Last Updated: June 24, 2019
Welcome to mbacg.com (the “Website”). Mele Brengarth & Associates LLC d/b/a MBA Consulting Group, and its affiliates, representatives, successors, and assigns (collectively, “MBA”) is a company dedicated to staying on top of things so you can focus on what’s important – promoting and advocating for your cause. We care about your privacy and the Personal Information (defined below) you share with us.
This Privacy Policy describes the Personal Information we collect from you and how it may be stored and processed in the United States. Our goal is to help explain why we are using and how we are protecting the Personal Information we collect about you, as well as how you can exercise your privacy rights. We recommend that you read this Privacy Policy in full to ensure you are completely informed about using MBA’s Website or Services (described below), or submitting any personal or financial information through MBA’s Website, or in using MBA’s Services.
Please note, this Privacy Policy does not apply to websites, applications, or services that display or link to third-party websites with other privacy statements. Any disputes in connection with our Privacy Policy are subject to our Terms of Service.
1. About Us
This Website is operated by MBA, a limited liability company located in the District of Columbia in the United States (“MBA,” “us,” “we,” or “our”). We provide campaign and administrative compliance services and information (collectively referred to in this Privacy Policy as the “Services”). We provide these Services both online at mbacg.com and in-person at our office or other locations.
For more information about MBA, please visit our About page here.
2. Key Terms
In this Privacy Policy, these terms have the following meanings:
“Website” or “Websites” means any website we own and operate (such as mbacg.com) or any web pages, interactive features, or other online offerings.
“Users,” “User,” “you,” or “your” means any person who schedules our Services or makes a purchase through our Website, signs up to receive emails or other communications from MBA, or uses our Website for any other reason. This also includes your respective representatives, successors, and assigns.
“Services” includes any services provided through our Website and other products and services.
“Personal Information” means any Personal Information that identifies or can be used to identify a User, directly or indirectly.
3. Personal Information that We Collect
(A) Personal Information Collected That You Provide Us
When you participate in the Services through our Website we ask you to provide Personal Information. The Personal Information we collect from you is only what we need to be able to provide you with the Services effectively. This Personal Information may include:
• Your name;
• Your email address;
• Your phone number;
• Your political opinions and affiliations;
• Your religious and philosophical beliefs;
• Your trade union membership; and
• Any communications related to your use of the Services or Website.
You may choose to provide additional Personal Information when you communicate with us through our Website or otherwise interact with us, and we will keep copies of those communications for our records.
Your decision to allow us to collect this Personal Information from you is voluntary, however if you choose not to provide this information, some or all of the Services may be unavailable to you.
(B) Personal Information Automatically Collected
In addition to Personal Information that you choose to provide to us when you visit our Website, we may also collect certain information automatically from your personal computer, laptop, tablet, mobile phone, or other devices. In some states and territories of the United States and countries, including those countries in the European Union, this information may be considered Personal Information under applicable information protection laws.
Specifically, the Personal Information we collect automatically may include the following:
• Your IP address or other unique identifier;
• Your computer hardware model and operating system information;
• Your Internet browser identification;
• Your interaction and activities with our Website, including remembering you and your preferences;
• Your mobile device used to access our Services, including the hardware model, operating system, unique device identifiers, and mobile network and data information; and
• Other certain information related to your devices, including the time of day you visit our Website, among other information.
We may use various methods and technologies to automatically collect or store this Personal Information through tracking tools like browser cookies, web beacons, pixels, embedded scripts, and ETags or entity tags. We do this on our Website and in emails we send to you.
(C) Information Security and Disclaimer
MBA endeavors to protect the privacy of your Personal Information we hold in our records, but please keep in mind that no method of transmission over the Internet is 100% safe. Therefore we cannot guarantee complete and absolute security of your Personal Information. Unauthorized access, use, disclosure, alteration, and destruction, in addition to hardware or software failure, and other factors, may compromise the security of your Personal Information at any time.
