correspond with us by email, questionnaires, surveys, social media, or other digital online platform, we may retain such correspondence and the information contained in it and use it to respond to your inquiry.
• Aggregate Data. We may share general information, aggregated data or publish information based on aggregated data. However, we will only do so in a way that your personal identity is protected.
• With Your Consent. We may share information consistent with this privacy policy with your consent.

MSC may occasionally provide links to sites operated by outside parties (“Third-Party Websites”) that we believe may be of interest to you. We do not disclose your information to these third-party websites without obtaining your consent. In addition, from our services you may be able to interact with social media platforms, for example, by “liking” us on Facebook. If you choose to click on a link to one of these third-party websites or choose to interact with or through a social media platform, your activities are not governed by this privacy policy and will be governed by the privacy policy on that third-party website or social media platform. Please review their privacy policies and terms of service before disclosing any information there. MSC does not review, does not endorse, and is not responsible for the privacy practices of these third-party websites and social media platforms.

We may also maintain a page on Facebook or other social media platforms. Those pages and your interaction with them are governed by the privacy policies of Facebook or other relevant social media platform, and not our privacy policy. As with other third-party websites, we not endorse and is not responsible for the privacy practices of these forums, although we may have a presence on them.

We use commercially reasonable measures to provide our services. However, you should assume that no data transmitted over the internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your information or private communications will always remain private or secure. We do not guarantee that your information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your information.

It is your responsibility to maintain the confidentiality of your log-in credentials and unique identifiers used to access the services. You are also responsible for ensuring the accuracy of the information you submit to MSC. Submitting inaccurate information, or failing to maintain the accuracy of information that changes (for example, a change of email address) may disrupt your ability to use our services, may affect the information you receive from us, and may impact our ability to contact you. You can update your information at any time by logging into and visiting your user account page.

If you believe that your information has been accessed or acquired by an unauthorized person, you shall promptly contact us so that necessary measures can quickly be taken.

We will retain your information for as long as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain information you have submitted to us. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.

You agree that we, our affiliates, and/or third-party service providers with whom we collaborate, and contract may communicate with you regarding our services via electronic messages, including email. For example, send you information relating to our products and services that we think may be of interest to you, communicate with you about offers, promotions, upcoming events, and other news about products and services provided by or through us through permissible targeted advertisements offered by us, our subsidiaries, our affiliates, and other business partners. See your choices, below, for how you can update the way we contact you.

1. 1. Email. By using our services, you agree that we may contact you by email as set forth herein. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or contact us directly.
   2. Mobile Push Notifications. By using our services, you agree that we may contact you by calling or sending messages to your phone. You can use the settings on your mobile device to enable or turn off mobile push notifications from us or contact us directly.
   3. Location Choices. You can change the privacy settings of your device at any time to turn off the sharing of location information with our services. If you choose to turn off location services, this could affect certain features or services of our services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
   4. Opting Out of Direct Marketing. To exercise choices regarding the marketing information you receive, you may also review the following links:

• You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
• You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

You can opt-out of having your activity on our services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web

To the extent other state laws provide users with additional data subject rights, those rights may be honored by the Company following proper authentication and verification. Please see the How to Contact Us section below to obtain more information.

Our website is intended only for users over the age of eighteen (18). By using our website, you agree that you are eighteen (18) years or older. If we have actual knowledge that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).

This section is included in this privacy policy to comply with the requirements of the General Data Protection Regulation (“GDPR”). It applies only to individuals coming to our services from within the European Union (EU) or European Economic Area (EEA) and only if we collect through the services any personal data as defined in such laws (which may include some or all of your Information as defined in this Privacy Policy) of those individuals or if we track individuals in the EU or EEA who access our services.

1. Data Controller

MSC is the data controller for the information (as defined above in Section I) we process, unless otherwise stated. You may contact MSC directly at:

Call us: 877.633.9840

Your Data Protection Rights

To the extent the GDPR applies and we hold such personal data in our capacity as a data controller as defined under those laws, you may request that we:

• Restrict the way that we process and share your personal data;
• Transfer your personal data to a third party;
• Revoke your consent for processing of your personal data;
• Provide you with access to your personal data;
• Remove your personal data if no longer necessary for the purposes collected;
• Update your personal data so it is correct and not out of date;
• Object to our processing of your personal data.

