Privacy Policy



Last updated: August 15, 2020




This Privacy Policy describes Our policies and procedures on the collection,


use and disclosure of Your information when You use the Service and tells You


about Your privacy rights and how the law protects You.




We use Your Personal data to provide and improve the Service. By using the


Service, You agree to the collection and use of information in accordance with


this Privacy Policy.




Interpretation and Definitions


==============================




Interpretation


--------------




The words of which the initial letter is capitalized have meanings defined


under the following conditions. The following definitions shall have the same


meaning regardless of whether they appear in singular or in plural.




Definitions


-----------




For the purposes of this Privacy Policy:




* Account means a unique account created for You to access our Service or


parts of our Service.




* Business , for the purpose of the CCPA (California Consumer Privacy Act),


refers to the Company as the legal entity that collects Consumers'


personal information and determines the purposes and means of the


processing of Consumers' personal information, or on behalf of which such


information is collected and that alone, or jointly with others,


determines the purposes and means of the processing of consumers' personal


information, that does business in the State of California.




* Company (referred to as either "the Company", "We", "Us" or "Our" in this


Agreement) refers to Mordent Group LLC, PO Box 210610, Auburn Hills MI


48321.




For the purpose of the GDPR, the Company is the Data Controller.




* Consumer , for the purpose of the CCPA (California Consumer Privacy Act),


means a natural person who is a California resident. A resident, as


defined in the law, includes (1) every individual who is in the USA for


other than a temporary or transitory purpose, and (2) every individual who


is domiciled in the USA who is outside the USA for a temporary or


transitory purpose.




* Cookies are small files that are placed on Your computer, mobile device or


any other device by a website, containing the details of Your browsing


history on that website among its many uses.




* Country refers to: Michigan, United States




* Data Controller , for the purposes of the GDPR (General Data Protection


Regulation), refers to the Company as the legal person which alone or


jointly with others determines the purposes and means of the processing of


Personal Data.




* Device means any device that can access the Service such as a computer, a


cellphone or a digital tablet.




* Do Not Track (DNT) is a concept that has been promoted by US regulatory


authorities, in particular the U.S. Federal Trade Commission (FTC), for


the Internet industry to develop and implement a mechanism for allowing


internet users to control the tracking of their online activities across


websites.




* Personal Data is any information that relates to an identified or


identifiable individual.




For the purposes for GDPR, Personal Data means any information relating to


You such as a name, an identification number, location data, online


identifier or to one or more factors specific to the physical,


physiological, genetic, mental, economic, cultural or social identity.




For the purposes of the CCPA, Personal Data means any information that


identifies, relates to, describes or is capable of being associated with,


or could reasonably be linked, directly or indirectly, with You.




* Sale , for the purpose of the CCPA (California Consumer Privacy Act),


means selling, renting, releasing, disclosing, disseminating, making


available, transferring, or otherwise communicating orally, in writing, or


by electronic or other means, a Consumer's Personal information to another


business or a third party for monetary or other valuable consideration.




* Service refers to the Website.




* Service Provider means any natural or legal person who processes the data


on behalf of the Company. It refers to third-party companies or


individuals employed by the Company to facilitate the Service, to provide


the Service on behalf of the Company, to perform services related to the


Service or to assist the Company in analyzing how the Service is used. For


the purpose of the GDPR, Service Providers are considered Data Processors.




* Third-party Social Media Service refers to any website or any social


network website through which a User can log in or create an account to


use the Service.




* Usage Data refers to data collected automatically, either generated by the


use of the Service or from the Service infrastructure itself (for example,


the duration of a page visit).




* Website refers to Mordent Group, accessible from


[mordentgroup.com](mordentgroup.com)




* You means the individual accessing or using the Service, or the company,


or other legal entity on behalf of which such individual is accessing or


using the Service, as applicable.




Under GDPR (General Data Protection Regulation), You can be referred to as


the Data Subject or as the User as you are the individual using the


Service.




