Privacy Policy

Last Updated May 25, 2020

This privacy policy (the “Privacy Policy”) constitutes an agreement between you and Miller Mendel, Inc. and its affiliates, corporate parent(s), and subsidiaries (collectively, “Miller Mendel,” “MMI,” “us,” “our,” or “we”) while accessing and using millermendel.com and other websites that we own or operate (collectively, the “Site”), eSOPH and other SaaS offerings, software, mobile applications or technologies owned or operated by MMI (collectively, the “Services”), and is governed by and a part of our Terms of Use.  Any terms defined in the Terms of Use have the same meaning when used in this Privacy Policy. Please note that additional, separate terms may apply to our Services.

SCOPE

This Privacy Policy applies to information that we collect when you visit the Site or submit your information to us on the Site or via the Services, via third parties that we work with to provide our Services, when communicate with us through email and other methods, or by any other means over the course of your use of our Services. This Privacy Policy also contains information about privacy rights specific to California residents.

CONSENT

By visiting the Site, creating an account or accessing the Services, or submitting information to MMI in any way, you consent to this Privacy Policy and the collection and use of information as described below.  At different stages of collecting information, we will take steps to notify you and to confirm that you agree. If you do not agree with our policies and practices, you may not be able to access or benefit from certain portions of the Site.

PERSONAL INFORMATION

As used in this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or device, such as:

  • Identifiers (e.g., name, address, telephone number, email address, username)
  • Sensitive personal information (e.g., state identification number, social security number)
  • Protected classification information (e.g., age, citizenship, sex, veteran or military status)
  • Biometric information (e.g., physical descriptors)
  • Internet or other similar activity (e.g., browsing history)
  • Employment-related information (e.g., current or past employment information)
  • Nonpublic educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)
  • Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Personal Information does not include (a) publicly available information; (b) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (c) deidentified information that cannot be easily linked back to the individual.

LAWFUL BASIS

We will only collect your Personal Information (a) when applicable, with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We will limit the collection of Personal Information to that which is reasonable and necessary. 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 a job applicant to an MMI Client.

During the preceding 12 months, we have collected these categories of Personal Information:

  • Identifiers (e.g., name, address, telephone number, email address, username)
  • Sensitive personal information (e.g., state identification number, social security number)
  • Protected classification information (e.g., citizenship, sex, veteran or military status)
  • Biometric information (e.g., physical descriptors)
  • Internet or other similar activity (e.g., browsing history)
  • Employment-related information (e.g., current or past employment information)
  • Nonpublic educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)

We collect Personal Information from these sources:

  • Directly from you with your consent when you communicate with MMI via the Site, the Services, or by email or phone as an MMI Client or as a job applicant to an MMI Client. We may ask you to provide identifiers like your name, email address, telephone number, or mailing address, as well as your job title. We use this information to communicate with you about our company and our Services.
  • Directly from an MMI Client, in our capacity as a service provider. We collect agency or organization information, point of contact information, account password and password hints or similar security information, information and documentation to populate your account as needed to collect information from job applicants for employment with the MMI Client, and MMI Client payment information. We use this information to establish the MMI Client’s account to use the Services, to provide our Services, to fulfill and manage MMI Client requests, and to communicate with the MMI Client about changes to our terms, conditions and policies. We process all payments via a PCI-compliant payment processor.
  • From you as a job applicant to an MMI Client, in our capacity as a service provider. If you use the Services as a job applicant to an MMI Client, we will collect certain Personal Information from you according to instructions we receive from the MMI Client. Note that your submission of Personal Information to the Services as a job applicant is governed by your relationship with the MMI Client, including but not limited to the notices, terms and other agreements presented to you while registering and using the Services, as well as the MMI Client’s privacy policy. MMI does not control what information an MMI Client collects about job applicants or how the MMI Client will use that information. If you would like to know how your Personal Information will be used by the MMI Client, please request those details from the MMI Client for which you have applied for employment or a volunteer position.
  • Indirectly from you, when you visit the Site or use the Services. We may automatically collect details about your interactions through the Site or Services, including your (i) search queries; (ii) device information (e.g., IP address, operating system, browser type, hardware ID, mobile network information and the device’s telephone number); (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. Like most commercial websites, we may use cookies and other technologies from time to time. Please read our Cookie Notice for more information. We collect this information to achieve our legitimate interest of providing and improving the Site and our Services.
  • From third parties, such as hosting providers, storage solution providers, advertisers, and analytics companies. The information these third parties collect may include Personal Information related to your internet or similar activities across different websites, apps and other online services. If you have any questions about an advertisement or other targeted content, you should contact the third party directly. We collect this information to achieve our legitimate interest of providing and improving the Site and our Services.

