Last Updated December 5, 2022
- Identifiers (e.g., name, email, telephone number, address, username);
- Sensitive information (e.g., government ID; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
- Legally protected information (e.g., race, citizenship, marital status, sex);
- Employment-related information (e.g., current or past employment);
- Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
- Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
- Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other similar activity (e.g., browsing history; content interactions); and
- Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Please note that information relating to a person that is publicly available, aggregated, anonymized, or deidentified may not be protected under privacy laws.
We will only collect your Personal Information as reasonable and necessary and with your consent, with a legitimate interest, or as authorized or required by law. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed.
COLLECTION & USE OF PERSONAL INFORMATION
The types of Personal Information we collect about you and the manner of collection depends on how you interact with MMI, whether as a client or potential client of MMI (an “MMI Client”) or as an applicant to an MMI Client (“Applicant”). We only collect, use, retain, and disclose Personal Information as is adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to provide you with the Services you have selected, or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Information.
During the preceding 12 months, we have collected Personal Information in the form of identifiers, employment-related information, nonpublic education information, and internet and similar activity data. Additionally, in our role as a service provider to MMI Clients, we may also collect sensitive information, protected classification information, and biometrics, as instructed by the MMI Client. MMI collects this Personal Information from:
- You with your consent when you communicate with MMI via the Site or by email or phone. Current or potential new MMI Clients and anyone interested in learning more about our Services can submit a contact form or communicate with MMI online, by phone, or through our other channels. We may ask you to provide identifiers like your name, email address, telephone number, or mailing address, as well as your job title. We collect this information with your consent, and we use it to communicate with you about the Services.
- MMI Clients, as a service provider. To facilitate MMI Client use of the Services, MMI collects point of contact information, account profile details, and documentation to setup and facilitate the MMI Client account on the Services. We collect this information to fulfill our contractual requirements to the MMI Client. All payments from an MMI Client to MMI are processed via a PCI-compliant payment processor.
- Your activity on the Site and use of the Services. We may automatically collect details about your interactions through the Site or Services, including your (i) device information (e.g., IP address, operating system, browser type, hardware ID, mobile network information and the device’s telephone number); (ii) location; (iii) usage details (e.g., traffic data, communication data and the resources you access and use through the Site and Services); (iv) stored information (e.g., metadata associated with the files stored on your device, personal contacts and address book information); and (v) geolocation information. We collect this information either as a service provider to the MMI Client or for the legitimate interest of providing and improving the Site and Services.
- Trusted third parties we work with for marketing and outreach purposes. The information these third parties collect may include Personal Information related to your internet or similar activities across different online platforms. For example, Police1 and FBI National Academy Associates provide us with information according to their own policies. We collect this information to achieve our legitimate interests of marketing the Services to interested parties and improving the Site and our Services.
In addition to the specific uses above, MMI might also use your Personal Information to provide you with maintenance or support, protect your privacy or ours, comply with law, bring legal action as we determine necessary, or to fulfill any other purpose to which you consent. MMI will not collect additional categories of Personal Information or use already collected Personal Information for purposes that are materially different, unrelated, or not reasonably necessary or compatible with the original purpose without notice and consent to you as required by law.
Cookies. Cookies are small text files downloaded and stored on your device when you interact with a website or online platform. Cookies may be used for functionality, security, analytics, or advertising. The Site uses first-party cookies for Google Analytics and Google Ads to identify unique users and sessions, store session data, and throttle the request rate. These technologies are essential for Site functionality.
Children Under the Age of 16. MMI Services are not intended for children under 16 years of age. MMI does not knowingly collect Personal Information from children under 16 without verification of parental consent. If you are under 16, do not use or provide any information on the Site or the Services. If we discover that a child under 16 has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information from or about a child under 16, or if you become aware of any unauthorized submission of information to MMI, including children’s information, please contact us.
Disclosure of Personal Information
MMI will only disclose Personal Information to the third parties as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed Personal Information for a business purpose to the following third parties:
- Our Service Providers. MMI relies on third party service providers like hosting companies, storage solution providers, advertisers, analytics companies, and billing processors to perform certain functions on the Site or Services. The type of information that we provide to a service provider will depend on the purpose of the service that they provide to In some cases, Applicant Personal Information is disclosed to a credit report bureau or social media screening service as requested and instructed by the respective MMI Client. In all cases, we prohibit our service providers from selling or disclosing the Personal Information we provide, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
- Law enforcement, and regulatory and other governmental agencies, as permitted or required by law.