More information on our cookies policy can be found here. If you wish to object to the use and processing of your personal data or withdraw consent to this privacy policy, you can contact us in the following ways:

Call us: 877.633.9840

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try to resolve it directly. Please contact us at:

Call us: 877.633.9840

Lawful Basis for Processing Your Information

As described throughout this privacy policy, we believe the foregoing handling of your Information, which may include your personal data, furthers our legitimate interests in commercial activities that are not overridden by the interest or fundamental rights and freedoms of the individuals at issue. Depending on what personal data we collect from you and how we collect it, we rely on various grounds for processing your personal data, including the following reasons:

• To administer our contractual relationship, including setting up any of the services you may request
• Because it is in our legitimate interest to effectively and efficiently operate our business and provide you with the services and other useful content and for other marketing, design, and advertising purposes
• To process employee data, prevent against fraud, provide technology security, and other necessary operational matters
• In order to fulfill any legal obligations
• Because you have provided your consent for us to do so

If the processing of your information is based on your consent, the GDPR also allows users the right to access, revoke or modify your consent at any time. To review or modify your consents, please contact us directly.

1. Consent to Transfer

MSC is operated in the United States and we may use service providers based in the United States to operate our business and our relationship with you. Please be aware that information, including your personal data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We only collect and transfer to the U.S. information, including personal data: (i) with your consent; (ii) to perform a contract with you; and/or (iii) to fulfill a compelling legitimate interest of MSC in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this privacy policy. We also enter into data processing agreements and model clauses with vendors whenever feasible and appropriate.

1. Children’s Information

We do not knowingly collect or maintain any Information on our services from persons under 13 years of age, and no part of our services are directed to persons under 13 years of age. If you are under 13 years of age, please do not use or access our services at any time or in any manner. Upon learning of the existence of information concerning persons under 13 years of age that has been collected on our services without verified parental consent, we will take appropriate steps to delete it.

• If you are located in the EU or EEA and are over 13 years of age but under 16 years of age, you must have your parent or legal guardian’s permission to use the services. Please have them read this agreement with you. If you are a parent or legal guardian of a user located in the EU or EEA and under the age of 16, by authorizing your child to use the services, you are subject to the terms of this agreement and responsible for your child’s activity on the services. You can contact us to help you manage your child’s experience.

NOTICE TO CALIFORNIA RESIDENTS

To the extent any California data privacy law applies, we will provide California residents with certain information upon request (“Data Subject Request”). This supplemental section of our privacy policy outlines how California residents can receive the information and what you can receive and applies solely to California residents.

• Notice of Collection:

  Categories of Personal Information We May Collect	Categories of Sources	Examples of Uses	Categories of Third Parties With Which We May Share That Information
  Identifiers: name, billing and shipping addresses, email address, billing information, any provided phone numbers, such as home, mobile or fax, security password.	You, if you choose to provide to us. Your use of our Services/automatically collected from you. Affiliates. Third parties (such as service providers and other users who, for example, may refer you to use the services). Consumer data resellers. Public records databases.	Processing orders. Providing the services, including registration and customer service. Fixing and improving the services. Facilitating payment. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud and legal compliance.	Affiliates. Service providers. Other individuals or companies at your request. Third parties, such as third-party advertisers, and advertising and list brokering networks and analytics providers. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Commercial Information: Records of your purchases and transaction data.	You, if you choose to provide to us. Your use of our services/automatically collected from you. Affiliates. Third parties (such as service providers). Third Parties (such as data brokers).	Providing the services, including registration, processing orders or catalog requests and customer service. Fixing and improving the services. Facilitating payment. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud and legal compliance.	Affiliates. Service providers. Other individuals or companies at your request. Third parties, such as third-party advertisers and advertising and list brokering networks and analytics providers. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Financial Data: Credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us.	You, if you choose to provide to us. Third parties (such as service providers and third parties confirming payments made on your behalf). Affiliates.	Providing the Services. Processing orders. Facilitating payment. Fixing and improving the Services. Analyzing use of the Service. Security, fraud, and legal compliance.	Affiliates. Service providers. Other individuals or companies at your request. Third parties relating to legal requests, if required by law. Third parties for sales or transfers of our business or assets.
  Device Information and Identifiers: IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.	You (through your device). Advertising providers. Analytics providers. Cookies and tracking technologies.	Providing the services, including registration, processing orders or catalog requests and customer service. Fixing and improving the services. Facilitating payment. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud, and legal compliance.	Service providers. Affiliates. Other individuals, services, and partners at your request. Other third parties, such as third-party advertisers and advertising and list brokering networks. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Internet Network and Electronic Activity Device Information: Information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our services, the websites you visit after this website; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information.	You (through your device). Advertising providers. Analytics providers. Cookies and tracking technologies. Marketers. Our affiliates.	Providing the services, including registration and customer service. Fixing and improving the services. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud, and legal compliance.	Service providers. Affiliates. Other individuals, services, and partners at your request. Other third parties, such as third-party advertisers and advertising and list brokering networks. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Social media information (which may include personal identifiers, photos, location, user generated content, demographic information): If you link your account or access the services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter).	You, if you choose to provide to us. Social media networks, in accordance with your privacy preferences on such services.	Providing the services, including registration and customer service. Fixing and improving the services. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud, and legal compliance.	Service providers. Affiliates. Other individuals, services, and partners at your request. Other third parties, such as third-party advertisers and advertising and list brokering networks. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Location Information: General location, and, if you provide permission, precise GPS location.	You, if you choose to provide to us. Your use of our services/automatically collected from you. Third parties (such as service providers).	Providing the services, including registration, processing orders or catalog requests and customer service. Fixing and improving the services. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud, and legal compliance.	Service providers. Affiliates. Other individuals, services, and partners at your request. Other third parties, such as third-party advertisers and advertising and list brokering networks. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Sensory Information: Audio recordings if you call our customer service or volunteer this information as part of using our Services.	You, if you choose to provide to us. Your use of our Services/automatically collected from you. Third parties (such as service providers).	Providing the services, including registration and customer service. Fixing and improving the services. Facilitating payment. Analyzing and improving the services. Security, fraud, and legal compliance.	Service providers. Affiliates. Other individuals, services, and partners at your request. Other third parties, such as third-party advertisers and advertising and list brokering networks. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Survey and a testimonials information (including personal identifiers and user generated content): Collected if you participate in a survey or submit a testimonial; includes information needed for you to participate (such as contact information).	You, if you choose to provide to us. Survey partners.	Providing the services, including registration and customer service. Fixing and improving the services. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services. Security, fraud, and legal compliance.	Affiliates. Service providers. Other individuals or companies at your request. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.
  Personalization data about you	You, if you choose to provide to us. Your use of our services/automatically collected from you. Affiliates. Third parties (such as data brokers).	Providing the services, including registration and customer service. Fixing and improving the services. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Analyzing and improving the services. Security, fraud, and legal compliance.	Affiliates. Third parties (such as service providers).
  Other Information: Any other information you choose to directly provide to us in connection with your use of the services.	You, if you choose to provide to us.	Providing the services, including registration and customer service. Fixing and improving the services. Facilitating payment. Personalizing content and your experience. Our marketing and third-party marketing and advertising purposes. Bug detection and error reporting. Analyzing and improving the services Security, fraud, and legal compliance.	Service providers. Affiliates. Other individuals, services, and partners at your request. Other third parties, such as third-party advertisers and advertising and list brokering networks. Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary. Third parties for sales of transfers of our business or assets.

• Rights of California Residents
  • Data Subject Requests

    If you are a California resident, you may submit a data subject request to receive information about our data collection practices as it relates to your data. By submitting this request, you are declaring that you are a California resident availing yourself of the rights afforded to you under the California Consumer Privacy Act (CCPA).