Collecting and Using Your Personal Data


=======================================




Types of Data Collected


-----------------------




Personal Data


~~~~~~~~~~~~~




While using Our Service, We may ask You to provide Us with certain personally


identifiable information that can be used to contact or identify You.


Personally identifiable information may include, but is not limited to:




* Email address




* First name and last name




* Phone number




* Address, State, Province, ZIP/Postal code, City




* Usage Data






Usage Data


~~~~~~~~~~




Usage Data is collected automatically when using the Service.




Usage Data may include information such as Your Device's Internet Protocol


address (e.g. IP address), browser type, browser version, the pages of our


Service that You visit, the time and date of Your visit, the time spent on


those pages, unique device identifiers and other diagnostic data.




When You access the Service by or through a mobile device, We may collect


certain information automatically, including, but not limited to, the type of


mobile device You use, Your mobile device unique ID, the IP address of Your


mobile device, Your mobile operating system, the type of mobile Internet


browser You use, unique device identifiers and other diagnostic data.




We may also collect information that Your browser sends whenever You visit our


Service or when You access the Service by or through a mobile device.




Tracking Technologies and Cookies


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~




We use Cookies and similar tracking technologies to track the activity on Our


Service and store certain information. Tracking technologies used are beacons,


tags, and scripts to collect and track information and to improve and analyze


Our Service.




You can instruct Your browser to refuse all Cookies or to indicate when a


Cookie is being sent. However, if You do not accept Cookies, You may not be


able to use some parts of our Service.




Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on


your personal computer or mobile device when You go offline, while Session


Cookies are deleted as soon as You close your web browser. Learn more about


cookies: [All About Cookies](https://www.termsfeed.com/blog/cookies/).




We use both session and persistent Cookies for the purposes set out below:




* Necessary / Essential Cookies




Type: Session Cookies




Administered by: Us




Purpose: These Cookies are essential to provide You with services


available through the Website and to enable You to use some of its


features. They help to authenticate users and prevent fraudulent use of


user accounts. Without these Cookies, the services that You have asked for


cannot be provided, and We only use these Cookies to provide You with


those services.




* Cookies Policy / Notice Acceptance Cookies




Type: Persistent Cookies




Administered by: Us




Purpose: These Cookies identify if users have accepted the use of cookies


on the Website.




* Functionality Cookies




Type: Persistent Cookies




Administered by: Us




Purpose: These Cookies allow us to remember choices You make when You use


the Website, such as remembering your login details or language


preference. The purpose of these Cookies is to provide You with a more


personal experience and to avoid You having to re-enter your preferences


every time You use the Website.




* Tracking and Performance Cookies




Type: Persistent Cookies




Administered by: Third-Parties




Purpose: These Cookies are used to track information about traffic to the


Website and how users use the Website. The information gathered via these


Cookies may directly or indirectly identify you as an individual visitor.


This is because the information collected is typically linked to a


pseudonymous identifier associated with the device you use to access the


Website. We may also use these Cookies to test new pages, features or new


functionality of the Website to see how our users react to them.




For more information about the cookies we use and your choices regarding


cookies, please visit our Cookies Policy or the Cookies section of our Privacy


Policy.




Use of Your Personal Data


-------------------------




The Company may use Personal Data for the following purposes:




* To provide and maintain our Service , including to monitor the usage of


our Service.


* To manage Your Account: to manage Your registration as a user of the


Service. The Personal Data You provide can give You access to different


functionalities of the Service that are available to You as a registered


user.


* For the performance of a contract: the development, compliance and


undertaking of the purchase contract for the products, items or services


You have purchased or of any other contract with Us through the Service.


* To contact You: To contact You by email, telephone calls, SMS, or other


equivalent forms of electronic communication, such as a mobile


application's push notifications regarding updates or informative


communications related to the functionalities, products or contracted


services, including the security updates, when necessary or reasonable for


their implementation.


* To provide You with news, special offers and general information about


other goods, services and events which we offer that are similar to those


that you have already purchased or enquired about unless You have opted


not to receive such information.


* To manage Your requests: To attend and manage Your requests to Us.