- Other Third Parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
- Aggregated and Deidentified Information. MMI reserves the right to share aggregate, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.
Retaining Personal Information
MMI only retains Personal Information for the minimum period necessary to provide our Services or achieve our business goals. As a service provider to MMI Clients, MMI retains MMI Client data for the duration instructed by the respective MMI Client. MMI may retain some applicant Personal Information indefinitely until we are lawfully instructed to delete or correct that information. MMI reserves the right to retain data for longer periods as required by law or court order or if doing so is critical to our business. MMI securely deletes data at the conclusion of the applicable retention period.
Controlling Your Personal Information
MMI provides you a variety of methods and options to directly control how we collect and use your Personal Information, including but not limited to:
- MMI may send you informational or support emails related to your use of the Services. If you do not wish to receive emails from us, you can send us a request to opt-out.
- Text/SMS. If you provide us with your wireless phone number, you consent to MMI sending you informational or service text messages related to your use of the Services. The number of texts you receive will depend on the MMI Client to which you apply and any alerts they wish to send you through our Services. You can unsubscribe messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
- Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.
- Privacy Requests. Depending on where you reside, you may be entitled to exercise certain privacy rights provided by the laws that apply to your state. The S. Privacy Rights section below provides notice of privacy rights available under United States federal and state laws. IMPORTANT: Applicants should contact the MMI Client to which they applied to exercise their privacy rights.
If you are not an Applicant, but you have submitted Personal Information to MMI through the Site or otherwise, you can submit a Privacy Request to request information or exercise your rights under applicable privacy laws. You must provide us with sufficient information to verify your identity and understand the nature and scope of your request. We do not charge a fee to process your Privacy Request unless we have legal grounds to do so and without first providing you with a cost estimate. MMI endeavors to respond to Privacy Requests in the legally required timeline. If we are delayed in responding, you can appeal by contacting MMI.
MMI has implemented and maintains reasonable security measures to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. Our security measures are appropriate to the volume, scope, and nature of the Personal Information processed and designed to meet our duty of care with respect to your Personal Information.
However, submission of information over the Internet is never entirely secure. MMI cannot guarantee the security of your Personal Information when transmitted through the Services. Any transmission of Personal Information is at your own risk, and we are not responsible for circumvention of any privacy settings or security measures we provide. MMI encourages you to keep your login credentials confidential and always sign off from your account and device at the end of a session. MMI is not responsible for any lost, stolen, or compromised passwords or call forwarding numbers, or for any activity on your account via unauthorized activity.
U.S. Privacy Rights
This section provides legally required notices of consumer privacy rights applicable in California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states with similar requirements. If you are not an Applicant and you reside in a state offering privacy protections (“Consumer”), you can exercise your privacy rights as to MMI by submitting a Privacy Request. Please note that MMI cannot fulfill requests from Applicants, and Applicants should not submit requests to MMI. applicants must DIRECT QUESTIONS TO the MMI Client to which they applied.
Depending on where you live, you may have some or all of the following rights over your Personal Information:
- Right to correct inaccurate Personal Information about you on our systems.
- Right to delete your Personal Information that we collected and retained, with certain exceptions.
- Right to access, including to receive confirmation that we have collected Personal Information about you and copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that MMI may be legally prohibited from disclosing certain pieces of Personal Information, and we may be limited in the number or frequency of requests we must fulfill.
- Right to opt-out or limit our use or disclosure of sensitive information. You may have the right to opt-out or limit our use of your sensitive information. MMI does not collect sensitive information for its own purposes and does not disclose any sensitive information to third parties for the purpose of inferring characteristics about you or otherwise use your sensitive information without your consent.
- No selling or sharing. Some states entitle consumers to opt-out of the sale or sharing of Personal Information or targeted advertising practices. MMI does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out.
- No Profiling. MMI does not process your Personal Information to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you.
- Right to receive details about our collection and use of your Personal Information, such as: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting, using, processing, sharing or selling that Personal Information, as applicable; (iv) the categories of third parties with whom we share that Personal Information; and (v) if we sold or shared your Personal Information under the CCPA, two separate lists stating: (a) sales or sharing, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.
- Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.
- Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.