MTN CONSULTING, LLC PRIVACY POLICY

Effective Date: July 10, 2018

Scope

MTN Consulting, LLC (“MTN”, “we”, “us” or “our”) respects the privacy of our users. This privacy policy (“Privacy Policy”) describes our privacy policy and the types of information we may collect from you or that you may provide when you visit or use our website at www.mtnconsulting.biz, or access our Blog located at www.mtnconsulting.biz/blog/ (together, “Website”), or use our services (collectively, all of the foregoing referred to as our “Services”), and our practices for collecting, using, maintaining, protecting and disclosing that information. This Privacy Policy applies to the data collected by us, or those working on our behalf, through information you enter or from the data imported from authorized and approved sources. It does not apply to data collected through other sites, products, or services not approved by us.
Our Privacy Policy describes:

• How and why we collect your Personal Information;
• How your Personal Information is used and protected;
• When and with whom we share your Personal Information; and
• What choices you can make about how we collect, use, and share your Personal Information.
• How we store, use, transfer, and retain your Personal Information.

If you are a resident of or subject to data privacy laws or regulations of a country outside of the United States, please see the additional provisions at the end of this Privacy Policy.
Below in this section are some of the highlights of the Privacy Policy. Please read this entire document for a full description of our policies.

HIGHLIGHTS OF OUR PRIVACY POLICY

The following presents highlights of our Privacy Policy. The details follow this section.
Personal Information
We collect your Personal Information for various purposes, such as, but not limited to, corresponding with you, informing you about your account, security updates and product information, processing your application, providing you with Services, processing your order, providing you with a subscription, and other purposes.
We may combine the information we collect from you with information obtained from other sources to help us improve its overall accuracy and completeness, and to help us improve our business and better tailor our interactions with you.
We may also collect information relating to your use of our Website through the use of various technologies, including cookies.
Overview of Uses of Your Data

• To create a user account.
• To fulfill your requests by us or by others involved in fulfillment.
• To contact you for customer satisfaction surveys, market research or in connection with certain transactions.
• To support products or services you have obtained from us.
• To share with our service providers who provide services to us in support of our business.
• To personalize your experience while you are on our Website, make navigation easier, and for Website usage statistics.

Your Choices
When we collect information from you, you may tell us that you do not want it used for further marketing contact.
You may also turn off cookies in your browser.
You can view, edit, or delete your Personal Information online or contact us to do so.
You can also opt out from receiving certain communications from us by emailing us.
Contacting Us
You may contact us using the Contact Information provided at the end of this Privacy Policy.

DETAILS OF OUR PRIVACY POLICY

Acknowledgement and Consent

By using or accessing our Website or the Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website or our Services. Your use of the Website and our Services is at all times subject to our Terms of Service (available at www.mtnconsulting.biz/terms/ (the “Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personally identifiable information. This is information which may be connected to you specifically as the individual to whom the information relates. Such information may include name, mailing address, email address, telephone number, or any other information defined as personally identifiable information (or similar term) by applicable laws (“Personal Information”). If you are a European citizen or resident, the definition may be different. Please see the section toward the end of this Privacy Policy. Personal Information does not include your personally identifiable information that has been deidentified, pseudonymized, anonymized, aggregated and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (the foregoing in this sentence being referred to as “De-Identified Personal Information”).

This Privacy Policy applies to information we collect:

• In email, text and other electronic messages between you and us.
• When and where available, through mobile and desktop applications, which provide dedicated non-browser-based interaction between you and us.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

We may also collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It may also include emails that you send to us separate from our Website. This Privacy Policy does not apply to Personal Information that you provide to us through means other than our Website. However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise. If for example, you are applying for membership, or, if applicable, for employment, either via our Website or offline, we may obtain information from third parties about membership, licensing, accreditation, certification, professional, and/or employment as part of a background check, among other information, as part of the application process. The Privacy Policy does not apply to Personal Information about you that we receive from other sources. However, we may combine the information received from these other sources with Personal Information collected through this Website. In those cases, we will apply the Privacy Policy to the combined information, unless specifically disclosed otherwise.

