PRIVACY POLICY
Last Updated: September 30, 2024
MLG Marketing LLC, Mooney Lesage Development LLC, MLG Capital and our other affiliates (“Company” “us” “we” or “our”) are committed to protecting your privacy and has adopted this Privacy Policy with that in mind. This Privacy Policy informs you of the personal information we collect and how and for what purposes we may collect and use certain types of personal information. This Privacy Policy applies to all information you provide to us, or that we obtain from you, through this website, including any subdomain thereof; related mobile applications and through email, text, chat and other electronic communications (this “Site”). By using the Site, you consent to and accept this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Site.
Types of Information We Collect
We may collect or receive the categories of personal information detailed below. Not all categories will be collected or received for every individual.
Identifiers – Information that identifies you personally or with which you can be contacted, such as, for example, your name, postal address, email address, telephone number, social security number, IP address, and account credentials and profile information.
Financial and Investor Information – Information such as your personal financial information and your status as an accredited investor.
Commercial Information – Information regarding records of your investments with us.
Internet or Other Similar Network Activity – Information about your internet connection, your equipment, browsing history, and your use of the site including your IP address, browser type and language, operating system, domains from which you access our site, referring/exit webpages, URLs and the number of clicks and time on each webpage.
Geolocation Information.
Sensory Information – Information such as photographs, audio, and video recordings.
Employment Information – Employment-related information if you apply for a position through the site.
Additionally, depending on how you use the Site, we may collect information about the precise location of your device, consistent with your device settings. We do not collect sensitive personal information through the Site, such as social security numbers, banking information, account login information, or racial or ethnic origin. We do, however, own or license other digital applications (e.g., Juniper Square) that do collect such information in connection with an investor’s subscription to one of our products.
We may aggregate or de-identify the information described above. Aggregated or de-identified information that we do not attempt to reidentify is not subject to this policy.
We may collect this information when you:
-Inquire about our services and offerings;
-Become an investor;
-Access the investor portal;
-Inquire into an employment opportunity;
-Create an account at our Site
-Sign up for e-mail updates;
-Enter a contest;
-Are referred to ss through a marketing promotion; or
-Participate in a marketing survey, promotion or event
If you contact us through electronic communication, including by e-mail, we typically retain the e-mail in our file servers and collect any contact information you provide so that we can reply to you. Your e-mail also contains metafiles that may contain IP addresses, domain names, and other standard file information and this information may be retained electronically on our servers or in routine back-up files.
If you browse the Site, regardless of whether you create a user account, or otherwise interact with the Site, we log your IP address (the internet address of your computer) to tell us which parts of the Site you visit and how long you spend there. The Company also may track the state and/or country you are accessing the internet from, the date and time you visited and the type of computer, operating system and Web browser you are using.
Automatic Information Collection and Tracking
As you access or use the Site, we may use automatic data collection technologies to collect certain information, which may include:
-Details of your access and use of the Site.
-Details about your device(s), equipment, connection, and other resources utilized in accessing or using the Site.
-Stored information and files such as metadata and other information associated with files stored on your device(s).
We also may use these technologies to collect information about your online activities over time and across third-party apps, websites, or other online services (behavioral tracking) for targeted advertising. You may opt out of or reduce the collection of this information at any time by changing your consent preferences in our Site’s Privacy Preference Center. You may navigate to our Privacy Preference Center at any time by clicking on the cookie icon in the bottom lefthand corner of our Site.
The technologies we use for automatic information collection may include:
-Cookies. A cookie is a small file placed on your device. It may be possible to refuse to accept cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain parts or features of the Site. Unless you have adjusted your settings to refuse cookies, the Site will issue cookies when you access the Site.
-Beacons. Pages or screens of the Site and our emails to you 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 screens or opened an email and for other related usage statistics (for example, recording the popularity of certain content and verifying system and server integrity).
-Pixels. A tracking pixel, also known as a marketing pixel, is a pixel graphic used to track user behavior, site conversions, web traffic, and other metrics similar to a cookie. It may be used for targeting or retargeting purposes.