CONSEQUENTLY, WE CANNOT GUARANTEE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US FROM SECURITY BREACHES, IDENTITY LEFT, OR EVENTS THAT COULD CAUSE LOSS OF YOUR DATA OR INFORMATION. WE SHALL NOT BE HELD LIABLE FOR ANY DAMAGES OR INJURY CAUSED BY THE DISCLOSURE OF YOUR PERSONAL INFORMATION, WHETHER CAUSED BY SECURITY BREACH, ACCIDENT, INADVERTENCE OR ANY OTHER ACT RESULTING IN DISCLOSURE. THEREFORE, ANY TRANSMISSION OF PERSONAL INFORMATION THROUGH OUR WEBSITE IS AT YOUR OWN RISK. IF YOU ARE AT ALL UNCOMFORTABLE WITH OUR SECURITY MEASURES, PLEASE DO NOT SUBMIT INFORMATION TO US THROUGH THE WEBSITE.
We are also not responsible for your or a third party’s circumvention of any privacy settings or security measures. Your own efforts to protect against unauthorized access play an important role in protecting the security of your Personal Information. For example, you should be sure to sign off when you finish using a shared computer, not transmit your Personal Information while on a public Wi-Fi network, and always log out of any site when viewing Personal Information. Please note, we are not security professionals and therefore recommend speaking to a security professional if you have any questions about your own efforts to protect your Personal Information.
4. We Combine Collected Personal Information
We combine Personal Information that we have collected offline with Personal Information we collect online, such as our Website. We also combine Personal Information that we have collected across other third-party websites, your devices, (such as computers and mobile devices), and from third parties with Personal Information we already have.
5. Cookies and Similar Tracking Devices; Google Analytics
(A) MBA Cookies Policy
Because we employ cookies and similar tracking tools, we wanted to provide you with some additional information on how it all works.
A cookie is a piece of information, which may include a unique identifier, that is sent to your Internet browser from a server and stored on your hard drive or device. We assign a different cookie to each device that accesses our Website. Cookies allow your devices to use all the features on our Website, such as remembering who you are, knowing if you have visited our site before or if you are a first-time visitor, and remembering your address and contact information. Cookies contain no information about you or any computer or device you are using.
You are always free to decline our cookies and you may be able to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note, if you disable or refuse cookies through your browser settings, including disabling or otherwise opting-out of Google Analytics (discussed below), this may cause some parts of our Website to be inaccessible or not function properly.
(B) Google Analytics
We also use tracking devices like Google Analytics to evaluate use of our Website. Google Analytics employs cookies that are stored to your personal computer, laptop, tablet, mobile phone, or other devices in order to facilitate an analysis of your use of the Website. The information generated by these cookies includes how often Users visit this Website, including your IP address, what pages those Users visit when they visit the Website, and what other websites those Users used prior to coming to this Website. Google may also transfer this information to third parties if required to do so by law or in situations where third parties process the Website information on Google’s behalf.
For more information on Google Analytics’ data collection process and how they use that information, please use the following link: https://policies.google.com/technologies/partner-sites.
If you would like to opt-out of Google Analytics, please visit the following link: https://support.google.com/analytics/answer/181881?hl=en.
6. How We Use Your Personal Information
We may use your Personal Information for various purposes, including, but not limited to, the following:
• Improving the effectiveness of our Website, marketing endeavors, and Services;
• Providing customer service;
• Notifying you of any information concerning the Services including reservations and cancellations;
• Sending you newsletters and related communications that you opt-into;
• Sending you direct mail offerings;
• Sending you email communications about our Services, promotions, events, or other important information that you opt-into;
• Sending you email communications about content you included on our Website;
• Sending you technical notices, updates, security alerts, and support messages;
• Enabling you to participate in the Website’s features;
• Identifying your Services preferences and informing you of new or additional products, services, and promotions that may be of interest to you;
• For internal business purposes such as trainings and business development;
• Notifying you about important changes to our Website;
• Detect, investigate and prevent fraudulent transactions and other illegal or unauthorized activities and protect the rights and property of MBA and our Users; and
• For purposes disclosed at the time you provide your information or as otherwise discussed in this Privacy Policy.