Other than as stated herein, this Privacy Policy does not apply to information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our website.

We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and Services, to provide and improve the Services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

We are not responsible for the practices of sites linked to from the Services, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.

Individuals under the Age of 18

As noted in the Terms, we do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 should provide any Personal Information to or on the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

Changes to Our Privacy Policy

We’re constantly working to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on our Website, or as part of communications involving or as part of the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to the new Privacy Policy, including all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

Information We Collect About You and How We Collect It

We collect several types of information from and about users, including Personal Information that is about you but individually does not identify you, such as, time and date of visits to our Website, etc., and/or, about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

• Directly from you when you provide it to us. When you sign up for the Services, you provide us with information such as your name and email address. We may also collect information from your public social media accounts.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us. The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to or purchasing our Services, posting material (where permitted) or requesting further Services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Website.
• • Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patters, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.

The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize and improve our Website.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include cookies, flash cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.

Cookies (or browser cookies)

A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies

These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies

These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or Service from our Website, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies

These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

We also use cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website which parts of our content interest you the most and which Service categories you request. This tracking uses De-Identified Personal Information data (i.e., data that cannot be identified as being specifically associated with you) and does not use your Personal Information. We will not combine this data with your other Personal Information without your express permission. 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. At any time, you can prevent the use of cookies like this in the future. To do so, you may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, you may be unable to access certain parts of our Website or your experience on our Website may be affected. Some of our contracted vendors and affinity partners are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons; GIF. Pages of our Website and our emails 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 or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our goods, services, and other offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.

IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically.

Information We Collect from Third Parties

We may collect information that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website.

• Third Party Services. If you link, connect, or login to your account with a third party service (e.g., Facebook, WeChat), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Your References. If someone has written a reference for you, it will be published on your public profile page.
• Background Information. For Subscribers, users, and visitors in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks.

Third-Party Use of Cookies and Other Tracking Technologies

First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Google

Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand use of our Services. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information for the following purposes:

• To present our Website and its contents to you.
• To provide you with information on products or services that you request from us.
• To provide you with services that you have requested.
• To process transaction payments
• To provide you with notices about your account, including expiration and renewal notices.
• To send you emails and newsletters with product, service, company, and other information.
• To communicate with you regarding information, features or offers that we believe will be of interest to you.
• To respond to your questions or other requests.
• To contact you with regard to the Website.
• To process any applications, changes to your account information.
• To process other information or Personal Information that you submit through this Website.
• To notify you about changes to our Website, our policies, terms or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• To provide access to restricted parts of our Website.
• To serve relevant information to you when you visit our Website or other third-party sites (including social media platforms).
• To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends and measuring demographics and interests.
• For internal purposes, such as Website and system administration or internal audits and reviews.
• To comply with applicable law(s) (for example, to comply with a search warrant, subpoena or court order) or to carry out professional ethics/conduct investigations.
• For analyzing how the Services are used, diagnosing service or technical problems, maintaining security, and personalizing content.
• To operate, maintain, and provide to you the features and functionality of the Services.

We retain your Personal Information for the longer of twelve months or until we no longer use your Personal Information for any of the purposes described above.

De-Identified Personal Information or non-Personal Information is aggregated for system administration and to monitor usage of the Website. It is utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content.

We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and, (f) help you efficiently access your information after you sign in.

We may use your Personal Information you provide to us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice is called “profiling”, which involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. You may object to such profiling at any time by contacting us (see Contact Information/User Rights below).