When you navigate to our Site, tracking technologies such as Google Analytics use cookies and other, similar technologies, to collect information about how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. To learn more about Google Analytics, including how to opt out of it, visit https://tools.google.com/dlpage/gaoptout.
Third-Party Websites
For your convenience, our Site may contain links to websites owned and operated by third parties. Please note that the Company does not control such third-party websites, the content of these sites, any products or services that may be offered through these sites, or any other use of the linked sites. These other websites may send their own cookies to visitors, collect data or solicit personal information, and the privacy policies of these other sites may be significantly different from this Privacy Policy. Your access to and use of such websites is governed by the terms of use and policies of those sites, and shall be at your own risk. The Company is not responsible for the privacy practices of these other sites and cannot guarantee the security of any information collected by any linked or other third-party website. Similarly, this Privacy Policy does not apply to the sites of other companies affiliated with the Company, such as Valiant Residential and PRM Property Management. Your use of those websites is governed by any policies existing on or applicable to those websites. The Company encourages you to review the privacy policy of any company or website before submitting your Personal Information.
How We Use Your Information
We may use the categories of personal information that we collect or that you provide to us for the purposes described below.
Identifiers
-To provide our services to you, including providing you information on investment opportunities and information on other of our products or services that you request from us
-To send you email alerts
-To create, maintain, customize, and secure your account with us
-To communicate with you, including in response to your inquiries and to fulfill your requests, including investigating and addressing your concerns and to monitor and improve our responses
-To provide you with information about our funds and investment products and services, and to provide information you have requested from us, for yourself, or on behalf of an entity you are affiliated with
-To provide you with targeted advertising about investments that may be of interest to you
-To process requests, transactions, and any corresponding payments
-To provide support, personalize, and develop our Site, products, or services
-To develop market intelligence
Financial Information
-To provide our services to you, including providing you information on investment opportunities and information on other of our products or services that you request from us
-To create, maintain, customize, and secure your account with us
-To communicate with you, including in response to your inquiries and to fulfill your requests, including investigating and addressing your concerns and to monitor and improve our responses
-To provide you with information about our products and services, and to provide information you have requested from us, for yourself, or on behalf of an entity you are affiliated with
-To provide you with targeted advertising about goods and services that may be of interest to you
-To provide support, personalize, and develop our Site, products, or services
-To process requests, purchases, transactions, and any corresponding payments
-To develop market intelligence
Internet or Other Similar Network Activity
-To provide support, personalize, and develop our Site, products, or services
-To provide you with targeted advertising about goods and services that may be of interest to you
-To track Site usage
Geolocation Information
-To personalize the Site for you
-To provide you with targeted advertising about goods and services that may be of interest to you
-To track usage
Sensory Information
-To provide the Site to you, including providing you any information, products, or services that you request from us
-To communicate with you, including in response to your inquiries and to fulfill your requests, including investigating and addressing your concerns and to monitor and improve our responses
-To provide you with information about our products and services, and to provide information you have requested from us, for yourself, or on behalf of an entity you are affiliated with
-To provide support, personalize, and develop our Site, products, or services
Employment Information
-To provide you information about employment opportunities
-To process your employment information to evaluate you for prospective employment
For all categories of personal information that we collect, we may also use such personal information for the following purposes:
-To fulfill or meet the reason you provided the information.
To carry out our obligations and enforce our rights, including those arising from any contracts entered into between you and us, including for billing and collection.
-To process your requests, investments and payments and prevent transactional fraud.
-To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
-To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
-For testing, research, analysis, and product development, including to develop and improve our site, products, and services.
-To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, or to otherwise comply with applicable law.
For any other purpose with your consent or as otherwise permitted by law.
Sharing of Information
The Company does not sell, rent, trade or otherwise disclose Personal Information, except as described in this Privacy Policy or with your consent. We may share your information among our affiliates and with third parties that We believe may provide services of interest to you. We may from time to time transfer information to third parties who analyze such information on behalf of the Company. We also may share the information with third-party service providers we have retained to perform services on our behalf to help with our business activities. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.
