1. Information We Collect
1.1. Personal Information- When you use the Sites or Services, we collect certain information from you which can be used to contact or identify you, including, but not limited to, your name, gender, date of birth, telephone number, postal address, and email address (“Identity Information”). If you place an order for Services and/or pay a fee, we will collect additional payment and billing information from you, including, but not limited to, your credit/debit card information or bank account information (“Billing Information”). If you place an order for Services, you may also be required to provide information or documents necessary for preparation or filing of forms or applications to be submitted to government agencies. Your Identity Information, Billing Information, Application Information, and Usage Data (defined below) are referred to as “Personal Information.”
1.2. Usage Data- we automatically collect certain information regarding your access to and use of the Sites and Services. This information includes your computer or device hardware and software, IP address, browser type, referring website URLs, domain names, access times, log files, pages on the Sites that you visit, and links you click on (“Usage Data”).
1.4. EU Lawful Grounds- If you reside in the European Economic Area or Switzerland (collectively the “EU”), we rely on the following lawful grounds under the General Data Protection Regulation (“GDPR”) to process (collect, store, and use) your personal data contained in Personal Information and Usage Data: (a) it is necessary for the performance of a contract with you; (b) our legitimate interests; and (c) your consent. If you are a customer, the lawful ground for processing your personal data is necessary in performing our contract to provide the Services to you; our legitimate interest in understanding, improving, and promoting our services; and your consent. If you visit or use our websites, the lawful ground for processing your personal data is our legitimate interest in understanding how users interact with our websites to improve our websites and Services, and your consent.
2. Use of Information We Collect
2.1. Account Creation- We use information you submit to us at the time of account registration, such as your name and email address, and any updated information you subsequently submit, such as a new email address, to create and maintain your account.
2.3. Customer Service and Technical Support- We may use your information, including Personal Information, to respond to questions you have regarding use of our Services or to provide technical assistance.
2.4. Communications with You- We may contact you using the contact information you provide in order to respond to inquiries you send to us, to communicate with you regarding our Services and the services of our partners, and to market our Services, or those of our partners, to you. We may also send you emails advertising or promoting our Services or those of our partners. If you do not wish to receive such emails, you can choose to opt-out of receipt using the unsubscribe link within each email, or by sending an unsubscribe request to email@example.com. We also may use information about you, including Personal Information, to improve the effectiveness of our marketing and advertising efforts.
2.5. Internal Research- We may use information about you, including Personal Information, and other users, in aggregate form, for our own internal research and analytical purposes. For example, we may use certain types of your information to understand which features of our Services are being used most frequently.
3. Information Sharing and Disclosure
3.1. Your Privacy Rights- MLOS does not share your Personal Information with third parties for their marketing purposes without your consent. MLOS does not sell, rent, or lease its customer lists to third parties.
3.2. Upon Consent- We may share your information, including Personal Information, with third parties if you provide us with authorization to do so. For example, if you include Personal Information in a review or testimonial of our Services for posting to social media platforms, such information will be publicly disclosed upon posting.
3.3. Service Providers- We may share your Personal Information with third-party service providers, but only to the extent necessary for them to assist us in providing our Services. For example, if you purchase Services, we will share your Billing Information with third-party payment processors to the extent necessary to process your payment. We use written contracts to require all third-party service providers to protect the security of your Personal Information, to keep your Personal Information confidential, and to use such information for no other purposes.
3.4. Responses to Legal Process- We will not voluntarily disclose your Personal Information. However, we may disclose your Personal Information as required by law, such as in response to a court order, subpoena, or similar legal process legally requiring us to produce the information. If legally permitted and feasible, we will give you notice of our receipt of a demand for your Personal Information and provide you a reasonable time in which to seek to quash such demand in court, or otherwise obtain a withdrawal or modification of the demand, before complying with the demand.
3.5. Business Transfers- Your Personal Information may be included in the event that some or all of our assets are sold, assigned or transferred in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. As a general matter, however, an acquiring party cannot retroactively change the Privacy Notice that was in place when MLOS collected your Personal Information.
