Privacy Policy
1. Scope
Malone knows that you care how information about you is used and shared, and we appreciate your trust that we will do so responsibly. This policy describes what information we collect, why we collect it, and what we do with it (“Privacy Policy”), and for our clients, supplements our client agreements. To the extent an inconsistency or conflict arises between the terms of an agreement and this Privacy Policy, the terms of this Privacy Policy will control.
By visiting our website at teammmg.com and other domain names managed by Malone and by using our products and services, you accept the conditions described in this Privacy Policy. This Privacy Policy covers our website(s) and the platform services we may provide to our clients.
When used in this Privacy Policy, “we,” “us,” and “our” may refer to us, JA Malone, LLC, or “Malone.”
2. Information We Collect
We may collect information that describes or relates to you (“Personal Information” or “Personal Data” as defined under applicable state law). Personal Information does not include:
- Publicly available information as defined under applicable state law;
- Deidentified or aggregated information; or
- Information excluded from the applicable state laws, including but not limited to Personal Information governed by the Health Insurance Portability and Accountability Act (“HIPAA”) or Gramm Leach Bliley Act (“GLBA”).
For details on what we do with information you may provide, please go to How We Use Information Collected.
A. Voluntarily Collected Data
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us through the website or in connection with any of our products or services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Malone and authorized third parties (more about them is described below).
During your use of our website or services, we may ask for Personal Data, which may include your name, email address, phone number, address, type of business, customer preference information, and customer number (if you have one), as well as other similar personal information that is needed to register or subscribe you to services or offers. In the case of newsletters or mailing lists, you will be able to “unsubscribe” or “opt-out” of these mailings at any time.
B. Automatically Collected Data
When you interact with Malone through our website or by use of our products or services, we receive and store certain information, which is collected using advertising tracking technologies and log data as described below:
When you interact with Malone through our website or by use of our products or services, we receive and store certain information, which is collected using cookies and log data as described below:
(i). Information which is automatically collected when you browse
- Certain information about your visit can be collected when you browse and/or interact with the site. When you visit our website, Malone creates a user profile including a user’s visitor ID number and any information the user directly provides through the site or other interactions with the site and/or the company associated with the site (e.g., phone calls and chats). This information may include below fields. We will not ask for or knowingly associate financial information with your user profile.
- Browser Type
- Geographic location (latitude and longitude)
- Available plugins
- Internet service provider
- Internet Protocol (“IP”) address and/or mobile device ID
- Geographic location based on the IP address of the user’s local system (which may be considered Precise under applicable state law)
- Pages visited, features used, and activities performed on the site
- Domain from which you accessed the internet
- Operating system for the device that you’re using and information about the browser you used when visiting the site.
- Date and time of your visit
- Address of the website that connected you to the site (such as google.com)
- Device Type (such as laptop, tablet, or type of mobile device)
- Screen resolution
- Browser language
- Time spent on page
- Scroll depth (measures how much of a web page was viewed)
- We use AdTech (defined below), which collects basic site usage information such as:
- How many visits the site gets
- The pages visited
- Time spent on the site
- The number of return visits to the site
- The geographic location of the device used to access the site
- Types of devices used
3. How We Collect Information
We may use advertising tracking technologies such as cookies, web beacons, pixel tags, and flash objects (“AdTech”). You may opt out from the data that we are collecting during your visit by contacting us here.
A. We use cookies from third parties, such as Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by these third parties (including your internet protocol (IP) address) will be transmitted to and stored by the third parties on our behalf for the purpose of evaluating your use of the website, compiling reports on the website activity, and providing further services to us relating to the website usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631. You can prevent your data from being collected by Google Analytics on our website by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
B. When you visit this website or use our products or services, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the website. This log data includes web pages visited, browser type and settings, length of visit, the date and time of your request, and product features you use. The website also automatically captures your Internet Protocol (“IP”) address as well geolocation data such as your latitude and longitude after obtaining your consent through a browser opt-in. Malone uses geolocation data & IP addresses to analyze trends, administer the website, track user movement, ensure the security of your interaction with the website, and gather broad demographic information for aggregate use.
4. How We Use Information Collected
The information collected is used to maintain the site, including:
- Monitoring website stability
- Measuring website traffic
- Optimizing website content
- Improving your experience
Except as otherwise set forth herein, the information associated with a user profile is used, maintained, and disclosed in accordance with the restrictions in our other agreement and this Privacy Policy, including any obligations around confidentiality and third-party disclosures.
The information associated with your user profile may be used to understand and analyze the usage of the site, and for the purposes of marketing our products and services to you. In particular, the AdTech may automatically generate and send email marketing communications to you (to the extent you have provided your email address as part of your interactions with the site and/or the company associated with the site). The content of those email marketing communications may be based on the pages that you have visited and/or the features you have used on the site. To opt-out of receiving the email marketing communications generated by the AdTech, please see the Opt-Out instructions in Your Data Choices below.