If you do not want to receive email notifications from us, please unsubscribe by using the link on the email communication or contact MBA at info@mbacg.com.
7. Sharing Your Personal Information with Third Parties
Like many businesses, the Personal Information we collect may be shared with third parties to enable us to provide our Services to you. We may hire other companies to perform certain business-related functions on our behalf, and we may provide access to or share your information with these companies so they can perform services for us. Examples of such functions include marketing, mailing information, data storage, security, fraud preventions, legal services, accounting services, and maintaining databases. We may also provide your Personal Information to third parties for those third parties’ direct marketing purposes.
By providing these third-party companies your Personal Information, they are not permitted to use, share, or sell said information; however, they have their own privacy policies with respect to the information we share with them to provide our Services. This includes how they may process and store your Personal Information.
We may also disclose your Personal Information to third parties for the following reasons:
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; or
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MBA, our Users, or others.
In general, these third-party companies will only collect, use and disclose your Personal Information to the extent necessary to allow them to perform the services they provide to us; however, once you leave our Website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Service. Therefore, we recommend that you read any third-party company’s privacy policies so you can understand the manner in which they will handle your Personal Information.
CONSEQUENTLY, WE ARE NOT RESPONSIBLE FOR, AND CANNOT GUARANTEE OR WARRANT, THE PRIVACY AND SECURITY PRACTICES AND POLICIES, OR USE OF COOKIES OF THESE THIRD-PARTY COMPANIES OR ANY OTHER WEBSITES THAT ARE LINKED TO OR FROM THE WEBSITE. WE SHALL NOT BE HELD LIABLE FOR ANY DAMAGES OR INJURY CAUSED BY THE DISCLOSURE OF YOUR PERSONAL INFORMATION BY THESE THIRD-PARTY COMPANIES. THEREFORE, ANY TRANSMISSION OF PERSONAL INFORMATION THROUGH OUR WEBSITE IS AT YOUR OWN RISK. IF YOU ARE AT ALL UNCOMFORTABLE WITH YOUR PERSONAL INFORMATION BEING SHARED WITH THIRD PARTIES, PLEASE STOP USING THE WEBSITE IMMEDIATELY.
8. Your Consent
By using our Website, you consent to the collection and use of your Personal Information by us as described in our Privacy Policy. If we decide to change our Privacy Policy, we will post a link to those changes on this page, so you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it. We reserve the right, in our sole and absolute discretion, to notify you of material changes to our Privacy Policy by email using the email address you provide us. Your continued use of our Website after we make changes indicates your acceptance of those changes, so please check this Privacy Policy periodically for updates.
Also, our Privacy Policy is part of our Terms of Service and as such your consent extends to our Terms of Service.
9. Minors and COPPA Compliance
The Services provided through our Website are only available for adults 18 or older. In in the event a minor under 18 uses our Website, that minor’s parent or guardian is fully responsible for: (i) the online conduct of such minor; (ii) controlling the minor’s access to and use of our Website; and (iii) the consequences of any misuse by the minor. You acknowledge that we have no obligation to monitor the content accessible on or through our Website.
Children under 13 years of age are prohibited from using the Services and the Website. No one under age 13 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 13, even with verified parental or guardian consent. If you are under 13, you are prohibited from providing us with any Personal Information about yourself, including your name, address, telephone number, email address, or any screen name or User name you may use.
If we learn we have collected or received Personal Information from a child under 13, we will delete that information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you believe we might have any information from or about a child under 13, please contact MBA at info@mbacgg.com, and we will take reasonable steps to ensure that such information is deleted from our records.
10. Social Media
Our Website may permit you to submit ideas, photographs, videos, audio recordings, questions, comments, suggestions or other content, including Personal Information, on social media websites and applications, message boards, and other public forums (collectively “Social Media Activities”). By engaging in these Social Media Activities, you agree to the processing of any of your Personal Information accessed on that social media page in accordance with its terms of use and privacy policy. Social Media Activities may include without limitation your name, your User profile, your age, your preferences, choices and viewpoints with regards to the topic or subject matter of the relevant social media page, your photos and other images and your videos.