We may disclose information about you (i) if We are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation or arbitration; (iv) to enforce the Company’s policies, contracts or other rights; (v) to collect amounts owed to the Company; (vi) when We believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if in good faith We believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Site. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
We reserve the right to disclose or transfer any information We have about you in the event of a proposed or actual reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of the Company or of any of our assets (including should We become insolvent, enter into receivership or any similar event occur). Should such an event take place, We will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.
Security
We maintain commercially reasonable procedures and technology designed to prevent the unauthorized access of your information that you provide to us. The Site has reasonable technical and organizational security measures in place to protect the loss, misuse or alteration of information under our control. However, we cannot guarantee that unauthorized third parties will never be able to defeat those security measures. We periodically update and test our technology in order to improve the protection of information.
If you believe your information has been accessed in an unauthorized manner, please contact Us immediately.
Legally Compelled Disclosure
We will also disclose your personal information when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency’s request, or in special cases when we have reason to believe that disclosing your personal information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (whether intentionally or unintentionally) our rights or property. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your personal information to be shared or transferred to third parties without your permission. If you object to your personal information being used in this manner, please do not register with or use the Site.
Privacy Policy for Children
This Site is not directed to children. We do not knowingly collect information from children under the age of 18 on the Site. If you are under the age of 18, please do not provide any personal information to us. If we become aware that We have collected personal information from a child under the age of 18, We will make commercially reasonable efforts to delete such information from our database.
Opt-Out Rights
You have the right to direct us not to sell your personal information at any time (the “right to opt-out”). Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request here: requestinfo@mlgcapital.com.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us here: requestinfo@mlgcapital.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Your State Privacy Rights
Depending on where you live, you may be entitled to certain rights with respect to your personal information, as described below. Note that we provide these rights to all individuals, regardless of current state of residence.
Right to Confirm and Access. You may have the right to confirm whether we process your personal information and know what personal information we have collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it, including the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes.
Data Portability. Subject to certain exemptions, you may have the right to request a copy of the personal information that we collected about you during the 12 months before your request. You can review and change your personal information by contacting us via the Contact Information set forth below.
Right to Correct. You have the right to request that we correct inaccuracies in your personal information. We may not accommodate a request to correct personal information if we believe the correction would violate any law or legal requirement or cause the information to be incorrect.
Right to Delete. You have the right to request that we delete personal information we have collected from or obtained about you, subject to certain exceptions. For example, we may not delete your information if retention is required for ongoing transactions with you or otherwise for our legitimate business purposes consistent with this policy or as permitted by law. Note that we cannot delete your personal information except by also deleting your user account.
Right to Opt Out of Targeted Advertising. We may use your personal information for targeted advertising. You have the right to opt out from processing of your personal information for the purpose of targeted advertising.
Right to Opt Out of Sales. You have the right to opt out of sales of your personal information. We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information for non-monetary compensation by allowing certain third parties (such as online advertising services and marketing partners) to collect personal information (i) via automated technologies on our Site for online targeted advertising purposes and/or (ii) for marketing-related purposes. This kind of sharing may be considered a “sale” under applicable law when the personal information is exchanged for non-monetary compensation.
Right to Opt Out of Profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
You may exercise any of the rights listed above by utilizing the Contact Information provided below or by submitting a request here: requestinfo@mlgcapital.com.
Additionally, you can access, correct, and delete some of your personal information by logging into the Site and visiting your account profile page(s).
To opt out of targeted advertising, you may submit a request here: requestinfo@mlgcapital.com
To opt out of the sale of your personal information, you may submit a request here: requestinfo@mlgcapital.com.
You may use an authorized agent to submit an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests here: requestinfo@mlgcapital.com.
If you request access to, or the correction or deletion of, your personal information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your name, address, email address, and/or phone number. When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. You may be asked to log into your online account and complete a one-time passcode validation. In the event more documentation is necessary to verify your identity, we will notify you directly.
If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision by utilizing the Contact Information provided below. If you are unsatisfied with the results of your appeal, you may contact the Attorney General or other responsible department of your state.