We may share your personal information in the following situations:




* With Service Providers: We may share Your personal information with


Service Providers to monitor and analyze the use of our Service, to


advertise on third party websites to You after You visited our Service,


for payment processing, to contact You.


* For Business transfers: We may share or transfer Your personal information


in connection with, or during negotiations of, any merger, sale of Company


assets, financing, or acquisition of all or a portion of our business to


another company.


* With Affiliates: We may share Your information with Our affiliates, in


which case we will require those affiliates to honor this Privacy Policy.


Affiliates include Our parent company and any other subsidiaries, joint


venture partners or other companies that We control or that are under


common control with Us.


* With Business partners: We may share Your information with Our business


partners to offer You certain products, services or promotions.


* With other users: when You share personal information or otherwise


interact in the public areas with other users, such information may be


viewed by all users and may be publicly distributed outside. If You


interact with other users or register through a Third-Party Social Media


Service, Your contacts on the Third-Party Social Media Service may see


Your name, profile, pictures and description of Your activity. Similarly,


other users will be able to view descriptions of Your activity,


communicate with You and view Your profile.




Retention of Your Personal Data


-------------------------------




The Company will retain Your Personal Data only for as long as is necessary


for the purposes set out in this Privacy Policy. We will retain and use Your


Personal Data to the extent necessary to comply with our legal obligations


(for example, if we are required to retain your data to comply with applicable


laws), resolve disputes, and enforce our legal agreements and policies.




The Company will also retain Usage Data for internal analysis purposes. Usage


Data is generally retained for a shorter period of time, except when this data


is used to strengthen the security or to improve the functionality of Our


Service, or We are legally obligated to retain this data for longer time


periods.




Transfer of Your Personal Data


------------------------------




Your information, including Personal Data, is processed at the Company's


operating offices and in any other places where the parties involved in the


processing are located. It means that this information may be transferred to —


and maintained on — computers located outside of Your state, province, country


or other governmental jurisdiction where the data protection laws may differ


than those from Your jurisdiction.




Your consent to this Privacy Policy followed by Your submission of such


information represents Your agreement to that transfer.




The Company will take all steps reasonably necessary to ensure that Your data


is treated securely and in accordance with this Privacy Policy and no transfer


of Your Personal Data will take place to an organization or a country unless


there are adequate controls in place including the security of Your data and


other personal information.




Disclosure of Your Personal Data


--------------------------------




Business Transactions


~~~~~~~~~~~~~~~~~~~~~




If the Company is involved in a merger, acquisition or asset sale, Your


Personal Data may be transferred. We will provide notice before Your Personal


Data is transferred and becomes subject to a different Privacy Policy.




Law enforcement


~~~~~~~~~~~~~~~




Under certain circumstances, the Company may be required to disclose Your


Personal Data if required to do so by law or in response to valid requests by


public authorities (e.g. a court or a government agency).