How We Share Your Information

Personal Information:

Broadly stated, we may disclose your Personal Information with third parties for the purpose of providing or improving the Services to you, who perform services on our behalf, or for marketing purposes. Disclosures may include the following types and purposes:

• Hosting providers for the secure storage and transmission of your data.
• Identity management providers for authentication purposes.
• Database software providers for the management and tracking of your data.
• Legal and compliance consultants, such as external counsel, external auditors, or tax consultants.
• Payment solution providers for the secure processing of payments you provide to us.
• Technology providers who assist in the development and management of our Website.
• Outbound call center providers, who may perform outreach on our behalf regarding our products and Services.
• Fulfillment and postal vendors for the fulfillment of our products and Services.
• Customer satisfaction surveying by service providers on our behalf.

Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms (including for billing and collection purposes), take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our Website; and (c) to exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

De-Identified Personal Information: We may share De-Identified Personal Information (such as anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services.

Disclosure/Assignment of Your Personal Information: Your Consent

You consent to our disclosure of your Personal Information and other information to a potential buyer or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, or transfer (whether by contract, merger or operation of law) of rights to your Personal Information and other information, with or without notice to you and without your further consent.

Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

• Your Personal Information is contained behind secured networks and a firewall and is only accessible by a limited number of persons and service providers who have special access rights to such systems, and are required to keep the information confidential.
• Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information.
• Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safer.
• We may store, retrieve, access, and transmit your Personal Information in the US, or in or from other countries.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. The information you share in public areas may be viewed by other users. We’ll never email you to ask for your password or other account information. If you receive such an email, please send it to us so we can investigate.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.

Data Retention

Following termination or deactivation of your account, we may retain your profile information and all information posted to public areas of the Website. Following termination or deactivation of your account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Privacy Policy and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your account without notice to you.

The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Services or for as long as we have another business purpose to do so and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration. The information we collect may be stored and processed in servers in or outside of the United States and wherever we and our service providers have facilities around the globe.

What You Can Access

Through your account settings, you may access and, in some cases, edit or delete certain information you’ve provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.

California Online Privacy Protection Act (CalOPPA”)

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom the business has shared such information during the immediately preceding calendar year. See more at the CalOPPA website. To obtain information under CalOPPA from us, please contact us. Please note that not all information sharing is covered by CalOPPA, and we will only include in our response information relating to our sharing practices for covered information. As required by CalOPPA, users can visit our Website anonymously by adjusting the settings in your browser.

Notices; Opting Out

By providing us with your email address (including by “following,” “liking,” linking your account to our Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity on the Service to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, or for any other purposes, please contact us at matt@mtnconsulting.biz.

Additional Information for Non-US Residents

IMPORTANT NOTICE: This Privacy Policy originates and is hosted on a Website located in the United States, which has different data protection laws from those of other nations, and particularly member nations in the European Union. Due to differing laws and legal practice, be aware that law enforcement agencies in the United States may have access to your Personal Information.

For European Citizens and Residents Only:

If you are a citizen or resident of the European Economic Area (“EEA”), or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. It may also be process your information by staff operating outside the EEA who works for us or for one of service providers. If required by applicable law, we will seek your explicit consent to process your Personal Information collected on our Website or volunteered by you.

The following provisions apply to you if you are a European citizen or resident. All processing of your Personal Information is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the “Directive”), and the implementations of the Directive in local legislation. As of May 25, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Information and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and our processing will take place in accordance with the GDPR. For purposes of the GDPR, we will be the “data controller” of Personal Information (referred to in the GDPR as “personal data”, and which is defined differently than in this Privacy Policy) we collect through the Website, unless we collect such information on behalf of a “data controller” in which case we will be a “data processor.” This Privacy Policy does not apply to websites, applications or services that do not display or link to this Privacy Policy or that display or link to a different privacy policy. For EU residents, to the extent any definition in this Privacy Policy conflicts with a definition under the GDPR, the GDPR definition shall control.

Your Rights

You have the right to have your Personal Data erased. You have the right to request a copy of your Personal Data. You have the right to have your Personal Data we collect corrected. You have the right to object to certain types of processing of your Personal Data. You can opt-out of certain uses of your Personal Data. For any of these, please contact us.

Data Transfers

We are headquartered in the United States. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the EEA or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.

If you are a resident of country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.