3.6. Academic Research- We may share non-personally identifiable and non-privileged information about you and other users, in aggregate form, to third-party academic researchers. We require all third-party researchers to use such anonymized information for no purposes other than academic research. For example, we may use certain types of non-personally identifiable and non-privileged information to help researchers study factors that reduce barriers facing applicants navigating the immigration system. If you are in the EU, we will only share your non-privileged information with such academic researchers with your consent.
3.7. Third Party Cookies- We use Google AdWords Conversion tracker and other Google services (collectively “Google Cookies”) that place cookies on a browser. These cookies help us increase our Sites effectiveness for our visitors. These cookies are set and read by Google. To learn more about Google Cookies and how to opt out, please visit https://policies.google.com/technologies/ads.
We also use AdWords remarketing to market our Sites across the web. It places cookies on a browser that are then read by Google or other third parties, such as advertising networks, which may then serve you an ad on a third-party website. You may opt out of this type of ad serving using the link to Google or by visiting the Network Advertising Initiative opt-out page at https://www.networkadvertising.org/choices/.
Our Sites and Services are not intended for persons under 18 years of age, and we do not knowingly collect Personal Information from persons under 18 years of age. If you are a parent or guardian and believe that your child has provided us with Personal Information without your consent, please contact us at firstname.lastname@example.org. If we become aware that a person under 18 years of age has provided us with Personal Information, we will delete such information from our files upon adequate notice.
5. EU Data Transfer and Individual Rights
5.1. Data Transfer Notice- We are located in the United States and transfer your personal data for processing in the United States. We make the transfer to the United States in the absence of an adequacy decision because it is necessary for the performance of a contract with you or because of your explicit consent. We may transfer your personal data to a processor located outside of the EU to assist us in providing our Services for which we enter standard contractual clauses with the processor for such transfers.
5.2. Individual Rights- If you are located in the EU, you may use your account to access, correct, or change Personal Information that you have provided to us. You may also email us at email@example.com to request access to, transfer of, and rectification or erasure of your Personal Information or restriction of processing; and to object to processing. In the email, specify the nature of your request and the information that is the subject of your request. We will respond to your request within 30 days.
If we are processing your personal data based upon the lawful ground of your consent, you have the right to withdraw your consent for such processing at any time without affecting the lawfulness of the processing based on consent before it is withdrawn. To withdraw consent, email us at firstname.lastname@example.org.
We have put in place physical, electronic and managerial procedures to protect the security of the information we collect, both during transmission and once received. This includes, but is not limited to, encryption, access control and audit logging on Personal Information. However, no method of transmission over the internet or method of storage is 100% secure. We cannot guarantee that our security measures will prevent our computer systems from being accessed illegally, nor can we guarantee that the information on our computer systems will not be viewed or stolen. ACCORDINGLY, MLOS DISCLAIMS ALL LIABILITY FOR THE THEFT, INTERCEPTION, LOSS, OR UNAUTHORIZED ACCESS TO DAMAGE TO YOUR INFORMATION. YOU ACKNOWLEDGE THAT USE OF THE SITES AND SERVICES IS AT YOUR OWN RISK.
7. Google Analytics
8. Changes to Privacy Notice
MLOS may make changes to this Privacy Notice at any time. If we make any material changes we will notify you via email (sent to the e-mail address specified in your account) or by posting the revised Privacy Notice on the Sites prior to any changes becoming effective. You should review our Privacy Notice each time you access the Sites or use the Services. Your continued use of the Sites or Services following the posting of any changes or notice to you of the changes constitutes your agreement to such changes.
9. Retention of Personal Information
At a minimum, we will retain your Personal Information for as long as it may be needed to provide you Service and as needed to comply with our legal obligations. Unless you request deletion of your Personal Information sooner, we may hold any of your Personal Information which may be used to provide future Services for up to ten years. Upon request, MLOS will inform you about whether we hold any of your Personal Information. You may terminate your account and request deletion of your Personal Information by contacting us at email@example.com. In some situations, we may be legally required to retain your Personal Information or for other reasons will not be able to comply with a request to delete data.
Questions can be directed to: MLOS at the following address: PO Box 994, Ada, MI 49301, firstname.lastname@example.org.
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