Mployer Advisor Privacy and Cookie Policy

Revised July 4th, 2020.

Welcome to Mployer Advisor website (the “Platform”). First and foremost, we take the privacy of your Personal Data and other information extremely seriously. We would like you to know that we will take commercially practicable precautions to ensure the security and privacy of your information. We also want you to know what information we collect, why and how we will treat that information. This Privacy Policy (the “Policy”) is for you. It includes important information regarding your Personal Data and other information. Please read it carefully.

This Policy applies only to information we collect, process and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.

I. Information

Voluntarily Shared Information

In order for us to best provide our services to you, it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.

When you register, fill out your profile, search for specific information or provide us with other personal or company information actively, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change.

Depending on how you interact with our Platform, the personal information we collect from you may vary. For example, if you are an employer and are searching for information, we may only ask you to create an account with a user name and password. If you are an insurance broker, agent or consultant, we may ask you for additional information that could be beneficial to searchers on the Platform and to you.

If you connect to the Platform using Facebook, Google+, or another social networking site (each a "Social Networking Site"), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, birthday, current city work, school, and email address. When we receive this information, it becomes Mployer Advisor account information for purposes of your use of the Platform. This information also constitutes personal information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site's privacy and data practices. You have the ability to disconnect your Social Networking Site account from your Mployer Advisor account by adapting the privacy settings in your Social Networking Site account. If you come to the Platform through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.

On certain Mployer Advisor domains, when you set up an individual user account on the Platform, you may create a profile (a "Profile") that will include personal information about you and or your firm that you provide. At your request, we will create your Profile with information you provide. When you fill out and save your Profile, your saved Profile can be viewed by prospective employers, subject to visibility settings you control. Because your anonymity on our Platform is important, your Profile does not include or link to information you submit to the Platform anonymously, for example reviews.

If you enter credit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.

II. Auto-generated Stats

When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform including Cookies, Log File information and Device Information.

Automated means of data collection include the following:

Cookies and Tracking Technologies. Technologies such as: cookies, web beacons, locally shared objects (sometimes called "flash cookies"), mobile identifiers and similar technologies ("Cookies") are used by Mployer Advisor and our partners (such as advertising, marketing and analytics providers) ("Ad Partners"). We use Cookies to remember users’ settings as well as for authentication and analytics. These technologies may be used in analyzing trends, administering the Platform, tracking users’ movements around the Platform and to gather demographic information about our user base as a whole. Our Ad Partners may also use such technologies to deliver advertisements to you. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our website or service.

Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access an Mployer Advisor website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.

Device Information. We collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

How We Use Information

We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. So it is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:

When we collect any information that does not identify you as a specific natural person ("Non-Personal Information"), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, including gender, dates of birth, ZIP codes, etc.; or any personal information that has been anonymized, aggregated or de-identified. If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.

How We Share Information

We only disclose your personal information to third parties as follows:

We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business subject to strict confidentiality agreements. These companies are authorized to use your personal information only as necessary to provide these services to us;

We may also share your information with Mployer Advisor affiliates, namely any entity that directly or indirectly controls, is controlled by, or is under common control with Mployer Advisor. Such affiliates shall process your personal data where we believe it is necessary for the purposes of a legitimate interest, and where such purposes are aligned with those for which you provided your personal data to us. These instances and processing activities are outlined in the "How We Use Your Information" section above.

We will disclose data If we believe in good faith such disclosure is necessary (1) to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us (though we reserve the right to take action on behalf of our users to defend their right to anonymity when we believe there is a legitimate basis to do so, because candid, lawful, anonymous free speech is fundamental to Mployer Advisor’s mission of workplace transparency); (2) to enforce our Mployer Advisor Terms of Use and Privacy Policy; (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (4) as we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of us, the users of our services, or third parties; or (5) as permitted under applicable laws to meet national security and similar requirements;

In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;

We share certain information that does not identify you personally, but which is unique to your use of the Platform, such as job titles that you have entered at the time of registration or on your profile. When we share such information, we do not link job titles with your name when we provide this information to others, such as advertisers, recruiters or employers;

We will otherwise share personal information with your consent.

Cookie Policy and Ad Choices

This Cookie Policy describes how Mployer Advisor, Inc. ("we", "our", "us") uses Cookies and similar technologies.