The information associated with your user profile will not be used or disclosed to third parties other than for the purpose it was collected, without the user’s prior consent. By using this site, you consent to the collection, use, and disclosure of your Personal Information as described herein. If you do not consent, you may opt-out of the use of the AdTech as set out in Your Data Choices below.
5. Your Data Choices
We offer everyone in the U.S. (as well as Puerto Rico, and the US Virgin Islands) choices about their personal data. Please note that your choices may vary depending on the laws that apply to where you are located.
A. Opt-In/Opt-Out
The AdTech is enabled by default to provide a quality consumer experience. The AdTech gathers information about the user’s hardware and software configurations to identify the user each visit and associate the user with their existing user profile. Unlike a “cookie,” and except for local storage discussed below, the system does not store a file on the user’s computer. Therefore, the user information gathered is not deleted when the user clears their cache and/or deletes their cookies.
To opt-in or opt-out of the different categories of data collection, please contact us here.
You may also opt-out of receiving email marketing communications by sending a request here, or by clicking the unsubscribe link on any such email marketing communication you receive.
Please note that clicking the unsubscribe link may only result in your no longer receiving marketing communications generated by the AdTech, you may still receive other email communications from the company associated with the site.
As noted above, the AdTech may also collect and store information (including personal or sensitive information) locally on your device using mechanisms such as browser web storage application data caches. Browser web storage enables the site to store data in a browser on a device. When used in “local storage” mode, it enables data to be stored across sessions. Similarly, an application data cache is a data repository on a device. You may stop local storage from being used by modifying your internet browser settings, but stopping local storage may result in the site having impaired or limited functionality.
Furthermore, disabling local storage will not block the AdTech from operating; rather, it will only prevent the AdTech from collecting and storing information locally on your device. To disable the AdTech, see the Opt-Out Instructions above. Further, you should refer to the help provided by your internet browser for the most up-to-date and accurate instructions on disabling local storage.
B. Browser or platform controls
- i. Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn more about how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings, and preferences controlled by these cookies, including advertising preferences, may be deleted and will need to be recreated.
- ii. Global Privacy Control. Some browser and browser extensions support the “Global Privacy Control” (“GPC”) or similar controls that can send a signal to the websites you visit indicated your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control recognized by regulations or otherwise widely acknowledged as a valid opt-out preference signal.
- iii. Do Not Track. Some browsers include a “Do Not Track” (“DNT”) setting that can send a signal to the websites you visit, indicating that you do not wish to be tracked. Unlike the GPC described above, there is no common understanding of how to interpret the DNT signal; therefore, our sites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described above.
- iv. Mobile Advertising ID Controls. iOS and Android operating systems provide options to limit tracking.
- v. Email Web Beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, which avoid the automatic connection to the web servers that host those images.
C. Accessing, Correcting, and Updating Your Personal Information.
To make a request for the rights described above, please contact us here or email us at privacy@teammmg.com. Please indicate that you are making a request pursuant to your “Utah Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records.
D. Notice and Consent.
We provide applicants with a notice about the personal data we collect, how it will be used, and with whom we disclose personal data. We will get consent from applicants for the collection and use of personal data where such consent is required by applicable law.
6. Children
In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect personal information from children under the age of 13, 16 in California, (a “child”) without verifiable consent of a parent or guardian, and our site is intended to be used by children under 13 only with significant parent or guardian involvement and approval.
If we learn that we have inadvertently collected personal information of a child without parental consent, as required by law, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child provided personal information to us without your consent, please alert us immediately by emailing privacy@teammmg.com.
7. Applicable Law
The AdTech and our provision of services are operated and controlled from offices in the United States. If you access the site or use our services from locations outside the United States, you do so at your own risk and are responsible for conformance with applicable local laws. Your access to the site and use of our services constitutes your consent that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by other jurisdictions.
8. Security
Malone takes reasonable and appropriate steps to protect Personal Information provided via the services and websites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Information to Malone.
APPLICABLE LAW
Our services and websites are operated and controlled from offices in the United States. If you access the site from locations outside the United States, you do so at your own risk and are responsible for compliance with applicable local laws. Your access to the site constitutes your agreement that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.
1. California Privacy Rights
Under the CCPA, California residents have the right to receive certain disclosures regarding our information practices related to “Personal Information,” as defined under the CCPA. To the extent you are a resident of California, and we collect Personal Information subject to CCPA, the following applies:
To the extent you are a resident of California, you may have the following rights to your Personal Information:
- Right to Access: With respect to the Personal Information we have collected about you in the prior 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions): (i) categories of Personal Information about you we have collected; (ii) the sources from which we have collected that Personal Information; (iii) our business or commercial purposes for collecting, selling, or disclosing that Personal Information; (iv) the categories of third parties to whom we have disclosed that Personal Information; and (v) a copy of the specific pieces of your Personal Information we have collected.
- Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information.
- Right to Delete: Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you.