    You may request information on the categories of personal information (as defined by California law) we have collected about you; the categories of data collection sources; any business or commercial purpose for collecting or selling personal information; the categories of third parties with whom we share personal information, if any; and the specific pieces of personal information we have collected about you. If you would like to also receive information about our data disclosure for business purposes, then please include that in the data subject request. We will clarify whether the information was collected and disclosed or simply collected and kept internally.

    If you would like to submit a data subject request, you can complete one online here. You can also call us, toll-free, at (877) 917-2077. If you complete our online form, it must be completed accurately and completely before we can respond. If you choose to submit a data subject request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive for verification. We will not be able to disclose information if we cannot verify that the person making the data subject request is the person about whom we collected personal information, or someone authorized to act on such person’s behalf.

• Do Not Sell My Personal Information

  The CCPA gives California residents the right to stop the “sale” of their personal information through a mechanism called “Do Not Sell My Personal Information” button or hyperlink.

  While there are many positive impacts of this requirement, California’s definition of “sale” also captures the transfer of data between corporate affiliates (that is, companies that share common ownership) and other transfers that ordinarily may not be thought of as a “sale” in the traditional sense of the word. Because the CCPA has defined some of these transfers as “sales,” we may be unable to offer all of our services to our users that ask us not to “sell” their personal information.

  California residents may utilize the “Do Not Sell My Personal Information” hyperlink located on our services to facilitate their opt-out of the sale of certain personal information. However, if you opt to request that we do not “sell” your personal Information you may not be able to use any service we offer that requires our continued use of your email address. Accordingly, users who direct us to stop “selling” their personal information may be asked to delete their account with us and their associated personal information. Users who make this request will still be able to access all of the services we offer on our website and through our services that are available to non-account holders and may always use a new email address to register a new account with our services.

  Please note that we will attempt to verify your identity via the email address and/or telephone number associated with your request prior to fulfilling it. If you authorize another person to make this request on your behalf, in addition to verifying your identity we will also require proof that the person is authorized to act on your behalf.

  Please note that the categories of personal information and sources will not exceed what is contained in this privacy policy. Additionally, we are not required to retain any personal information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. We are also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

• Deletion of Information

  You may request that we delete your personal information. Your deletion request should be submitted through a data subject request. Subject to certain exceptions set out below we will, on receipt of a verifiable data subject request, delete your personal information from our records and direct any service providers to do the same.

  Please note that we may not delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected
  • Provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
  • Detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk
  • Debug and repair internal information technology as necessary
  • Undertake internal research for technological development and demonstration
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law
  • Comply with the California Electronic Communications Privacy Act
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the personal information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
  • Comply with an existing legal obligation
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the personal information

• Non-Discrimination

  We may not, and will not, treat you differently because you of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

• Notice to Minors

  In addition, if you are a California resident under the age of 18 and are a registered user, you may request us to remove content or personal information posted on our websites or stored on our servers by (a) submitting a request in writing to insert email, and (b) clearly identifying the content or personal information you wish to have removed and providing sufficient information to allow us to locate the content or personal information to be removed. However, please note that we are not required to erase or otherwise eliminate content or personal information if (i) other state or federal laws require us or a third party to maintain the content or personal information; (ii) the content or personal information was posted, stored, or republished by another user; (iii) the content or personal information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted in this privacy policy on how to request removal of such content or personal information; and (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or personal information.

• Verifying Requests

  To help protect your privacy and maintain security, if you request access to or deletion of your Personal Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your pin information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).

• Shine the Light Requests

  California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by Bonadio to third parties for the third parties’ direct marketing purposes. To make an opt-out request of such disclosures, you can contact us in the following ways:

  Call us: 877.633.9840

• Additional Information

  If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This statement is available in alternative formats upon request by contacting us in the following ways:

  Call us: 877.633.9840

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify or amend this privacy policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements or other purposes. If we modify our privacy policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current privacy policy for any changes.

If you have any questions about this privacy policy or the personal information we have collected about you, please contact us in the following ways:

Call us: 877.633.9840

Last Updated on: July 6, 2021