You will not receive discriminatory treatment as a result of exercising your rights detailed above.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. We do not currently sell any information or otherwise trigger Nevada’s opt-out requirements. Nevertheless, any Nevada residents who wishes to exercise this sale opt-out right proactively may submit a request using the Contact Information provided below.
Transfer of Personal Information
The Company is based in the United States and our Site is designed for users from the United States. Any information collected through the Site or electronic communications as described in this Privacy Policy may be stored and processed in the United States or any other country in which the Company or its affiliates or service providers maintain facilities. The United States is not recognized as having adequate safeguards. If you are located outside of the United States, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the United States.
Data Retention
We will retain the Personal Information we collect and receive as described in this Privacy Policy for as long as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements as permitted with all applicable laws and in accordance with our routine information storage policies.
Terms of Service. Please take the time to read our Terms of Service at https://mlgcapital.com/terms-of-use/. These terms govern our interactions as a legal contract, and We welcome and encourage the time you spend becoming familiar with these legal terms.
Access to Your Information; Contact Information
You have the right to access, correct, or delete your personal information in certain circumstances. You also have the right to withdraw any consent you have given the Company to process your personal information. If you have questions about the personal information the Company has about you, need to modify, access or delete your information, or want to withdraw your consent for to process your personal information, you can contact us as provided below.
You can opt-out of receiving marketing and promotional e-mails from the Company by using the opt-out or unsubscribe feature contained in our emails.
If you are a California resident, we will not discriminate against you for exercising any of your rights under the California Consumer Protection Act of 2018 (the “CCPA”). Please see Addendum A for further information regarding the CCPA.
-Send an email to requestinfo@mlgcapital.com
-Send a request by mail to: 19000 W Bluemound Road, Brookfield, WI 53045, Attn: Legal Department
-(888) 312-6783
Changes and Updates to this Privacy Policy
If you choose to visit our Site, your visit and any disputes over privacy are subject to this Privacy Policy. We reserve the right to change this Privacy Policy at any time without notice except as otherwise provided here. Please check back periodically to see if our Privacy Policy has been updated. Your continued use of the Site constitutes your agreement to the terms of this Privacy Policy and any future versions of this Privacy Policy.
Governing Law and Jurisdiction
Unless otherwise required by applicable law, this Privacy Policy, and the Company’s collection and use of personal information, shall be governed and interpreted in accordance with the laws of the United States and the State of Wisconsin. Unless prohibited by law, any disputes arising out of this policy shall be adjudicated in Milwaukee County, Wisconsin or a federal court of competent jurisdiction in the Eastern District of the State of Wisconsin.
CA PRIVACY POLICY
Last updated: September 30, 2024
California Privacy Rights Notice
This California Privacy Rights Notice (“California Privacy Notice”) applies to the processing of personal information of residents of the State of California by MLG Capital LLC and its affiliates (“MLG” or “we”) as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”). We fully describe our practices in our Privacy Policy but use this separate notice to ensure we meet the CCPA’s requirements. If this California Privacy Notice and any provision of our Privacy Policy conflict, then this California Privacy Notice controls for the processing of personal information of residents of the State of California. In the CCPA, California residents are referred to as “consumers,” and we refer to them in this California Privacy Notice as “California Consumers.”
HOW WE COLLECT AND USE PERSONAL INFORMATION
Our Privacy Policy describes the personal information we collect and its sources, along with our retention policies regarding such information. This California Privacy Notice organizes that description around the personal information categories set forth in the CCPA. For each category, we list examples of the types of personal information that we may have collected from California Consumers within the past 12 months.
Category of Personal Information |
Personal Information in Category That MLG Collected in Past 12 Months |
|
Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
Name, signature, address or telephone number, educational information, employment history, bank account number, credit card number, debit card number |
|
Protected classification characteristics under California or federal law |
Age, race, citizenship, sex (including gender, gender identity, or gender expression) |
|
Commercial information |
Records of products or services purchased or considered and other purchasing or consuming histories or tendencies |
|
Biometric Information |
N/A – We do not collect biometric information |
|
Internet or other similar network activity information |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement |
|
Geolocation data |
Physical location |
|
Sensory information |
Audio or visual information |
|
Professional or employment-related information |
Current or past job history |
|
Non-public education information per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99) (“FERPA”)) |
MLG may collect education-related information, but MLG is not subject to FERPA |
|
Inferences drawn from other categories |
Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
|
Sensitive personal information |
Personal information that reveals an individual’s racial or ethnic origin, and citizenship or immigration status |
Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect information that falls within the sensitive personal information categories listed in the table above, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about an individual.