Other legal requirements


~~~~~~~~~~~~~~~~~~~~~~~~




The Company may disclose Your Personal Data in the good faith belief that such


action is necessary to:




* Comply with a legal obligation


* Protect and defend the rights or property of the Company


* Prevent or investigate possible wrongdoing in connection with the Service


* Protect the personal safety of Users of the Service or the public


* Protect against legal liability




Security of Your Personal Data


------------------------------




The security of Your Personal Data is important to Us, but remember that no


method of transmission over the Internet, or method of electronic storage is


100% secure. While We strive to use commercially acceptable means to protect


Your Personal Data, We cannot guarantee its absolute security.




Detailed Information on the Processing of Your Personal Data


============================================================




Service Providers have access to Your Personal Data only to perform their


tasks on Our behalf and are obligated not to disclose or use it for any other


purpose.




Analytics


---------




We may use third-party Service providers to monitor and analyze the use of our


Service.




* Google Analytics




Google Analytics is a web analytics service offered by Google that tracks


and reports website traffic. Google uses the data collected to track and


monitor the use of our Service. This data is shared with other Google


services. Google may use the collected data to contextualize and


personalize the ads of its own advertising network.




You can opt-out of having made your activity on the Service available to


Google Analytics by installing the Google Analytics opt-out browser add-


on. The add-on prevents the Google Analytics JavaScript (ga.js,


analytics.js and dc.js) from sharing information with Google Analytics


about visits activity.




For more information on the privacy practices of Google, please visit the


Google Privacy & Terms web page: <https://policies.google.com/privacy>




Email Marketing


---------------




We may use Your Personal Data to contact You with newsletters, marketing or


promotional materials and other information that may be of interest to You.


You may opt-out of receiving any, or all, of these communications from Us by


following the unsubscribe link or instructions provided in any email We send


or by contacting Us.




We may use Email Marketing Service Providers to manage and send emails to You.




* HighLevel




Their Privacy Policy can be viewed at


<https://www.gohighlevel.com/privacy-policy>




Payments


--------




We may provide paid products and/or services within the Service. In that case,


we may use third-party services for payment processing (e.g. payment


processors).




We will not store or collect Your payment card details. That information is


provided directly to Our third-party payment processors whose use of Your


personal information is governed by their Privacy Policy. These payment


processors adhere to the standards set by PCI-DSS as managed by the PCI


Security Standards Council, which is a joint effort of brands like Visa,


Mastercard, American Express and Discover. PCI-DSS requirements help ensure


the secure handling of payment information.




* Stripe




Their Privacy Policy can be viewed at <https://stripe.com/us/privacy>




* PayPal




Their Privacy Policy can be viewed at


<https://www.paypal.com/webapps/mpp/ua/privacy-full>




Behavioral Remarketing


----------------------




The Company uses remarketing services to advertise on third party websites to


You after You visited our Service. We and Our third-party vendors use cookies


to inform, optimize and serve ads based on Your past visits to our Service.




* Google Ads (AdWords)




Google Ads (AdWords) remarketing service is provided by Google Inc.




You can opt-out of Google Analytics for Display Advertising and customise


the Google Display Network ads by visiting the Google Ads Settings page:


<http://www.google.com/settings/ads>




Google also recommends installing the Google Analytics Opt-out Browser


Add-on - <https://tools.google.com/dlpage/gaoptout> \- for your web


browser. Google Analytics Opt-out Browser Add-on provides visitors with


the ability to prevent their data from being collected and used by Google


Analytics.




For more information on the privacy practices of Google, please visit the


Google Privacy & Terms web page: <https://policies.google.com/privacy>




* Bing Ads Remarketing




Bing Ads remarketing service is provided by Microsoft Inc.




You can opt-out of Bing Ads interest-based ads by following their


instructions: <https://advertise.bingads.microsoft.com/en-


us/resources/policies/personalized-ads>




You can learn more about the privacy practices and policies of Microsoft


by visiting their Privacy Policy page: <https://privacy.microsoft.com/en-


us/PrivacyStatement>




* Facebook




Facebook remarketing service is provided by Facebook Inc.




You can learn more about interest-based advertising from Facebook by


visiting this page: <https://www.facebook.com/help/164968693837950>




To opt-out from Facebook's interest-based ads, follow these instructions


from Facebook: <https://www.facebook.com/help/568137493302217>




Facebook adheres to the Self-Regulatory Principles for Online Behavioural


Advertising established by the Digital Advertising Alliance. You can also


opt-out from Facebook and other participating companies through the


Digital Advertising Alliance in the USA


<http://www.aboutads.info/choices/>, the Digital Advertising Alliance of


Canada in Canada <http://youradchoices.ca/> or the European Interactive


Digital Advertising Alliance in Europe <http://www.youronlinechoices.eu/>,


or opt-out using your mobile device settings.




For more information on the privacy practices of Facebook, please visit


Facebook's Data Policy: <https://www.facebook.com/privacy/explanation>




GDPR Privacy


============




Legal Basis for Processing Personal Data under GDPR


---------------------------------------------------




We may process Personal Data under the following conditions:




* Consent: You have given Your consent for processing Personal Data for one


or more specific purposes.


* Performance of a contract: Provision of Personal Data is necessary for the


performance of an agreement with You and/or for any pre-contractual


obligations thereof.


* Legal obligations: Processing Personal Data is necessary for compliance


with a legal obligation to which the Company is subject.


* Vital interests: Processing Personal Data is necessary in order to protect