- Right to Opt-Out of Sale/Sharing: You may have the right to opt-out of the “sale” or “sharing” of your Personal Information. Where applicable, to opt out from the sharing or sale of information described above, please click on the “Do Not Sell or Share My Personal Information” Link on the bottom of the website homepage.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section.
- Authorized Agent: You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf.
To make a request for the rights described above, please write us at 1475 Phoenixville Pike, Ste. 202, West Chester, PA 19380, or email us at privacy@teammmg.com. Please indicate you are making a request pursuant to your “California Privacy Rights.” You must provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or, where necessary, to process your request. If we are unable to adequately verify a request, we will notify the requestor. In order to opt out of sharing information for targeted marketing, where applicable, please email us at privacy@teammmg.com.
2. Colorado Privacy Rights (Effective July 1, 2023)
Under the CPA, Colorado residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Colorado, and we collect Personal Data subject to applicable Colorado law, the following applies.
- Right to Access: You have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
- Right to Correction: You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
- Right to Deletion: You have the right to delete the Personal Data provided to us by you.
- Right to Data Portability: You have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.
- Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of the CPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. We do not “sell” Personal Information under this definition. Colorado residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
- Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you, providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Colorado Attorney General if you have concerns about the result of the appeal.
To make a request for the rights described above, please write us at 1475 Phoenixville Pike, Ste. 202, West Chester, PA 19380, or email us at privacy@teammmg.com. Please indicate that you are making a request pursuant to your “Colorado Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records.
3. Connecticut Privacy Rights (Effective July 1, 2023)
Under the CTDPA, Connecticut residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CTDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a Connecticut resident, and we collect Personal Data subject to applicable Connecticut law, the following applies.
- Right to Access: You may have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
- Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
- Right to Deletion: You may have the right to delete the Personal Data provided to us by you.
- Right to Data Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.
- Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of the CTDPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. We do not “sell” Personal Information under this definition. Connecticut residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
- Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you, providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.
To make a request for the rights described above, please write us at 1475 Phoenixville Pike, Ste. 202, West Chester, PA 19380, or email us at privacy@teammmg.com. Please indicate that you are making a request pursuant to your “Colorado Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records.
4. Virginia Privacy Rights (Effective January 1, 2023)
Under the VCDPA, Virginia residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the VCDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent, you are a resident of Virginia and we collect Personal Data subject to applicable Virginia law, the following applies.
- Right to Access: To confirm whether or not we are processing your Personal Data and to access such Personal Data.
- Right of Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller or business where the processing is carried out by automated means.
- Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
- Right to Deletion: You may have the right to delete Personal Data provided by or obtained about you.
- Right to Opt-Out of Sale: Under the VCDPA, a “sale” includes disclosing or making available Personal Information to a third party in exchange for money. We do not “sell” Personal Information under this definition.
- Right to Opt-Out of Targeted Ads and Significant Profiling: You may have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
- Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you, providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.
To make a request for the rights described above, please write us at 1475 Phoenixville Pike, Ste. 202, West Chester, PA 19380, or email us at privacy@teammmg.com. Please indicate that you are making a request pursuant to your “Virginia Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records. Please note, we may deny your request if (1) we are not reasonably capable of associating your request with the Personal Data or it would be unreasonably burdensome for us to associate your request with the Personal Data; (2) we do not use the Personal Data to recognize or respond to you specifically or associate the Personal Data with other Personal Data about you; and (3) we do not sell the Personal Data to any third party or otherwise voluntarily disclose the Personal Data to any third party other than a processor, except as otherwise permitted under Virginia law.
5. Utah Privacy Rights (Effective December 31, 2023)
Under the Utah Consumer Privacy Act (“UCPA”), Utah residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under UCPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Utah, and we collect Personal Data subject to applicable Utah law, the following applies.
- Right to Access: You may have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
- Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
- Right to Deletion: You may have the right to delete the Personal Data provided to us by you.
- Right to Data Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.
- Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of UCPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation. We do not “sell” Personal Information under this definition. Utah residents have the right to opt out of the processing of your Personal Data by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Data for such profiling. To opt out of targeted marketing, where applicable, please click on the Opt-Out Link on the bottom of the website homepage.
To make a request for the rights described above, please write us at 1475 Phoenixville Pike, Ste. 202, West Chester, PA 19380, or email us at privacy@teammmg.com. Please indicate that you are making a request pursuant to your “Utah Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records.
6. Changes to the Notice
We review this policy at least annually and may amend it from time to time. Except as otherwise required by applicable law, our only notification will consist of posting a new policy. When we update this policy, we will revise the “Effective Date” date above and post the new privacy policy. We recommend that you review the privacy policy each time you visit our site to stay informed of our privacy practices.
a. Questions and Contact Us
If you have any questions about this Policy or our privacy practices, you may write us at 1475 Phoenixville Pike, Ste. 202, West Chester, PA 19380, or email us at privacy@teammmg.com.
This Privacy Policy was last updated on August 24, 2023.