HOW WE DISCLOSE, SHARE, AND SELL PERSONAL INFORMATION
Our Privacy Policy describes how and why we disclose your personal information. The CCPA requires us to describe the “business purposes” for which we may disclose your personal information, which include the following:
Auditing – Auditing such as to count ad impressions to unique visitors and verify positioning and quality of ad impressions.
Security and Integrity – Helping to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for such purposes.
Service Improvements and Research – Implementing improvements such as debugging to identify and repair errors that impair existing intended functionality, undertaking other activities to verify or maintain the quality or safety of the Site, and undertaking internal research for development of the Site.
Service Providers and Other Notified Purposes – Disclosing personal information with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract (e.g., maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar services) or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).
Marketing and Advertising – Providing advertising and marketing services, except for cross-context behavioral advertising services, as described below.
We do not sell your personal information for monetary consideration. However, as further described in our Privacy Policy, we may disclose your personal information for non-monetary compensation by allowing certain third parties (such as online advertising services and marketing partners) to collect personal information (i) via automated technologies on our Site for online advertising purposes and/or (ii) for marketing-related purposes. This kind of sharing may be considered a “sale” under the CCPA. We also “share” your personal information under the CCPA, which broadly defines this term as disclosing personal information to third parties for purposes of cross-context behavioral advertising, or targeted advertising. In the preceding 12 months, we sold or shared personal information related to California Consumers to the categories of third parties indicated in the chart below. You have the right to opt out of the sharing or the sale of your personal information at any time, as described in additional detail below.
|
Category of Personal Information Under CCPA |
Categories of Third Parties to Whom Personal Information Was Disclosed to for a Business Purpose |
Categories of Third Parties to Whom Personal Information Was Sold or Shared |
|
Identifiers |
-Affiliated Companies -Service Providers -Professional Advisors -Government Authorities -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-Affiliated Companies -Service Providers -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
-Affiliated Companies -Service Providers -Professional Advisors -Government Authorities -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-Affiliated Companies -Service Providers -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
|
Protected classification characteristics under California or federal law |
-Affiliated Companies -Government Authorities |
-N/A |
|
Commercial information |
-Affiliated Companies -Service Providers -Professional Advisors -Government Authorities -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-Affiliated Companies -Service Providers -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
|
Biometric information |
-N/A |
-N/A |
|
Internet or other similar network activity information |
-Service Providers -Professional Advisors -Government Authorities -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-N/A |
|
Geolocation data |
-Affiliated Companies -Service Providers -Professional Advisors -Government Authorities -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-N/A |
|
Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information |
-N/A |
-N/A |
|
Professional or employment- related information |
-Affiliated Companies -Service Providers -Professional Advisors -Government Authorities -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-Affiliated Companies |
|
Non-public education information per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)(“FERPA”)) |
-N/A |
-N/A |
|
Inferences drawn from other categories |
-Affiliated Companies -Service Providers -Professional Advisors -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
-Affiliated Companies -Service Providers -Professional Advisors -Select Third Party Marketing Partners and Digital Advertising Networks for Targeted or Direct Mail Marketing |
|
Sensitive personal information |
-Affiliated Companies -Government Authorities |
-N/A |
The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and opportunity to opt out of further sales. We do not authorize third parties to resell your personal information.
YOUR CALIFORNIA PRIVACY RIGHTS
The CCPA offers California Consumers the following key privacy rights:
-You have the right to know and request information about categories of personal information that we have collected about you, as well as the categories of sources from which the personal information is collected, the purpose for collecting personal information, and the categories of third parties with whom or to whom we disclose, sell, or share personal information (“right to know”).