Cookies

Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. We use cookies, web beacons, locally shared objects (sometimes called "flash cookies"), mobile identifiers and similar technologies ("Cookies") to help us recognize you on the Platform, enhance your user experience, understand usage of the Platform, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you're visiting. After you register on the Platform, we may connect information we collect from the Cookies set by us and our partners with other information received from you. The provision of your data via Cookies is voluntary except for those Cookies that we place on your device because we need them for the performance of our Platform and our services.

What types of Cookies do we use?

We use two types of Cookies on the Platform: "session cookies" and "persistent cookies." Session Cookies are temporary Cookies that remain on your device until you leave the Platform. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or "lifetime" of the specific Cookie and your browser settings).

What are Cookies used for?

Cookies transmit information about you and your use of the Platform, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information such as the job titles that you entered at time of registration or on your profile, but this is not linked to your name.

We use Cookies for things like:

Other Important Privacy Information

International Resident Rights

If you are a resident of the European Economic Area, or any other country providing it's residents the rights substantially similar to the GDPR, you have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the "Contact us" section of our site.

You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Choices Regarding Your Personal Information

We will send you notifications and if, and to the extent, you have opted-in to promotional communications, or other messages using the contact information (e.g., your email address, your mobile device identifier) you provided to us when you registered or when you requested information from us. You may opt-out of continuing to receive optional messages by following the instructions included in each message. Also, you can control most of the emails you receive from us by editing your email preferences within "My Account" settings on the site; provided you will need to separately opt-out of receiving our various blog post update emails by unsubscribing to each blog that you have originally subscribed to.

We will send you service-related announcements when we believe it is necessary to do so. Generally, you cannot opt-out of these announcements, which are not primarily promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your account. In some cases, you can stop or limit the information we collect by automated means.

Close Your Account

If you'd like to close your Mployer Advisor account, you can do so within your Account Settings on the Platform.

How Long We Keep Your Personal Information

We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

Security Safeguards

Security. We employ physical, electronic, and managerial measures to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. You are responsible for keeping your username and password secret. Once you have registered with us, we will never ask you for your password. Please create a unique password for your Mployer Advisor account and do not use it for any other web services or applications. Do not share your password with anyone else.  It is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee the security of your Personal Data, or any other information, transmitted to or through any of our Site. Any transmission of Personal Data, or other information, is at your own risk. By using our Site, you acknowledge and accept these risks. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information. It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Site. Any transmission of information is at your own risk.  If you have any questions about security on our Site, or if you become aware of any unauthorized use of an account, loss of your account credentials, or suspect a security breach, notify us immediately via [email].  If our security system is breached, we will notify you of the breach to the extent required under applicable law.

Privacy of Minors

To access or use the Platform you must be at least 18 years of age or, if older, the age of majority in your jurisdiction, otherwise you may not use the Platform. We do not sell products or services to anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit personal data from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such personal data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Site.

Data Controller

The information about you that we collect, process and/or use through the Platform is controlled by Mployer Advisor. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

Updates to Our Privacy Policy

We may revise this Policy from time to time by posting an updated version on the Platform. The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately. However they can object to the new Policy within thirty (30) days after the revision date. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy.

Contact Us

If you have any questions or suggestions regarding this Policy, please contact us via the contact us form on our website.

 

Privacy Notice for California Residents

Effective Date: DATE

Last Updated: October 19, 2020

 

Introduction

This Privacy Notice for California Residents (the “Notice”) supplements the information contained in the Mployer Advisor, Inc. (“Mployer,” “we,” “us,” “our”) Privacy Policy https://www.mployeradvisor.com/privacy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (“user(s),” “you,” or “your”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice governs our Site and Services, as those terms are defined in the Privacy Policy.

 

1. Information We Collect

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). Below, we have provided a list of categories of Personal Information and examples of the types of Personal Information that may fall within those categories. For clarity, even where we indicate that we collect a category of Personal Information, we may not collect all types of Personal Information described in that category. 

 

Within the last twelve (12) months, our Services have collected the following categories of Personal Information from consumers:

 

Category Examples Collected

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. YES

C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES

E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO

F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES

G. Geolocation data. Physical location or movements. NO

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO

I. Professional or employment-related information. Current or past job history or performance evaluations. YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO

K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

 

Mployer obtains the categories of Personal Information listed above from the following categories of sources: 

· Directly from you. For example, from information you provide through the Site and Services and through any correspondences, such as when you request to receive information or support.