Your vital interests or of another natural person.


* Public interests: Processing Personal Data is related to a task that is


carried out in the public interest or in the exercise of official


authority vested in the Company.


* Legitimate interests: Processing Personal Data is necessary for the


purposes of the legitimate interests pursued by the Company.




In any case, the Company will gladly help to clarify the specific legal basis


that applies to the processing, and in particular whether the provision of


Personal Data is a statutory or contractual requirement, or a requirement


necessary to enter into a contract.




Your Rights under the GDPR


--------------------------




The Company undertakes to respect the confidentiality of Your Personal Data


and to guarantee You can exercise Your rights.




You have the right under this Privacy Policy, and by law if You are within the


EU, to:




* Request access to Your Personal Data. The right to access, update or


delete the information We have on You. Whenever made possible, you can


access, update or request deletion of Your Personal Data directly within


Your account settings section. If you are unable to perform these actions


yourself, please contact Us to assist You. This also enables You to


receive a copy of the Personal Data We hold about You.


* Request correction of the Personal Data that We hold about You. You have


the right to to have any incomplete or inaccurate information We hold


about You corrected.


* Object to processing of Your Personal Data. This right exists where We are


relying on a legitimate interest as the legal basis for Our processing and


there is something about Your particular situation, which makes You want


to object to our processing of Your Personal Data on this ground. You also


have the right to object where We are processing Your Personal Data for


direct marketing purposes.


* Request erasure of Your Personal Data. You have the right to ask Us to


delete or remove Personal Data when there is no good reason for Us to


continue processing it.


* Request the transfer of Your Personal Data. We will provide to You, or to


a third-party You have chosen, Your Personal Data in a structured,


commonly used, machine-readable format. Please note that this right only


applies to automated information which You initially provided consent for


Us to use or where We used the information to perform a contract with You.


* Withdraw Your consent. You have the right to withdraw Your consent on


using your Personal Data. If You withdraw Your consent, We may not be able


to provide You with access to certain specific functionalities of the


Service.




Exercising of Your GDPR Data Protection Rights


----------------------------------------------




You may exercise Your rights of access, rectification, cancellation and


opposition by contacting Us. Please note that we may ask You to verify Your


identity before responding to such requests. If You make a request, We will


try our best to respond to You as soon as possible.




You have the right to complain to a Data Protection Authority about Our


collection and use of Your Personal Data. For more information, if You are in


the European Economic Area (EEA), please contact Your local data protection


authority in the EEA.




CCPA Privacy


============




Your Rights under the CCPA


--------------------------




Under this Privacy Policy, and by law if You are a resident of California, You


have the following rights:




* The right to notice. You must be properly notified which categories of


Personal Data are being collected and the purposes for which the Personal


Data is being used.


* The right to access / the right to request. The CCPA permits You to


request and obtain from the Company information regarding the disclosure


of Your Personal Data that has been collected in the past 12 months by the


Company or its subsidiaries to a third-party for the third party's direct


marketing purposes.


* The right to say no to the sale of Personal Data. You also have the right


to ask the Company not to sell Your Personal Data to third parties. You


can submit such a request via email - support@mordentgroup.com



* The right to know about Your Personal Data. You have the right to request


and obtain from the Company information regarding the disclosure of the


following:


* The categories of Personal Data collected


* The sources from which the Personal Data was collected


* The business or commercial purpose for collecting or selling the


Personal Data


* Categories of third parties with whom We share Personal Data


* The specific pieces of Personal Data we collected about You


* The right to delete Personal Data. You also have the right to request the


deletion of Your Personal Data that have been collected in the past 12


months.


* The right not to be discriminated against. You have the right not to be


discriminated against for exercising any of Your Consumer's rights,


including by:


* Denying goods or services to You


* Charging different prices or rates for goods or services, including the


use of discounts or other benefits or imposing penalties


* Providing a different level or quality of goods or services to You


* Suggesting that You will receive a different price or rate for goods or


services or a different level or quality of goods or services.




Exercising Your CCPA Data Protection Rights


-------------------------------------------




In order to exercise any of Your rights under the CCPA, and if you are a


California resident, You can email or call us or visit our "Do Not Sell My


Personal Information" section or web page.




The Company will disclose and deliver the required information free of charge


within 45 days of receiving Your verifiable request. The time period to


provide the required information may be extended once by an additional 45 days


when reasonable necessary and with prior notice.




Do Not Sell My Personal Information


-----------------------------------




We do not sell personal information. However, the Service Providers we partner


with (for example, our advertising partners) may use technology on the Service


that "sells" personal information as defined by the CCPA law.




If you wish to opt out of the use of your personal information for interest-


based advertising purposes and these potential sales as defined under CCPA


law, you may do so by following the instructions below.




Please note that any opt out is specific to the browser You use. You may need


to opt out on every browser that you use.




Website