11. Personal Information Retention
We retain your Personal Information as long as is commercially reasonable to provide you with our Services, complying with any applicable laws, resolving disputes, and enforcing any of our agreements or our Terms of Service, or the other purposes described in this Privacy Policy. We may retain your Personal Information for longer periods if we have obtained your consent to use or retain your Personal Information for another or similar purpose. We may also retain your Personal Information for any such period as may be required by applicable law.
Because these needs can vary for different Personal Information types in the context of different products, actual retention periods can vary based on criteria such as User expectations or consent, the sensitivity of the information, the availability of automated controls that enable Users to delete information, and our legal or contractual obligations. If you have any questions concerning our retention of your Personal Information, please contact MBA at info@mbacg.com.
12. Updating Your Information and Choices
You may update or correct information about yourself through the Website’s account registration forms or by contacting MBA at info@mbacg.com.
You may opt-out of receiving promotional mail, emails, or other forms of communication from us by unsubscribing using the link on the email communication or by contacting MBA at info@mbacg.com. Please be sure to include your current information and the requested changes you would like us to make to your marketing profile in your communication.
Please note, we may still send you certain communications relating to your use of our Website, such as administrative and service announcements, security notifications, and Terms of Service or Privacy Policy updates, and these communications may be unaffected if you choose to opt-out from receiving our marketing communications.
13. Applicable Law
The Privacy Policy will be governed by and construed in accordance with the laws of the District of Columbia in the United States, without regard to its conflicts of law provisions.
14. Your California Privacy Rights [California Users Only]
As discussed in this Privacy Policy, we may from time to time elect to share your Personal Information with third parties for those third parties’ direct marketing purposes. Under California Civil Code § 1798.83, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties for their direct marketing purposes. That notice will identify the categories of Personal Information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such Personal Information. If you are a California resident and would like a copy of this notice, please submit a written request to MBA at the following address (limit one request per year): info@mbacg.com. You must include your full name, email address, and postal address in your request. Please allow thirty (30) days for us to respond.
15. Know Your Rights Under The General Data Protection Regulation (“GDPR”) [European Union Users Only]
Unless subject to an exemption under the GDPR, you have the following rights with respect to your Personal Information:
• The right to request a copy of the Personal Information we hold about you;
• The right to request that we correct any Personal Information if it is found to be inaccurate or out of date;
• The right to request your Personal Information be erased where it is no longer necessary for us to retain such information;
• The right to withdraw your consent to the processing of your Personal Information at any time;
• The right to request we provide you with your Personal Information and where possible, to transmit that information directly to another information controller, (known as the right to information portability), where applicable;
• The right, where there is a dispute in relation to the accuracy or processing of your Personal Information, to request a restriction on further processing;
• The right to object to the processing of Personal Information. Please note, this only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority), direct marketing, and processing for the purposes of scientific/historical research and statistics;
• The right to lodge a complaint with authorities.
• The right to transfer your Personal Information abroad. Please note, if your Personal Information is to be transferred to countries or territories outside the European Union, you must include details of how the information will be protected.
If we wish to use or process your Personal Information for a purpose not covered by this Privacy Policy, we will provide you with a new notice explaining this use prior to commencing the processing and setting out the relevant purposes and processing conditions. Wherever and whenever necessary, we will seek your consent prior to any new use or processing.
16. MBA & GDPR [European Union Users Only]
Under the new law effective May 25, 2018, you have the right to manage the Personal Information we have collected from you in the due course of using our Website and related Services. These rights include the:
• Right to be forgotten: you may request we delete all of your Personal Information without undue delay.
• Right to object: you may prohibit certain Personal Information uses.
• Right to rectification: you may request that incomplete Personal Information be completed or that incorrect information be corrected.
• Right of access: you have the right to know what Personal Information is being processed and how.
• Right of portability: you may request that Personal Information held by us be transported to another entity.
17. Questions or Comments Regarding this Policy
We value your comments and opinions. If you would like to act on any of the rights discussed above, please contact MBA at info@mbacg.com.