· Indirectly from you. For example, from observing your actions on our Site through the use of automated data collection tools.

 

2. Use of Personal Information

We may use, sell, or disclose the Personal Information we collect for one or more of the following purposes:

 

· To fulfill or meet the reason you provided the Personal Information.  For example, if you share your name and contact information to ask a question about our Site, we will use that Personal Information to respond to your inquiry. 

· To establish and secure accounts to use the Services, check on your account status, and to validate your username, e-mail, password, and/or other login credentials.

· To provide, support, personalize, and develop our Services, including without limitation, to conduct aggregate or research analysis and develop business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services.

· To communicate information and promotional materials to you, where you have not expressed a preference otherwise, and to send you information and updates about the Services.

· To notify you of any changes to relevant agreements, policies, or other terms, and to enforce such terms.

· To work with our service providers, who perform certain business functions or services on our behalf and who are bound by contractual obligations consistent with this Privacy Policy.

· To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Site, databases and other technology assets, and business.

· To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other 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 consumers is among the assets transferred.

· As otherwise described to you when collecting your Personal Information or as set forth in the CCPA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

3. Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose or sell your Personal Information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights, below). When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

 

We share your Personal Information with the following categories of third parties:

· Corporate affiliates, including corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Notice which are required to treat the information in accordance with this Notice.

· Service providers and other third parties that help us administer and provide the Site and Services (for example, a web hosting company whose services we use to host our platform).  These third parties have access to your Personal Information only for the purpose of performing services on our behalf. We have entered into contractual relationships with these service providers and require them to comply with all applicable information privacy laws and regulations and to use the Information only for the purposes for which it was disclosed.  We require that any third-party service providers limit their use of your Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Information and not make unauthorized use or disclosure of the Information;

· Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such information in accordance with this Privacy Policy; 

· Data brokers or aggregators who may, for example, use the information to compile combined datasets for behavioral analysis or profiling.

 

4. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Mployer has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category D: Commercial information.

Category E: Internet or other similar network activity.

Category F: Geolocation data.

Category G: Sensory data.

Category H: Professional or employment-related information.

Category I: Inferences drawn from other Personal Information.

 

We disclose your Personal Information for a business purpose to the following categories of third parties:

 

· Corporate affiliates, including corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Notice which are required to treat the information in accordance with this Notice;

· Service providers and other third parties that help us administer and provide the Site and Services (for example, a web hosting company whose services we use to host our platform); 

· Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such information in accordance with this Privacy Policy.

 

5. Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. The following sections describe your CCPA rights and explains how to exercise those rights.

 

6. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights, below), we will disclose to you:

· The categories of Personal Information we collected about you.

· The categories of sources for the Personal Information we collected about you.

· Our business or commercial purpose for collecting or selling that Personal Information.

· The categories of third parties with whom we share that Personal Information.

· The specific pieces of Personal Information we collected about you (also called a data portability request).

 

7. Deletion Request Rights 

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights, below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 

 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

1.  Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2.  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.  Debug products to identify and repair errors that impair existing intended functionality.

4.  Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.  Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6.  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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7.  Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.  Comply with a legal obligation.

9.  Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

8. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

· Calling us at 703-643-4736.

· Visiting www.mployeradvisor.com/contact-us.

· [email protected] 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent to act on your behalf with respect to the rights contained in this Notice, we may require proof from the agent that you have provided the authorized agent written permission to do so, and we may require that you verify your own identity directly with us. If you have provided the agent with power of attorney, that may be sufficient.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. To verify your requests, we ask that you provide information required to match the request with the consumer about whom information has been collected or utilize the authentication practices for your password-protected account. We verify requests by matching information you provide to information that we maintain in our records. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

 

9. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, up to an additional forty-five (45) days, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically .CSV.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

 

10. Non-Discrimination

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

· Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

· Provide you a different level or quality of goods or services.

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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

 

11. Other California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to ¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬[email protected]

 

12. Changes to Our Privacy Notice

Mployer reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Site and update the Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

 

13. Contact Information

If you have any questions or comments about this notice, the ways in which Mployer collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our representative(s) at the following: 

 

By e-mail: [email protected]

By telephone: 703-643-4736

By regular mail: Mployer Advisor, Inc.

 

 

 

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