In addition to the specific uses above, MMI might use also your Personal Information to:

  • Provide the Site and Services and their contents, maintenance or support, and any other information, products or services that is requested from us.
  • Protect your privacy and enforce this Privacy Policy.
  • If we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Inspired Taste, or to others.
  • Comply with a law, regulation, legal process or court order.
  • Fulfill any other purpose to which you consent.

Children Under the Age of 16. Neither the Site nor the Services are 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 at (206) 330 2094 option 2.

DISCLOSURE OF PERSONAL INFORMATION

In the preceding 12 months, MMI has disclosed the following categories of Personal Information for a business purpose:

  • Identifiers
  • Sensitive personal information
  • Protected classification information
  • Biometric information
  • Internet or other similar activity
  • Employment-related information
  • Nonpublic educational information, including information protected under the Family Educational Rights and Privacy Act

MMI may disclose Personal Information for a business purpose to the following:

  • Service Providers. Vendors that provide us with various services (collectively, “Service Providers”) may have access to your Personal Information while they are performing their contractual obligations. These Service Providers include but are not limited to hosting companies, storage solution providers, advertisers, analytics companies, and billing processors. 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. The type of information that we provide to a Service Provider will depend on the purpose of the service that they provide to
  • Affiliate Companies. If we disclose your Personal Information to our affiliates, their use and disclosure of your Personal Information will be subject to this Privacy Policy.
  • Law enforcement, and regulatory and other governmental agencies, as permitted or required by law.
  • Cookie information recipients, subject to their respective privacy notices.
  • 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.

No Sale of Personal Information. MMI does not, and will not, sell your Personal Information.

No Automated Decision-Making. MMI does not use Automated Decision-Making (“ADM”) as part of the Services. MMI is not aware of whether a particular MMI Client uses ADM in connection with its job applicants or any other transactions related to MMI. Please check with the MMI Client to which you have applied for employment to confirm their use of ADM.

Aggregated and Deidentified Information. We reserve the right to share aggregate, anonymized, or deidentified information about any individuals with non-affiliated entities for marketing, advertising, research or other purposes, without restriction.

CONTROLLING YOUR PERSONAL INFORMATION

MMI provides you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Depending on where you reside, your options to control your Personal Information may include some or all of the following:

  • Changing your registration, subscription or use of the Services.
  • Changing your preferences for how and about what we communicate with you.
  • Correcting, updating, and deleting the Personal Information in your account. Please note that certain legal obligations may limit or prevent our ability to fulfill these requests, and that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Services for a period of time.
  • Requesting access to the Personal Information we hold about you and that we amend or delete it.
  • Choosing whether to receive marketing communications from us, including promotions, surveys, and information about products and services that may be of interest to you.
  • Controlling how the cookies we use interact with your browser.

Read more about privacy rights available to California residents.

Consumer Privacy Requests. At any time, you may exercise any of these controls and choices, express concerns, lodge a complaint, or obtain additional information about the use of your Personal Information by contacting us at (206) 330 2094, option 2.

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. You may, however, disable certain tracking as discussed below.