-You have a right to request the specific pieces of personal information we collected about you (“data portability”).
-You have the right to request that we delete certain personal information that we have collected from you (“right to delete”). We may deny your request to delete if retaining the information is necessary for us or our service providers to:
-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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
-Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-Debug products to identify and repair errors that impair existing or intended
-Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
-Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
-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.
-Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
-Comply with a legal obligation
-Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
-You have the right to request that we correct personal information that we maintain about you if you believe it is inaccurate. We may request documentation to validate a request and will use reasonable efforts to correct the personal information.
-You may also make a request related to a right to know, data portability, a right to delete, or a right to correct personal information on behalf of your child by contacting us as provided below.
-If we offer a financial incentive or price or service difference in exchange for your personal information, we will notify you in advance before collecting your personal information for this purpose and explain how you can opt-in to the financial incentive or price or service difference. See the FINANCIAL INCENTIVES section below for more information on our current financial incentives.
-You have the right to opt out of our sale or sharing of your personal information. In the CCPA, “sale” means transferring or making available personal information to third parties for monetary or other valuable consideration, and “sharing” means disclosing your personal information to third parties for cross-context behavioral advertising purposes. Disclosing your personal information with our service providers for a business purpose does not constitute selling or sharing your personal information because we make sure that our service providers are contractually obligated to use the personal information only to provide services to us and not to sell or share it. To exercise the right to opt-out, you (or your authorized representative) may submit a request to requestinfo@mlgcapital.com. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. However, you may change your mind and opt back in at any time by contacting us as provided below.
-If you are a California Consumer under age 16, we cannot make available to third parties the personal information that we collect from or about you for monetary or other valuable consideration (e.g., in exchange for showing students information about colleges and universities) unless you opt-in. We do not knowingly collect personal information from California Consumers we know are under age 16, so we do not make any such sales or sharing of personal information of California Consumers under age 16.
-You have the right to not receive discriminatory treatment from us for exercising any of these rights. That is, we cannot treat you differently for exercising any of these rights unless we demonstrate that the value of the personal information that you provide to us is reasonably related to the difference in price or service that we offer.
HOW TO SUBMIT A REQUEST TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS
To submit a request to exercise your privacy rights:
-Send an email to requestinfo@mlgcapital.com with the subject line “California Privacy Rights Request.”
-Call us at 1-888-312-6783.
Only you or your authorized agent may make a request to exercise your privacy rights. To designate an authorized agent, contact us through one of the methods listed above.
We will confirm receipt of your request within 10 business days. If you do not receive confirmation within this timeframe, please contact us as provided above.
We try to substantively respond to a request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period. We cannot respond to your request or provide you with personal information unless we can verify your identity or authority to make the request and confirm the personal information relates to you. To do so, we may ask that you log into your account or that you provide us with your name, address, email address, and/or phone number. You may also be asked to answer a few questions about yourself to help us verify your identity. In the event more documentation is necessary to verify your identity, we will notify you directly. If we cannot verify your request within 45 days of its receipt, we may deny your request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your 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. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.
We also respect the GPC browser signal and other commonly used preference signals and will treat it as a valid means of communicating your desire to exercise certain rights, such as your right to opt out of sales or sharing.
Please note:
-We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights.
-When we collect personal information on behalf of a client and use it solely for the benefit of that client, we are acting as a service provider under the In this case, we will direct you to contact our client.
-We may not honor part or all your For example, certain information we collect may be exempt from this California Privacy Notice, such as public information made available by a government entity or information covered by another privacy law. Also, not-for-profit organizations are not subject to the CCPA.
If we do not honor your request, we will explain why when we respond to you.
A different California law permits California residents to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. (For these purposes, third parties include entities that are owned directly or indirectly by MLG.) If you would like to exercise your rights under this California law, please submit your request to us by contacting us by email at requestinfo@mlgcapital.com with the subject line of “California Privacy,” or contacting us by mail at:
MLG Capital LLC
Attn: California Privacy
19000 West Bluemound Road
Brookfield, WI 53045
FINANCIAL INCENTIVES
We do not offer any financial incentives.