~~~~~~~




You can opt out of receiving ads that are personalized as served by our


Service Providers by following our instructions presented on the Service:




* From Our "Cookie Consent" notice banner


* Or from Our "CCPA Opt-out" notice banner


* Or from Our "Do Not Sell My Personal Information" notice banner


* Or from Our "Do Not Sell My Personal Information" link




The opt out will place a cookie on Your computer that is unique to the browser


You use to opt out. If you change browsers or delete the cookies saved by your


browser, you will need to opt out again.




Mobile Devices


~~~~~~~~~~~~~~




Your mobile device may give you the ability to opt out of the use of


information about the apps you use in order to serve you ads that are targeted


to your interests:




* "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on


Android devices


* "Limit Ad Tracking" on iOS devices




You can also stop the collection of location information from Your mobile


device by changing the preferences on your mobile device.




"Do Not Track" Policy as Required by California Online Privacy Protection Act


(CalOPPA)


========================================================================




Our Service does not respond to Do Not Track signals.




However, some third party websites do keep track of Your browsing activities.


If You are visiting such websites, You can set Your preferences in Your web


browser to inform websites that You do not want to be tracked. You can enable


or disable DNT by visiting the preferences or settings page of Your web


browser.




Your California Privacy Rights (California's Shine the Light law)


=================================================================




Under California Civil Code Section 1798 (California's Shine the Light law),


California residents with an established business relationship with us can


request information once a year about sharing their Personal Data with third


parties for the third parties' direct marketing purposes.




If you'd like to request more information under the California Shine the Light


law, and if you are a California resident, You can contact Us using the


contact information provided below.




California Privacy Rights for Minor Users (California Business and Professions


Code Section 22581)


==================================================================================================




California Business and Professions Code section 22581 allow California


residents under the age of 18 who are registered users of online sites,


services or applications to request and obtain removal of content or


information they have publicly posted.




To request removal of such data, and if you are a California resident, You can


contact Us using the contact information provided below, and include the email


address associated with Your account.




Be aware that Your request does not guarantee complete or comprehensive


removal of content or information posted online and that the law may not


permit or require removal in certain circumstances.




Links to Other Websites


=======================




Our Service may contain links to other websites that are not operated by Us.


If You click on a third party link, You will be directed to that third party's


site. We strongly advise You to review the Privacy Policy of every site You


visit.




We have no control over and assume no responsibility for the content, privacy


policies or practices of any third party sites or services.




Changes to this Privacy Policy


==============================




We may update our Privacy Policy from time to time. We will notify You of any


changes by posting the new Privacy Policy on this page.




We will let You know via email and/or a prominent notice on Our Service, prior


to the change becoming effective and update the "Last updated" date at the top


of this Privacy Policy.




You are advised to review this Privacy Policy periodically for any changes.


Changes to this Privacy Policy are effective when they are posted on this


page.




Contact Us


==========




If you have any questions about this Privacy Policy, You can contact us:




* By email: support@mordentgroup.com




* By visiting this page on our website:


<https://mordentgroup.com/privacypolicy>







© 2020. All rights reserved by Mordent Group, LLC