CALIFORNIA PRIVACY RIGHTS

MMI adopted this section to provide supplemental information in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and applies solely to residents of the State of California (“California Consumers”). The CCPA provides California Consumers with specific rights regarding their Personal Information. The following paragraphs describe CCPA rights and explain how to exercise those rights. Each of these rights is subject to our receipt of a verifiable consumer request, and certain exceptions and limitations, may apply.

  • Right to Disclosure. You have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months, 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 or selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; and (v) if we sold or disclosed your Personal Information for a business purpose, two separate lists stating (a) sales, 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. MMI is only required to respond to two disclosure requests within a 12-month period.
  • Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that MMI is prohibited by law from disclosing copies of certain pieces of Personal Information (e.g., government identification numbers, financial account information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. MMI is only required to respond to two access requests within a 12-month period.
  • Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. MMI may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
  • Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. 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, or (iv) 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 the CCPA.
  • 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.

California Consumers may exercise their CCPA rights by submitting a Consumer Privacy Request. MMI may only legally fulfill requests when we have sufficient information to confirm that you are the person about whom we have collected Personal Information or are an authorized representative thereof, and to properly understand, evaluate, and respond to it.

We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response. We do not charge a fee to process or respond to your verifiable consumer privacy 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.

DATA SECURITY

We implement measures designed to protect your Personal Information from accidental loss or unauthorized access, use, alteration or disclosure. However, the safety and security of your information also depends on you. We urge you to protect your user information and password and to be careful about giving out information in public areas of the Site or Services, which may be viewed by other users of the Site or Services. Unfortunately, transmitting information via the internet and mobile platforms is not completely secure. We cannot guarantee the security of your Personal Information when transmitted through our Site or 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.

Account Security. If you create an account with MMI, you will have login credentials. MMI encourages you to take steps to protect against unauthorized access to your account by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords or call forwarding numbers, or for any activity on your account via unauthorized activity.

COOKIE NOTICE

What Are Cookies? Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Cookies are used to recognize your device and to store your preferences. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising on sites provided by other entities.

 

Where We Place Cookies. We may set cookies on the Site and within our Services. Some cookies allow us to make it easier for you to navigate the Site or Services, while others are used to enable a faster login process or to allow us to track your activities on the Site and Service. We may also place cookies in the emails we send to track when the email is opened.

Types of Cookies. The cookies we use from time to time on the Site or Services may fall within the following categories:

  • Strictly necessary cookies are browser cookies that are necessary for the Site or Services to work as intended.
  • Functionality cookies monitor and enhance your browsing experience. We may use these cookies from time to time to help us to identify errors and other issues users may face when using the Site or Services, and to gain insight into Site performance.
  • Analytics cookies help us understand how users engage with our Site and Services. These cookies are typically deployed as a set of cookies to collect information and report website or application usage statistics without personally identifying individual users.
  • Advertising cookies can be used to personalize and measure the effectiveness of advertising on the Site and other websites.
  • Security cookies may sometimes be used by some websites to help identify and prevent potential security risks.

Please note that the names of cookies and their use can change from time to time as necessary to ensure that the Site functions as intended and, for third-party cookies, as determined by the third-party cookie host. MMI is not responsible for how third-party cookies behave or may change from time to time. You can control how cookies, including third-party cookies, interact with your browser as described in Controlling Cookies below.

Controlling Cookies. Most browsers provide for ways to control cookie behavior, either through built-in functionality or by using third-party plugins. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. Specifically, you can opt out of Google Analytics by installing Google’s opt-out browser add-on. On a mobile device, you can adjust your settings to limit ad tracking. However, certain features of our Site or other services may not work if you delete or disable cookies.

Websites and HTML emails may also contain tracking technologies like “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

CHANGES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. If we make material changes to how we treat your Personal Information, we will post the new Privacy Policy on this page. Your continued use of the Site or Services after we make changes is deemed to be your acceptance of those changes. The date that this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Privacy Policy to check for any changes.

CONTACT MMI

Please contact us with any questions or comments about this Privacy Policy and our privacy practices at (206) 330 2094, option 2.