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Palm Beach, Florida 33480
We can be reached via e-mail at TheMcShaneLetter@gmail.com or you can reach us by telephone at [PHONE NUMBER]
General
The McShane Letter ("TML") has adopted the following policy (the "Privacy Policy") that applies to the information about you that is collected, used and disclosed by TML in the course of its business activities, including the information collected, used and disclosed by you on the www.themcshaneletter.com web site (the "Web Site").
Consent
Except where permitted or required by law, TML will endeavor to obtain the consent of each individual providing personal information to TML for the collection, use or disclosure of such personal information by TML.
Any use of the Web Site signifies your consent and agreement to the terms and conditions contained in this Privacy Policy, and to the collection, use and disclosure described herein of your personal information by TML. If you do not agree with the Privacy Policy, do not use or access the Web Site or information, material, products or services provided therein. If at any time you wish to withdraw your consent to the collection, use and disclosure described herein of your personal information by TML, you may do so by contacting TML in the manner specified in the "Accessing, Changing or Updating Your Information or Your Privacy Preferences" below.
You may also withdraw your consent to the terms and conditions contained in this privacy policy by providing notice in writing to that effect delivered to the address as specified in the "Contact Us" section below. However, please note that if you do withdraw your consent to the provisions of this Privacy Policy, TML may cancel your Account. You further acknowledge and agree that you will not, after withdrawing your consent to the provisions of this Privacy Policy, use or access the Web Site or information, material, products or services provided therein. If you use the Web Site after withdrawing your consent, such action signifies your consent and agreement to the terms and conditions contained in this Privacy Policy, and to the collection, use and disclosure described herein of your personal information by TML.
Collection of Information
When you access and use the Web Site, our web server automatically collects certain technical information ("Technical Information") about your visit to the Web Site, including your Internet Protocol (IP) address, referring IP address, the internet browser and the operating system used by you, and information on what web pages on the Web Site are accessed or used by you. In addition, if you have set up an Account (see below) and are signed in, the keywords you use to search for jobs or potential employees may be matched with your Personal Information, as defined below.
If you wish to access and use certain information, material, products and services offered by TML, including those offered on or through the Web Site, TML will require that you set up an account ("an "Account") with TML and provide certain information about yourself ("Personal Information"). In setting up your Account, TML may require that you provide some or all of the following Personal Information: 1) your full name you're your mailing address (including postal or ZIP code); 3) e-mail address; 4) telephone and facsimile numbers; and 5) user name and password. In addition to the information above, if you wish to purchase services, TML will require your credit card number and associated information. TML may also receive and collect information about you from other parties, including the third party vendors featured on the Web Site. The Technical Information and the Personal Information will be used by TML for the purposes set out below in the "Use and Disclosure of Information" section.
Warning: Other Web Sites
Please note that other web sites may collect information about you when you visit the other web sites and that this Privacy Policy does not extend to information collected by such web sites, including those web sites that provide hypertext links to the Web Site and those web sites not controlled by TML that you may be directed to by hypertext links found on the Web Site. Web sites not controlled by TML are not covered by this Privacy Policy and TML does not accept any responsibility or liability for the collection, use or disclosure of information about you by any other web site. For information regarding the privacy policy on another web site, click on the privacy policy for that web site.
Use and Disclosure of Information
The information that is collected, stored and processed in the course of its business operations is used for a number of purposes, including providing employers with an online placement service and job applicants with an online employment search service, providing customer service to you, communicating with you, informing you of or providing updates or upgrades to products or services, customizing and facilitating your use of the Web Site, improving, modifying or developing products and services, and marketing, including direct marketing of products and services offered by or through TML (including those of third parties) through the distribution (by e-mail or otherwise) of catalogues, advertisements or other publications to you. TML will also use Technical and Personal Information about you and aggregate it with Technical and Personal Information about others, such that no person is individually identifiable. TML will then use this aggregated information for web site analysis, product or service analysis, statistical analysis, or marketing and promotional purposes.
Information about you is important to our business and we are not in the business of selling your information to others. Except as required or permitted by applicable law, the information that is collected, stored and processed by TML will only be disclosed to other parties in the circumstances outlined below.
- Agents. Information will be disclosed to a person that TML is satisfied has been authorized by you to receive information. Information will also be disclosed to agents of TML such as a company hired to deliver packages on behalf of TML and a company hired by TML to provide list processing services to assist TML in the mailing of its newsletters. Agents of TML will only be given access to information required by them in order to perform the services on behalf of TML.
- Disclosure for Legal Purposes. TML will disclose information about you if required to do so by law, court order or as requested by any other government or law enforcement authority. TML will also disclose information about you where TML, acting reasonably, believes that such disclosure is necessary or advisable, including when TML has reason to believe that the safety of TML employees, customers or others is at risk, or if disclosure of such information is necessary or advisable to identify, contact or bring legal action against someone who may be causing interference with TML's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed in such activities.
- Sale of the Business. TML will disclose information about you to a purchaser in the unlikely event of a change of ownership of all or part of TML through an asset or share sale, or some other form of business combination, merger or joint venture. This will occur only if the parties have entered into an agreement under which the collection, use and disclosure of the information is restricted to those purposes that relate to the business transaction, including a determination whether or not to proceed with the business transaction, and is to be used by the parties to carry out and complete the business transaction.
- Third Party Vendors. Information may be disclosed to the third party providers of products and services. TML will share Technical Information and Personal Information about you only if such organizations agree to act in a manner consistent with the relevant principles articulated in applicable personal information protection or privacy legislation. Please note that if you do not want your Personal Information to be shared with one or more third party providers of products and services, you may instruct TML not to disclose your Personal Information to such parties by contacting TML as set out below in the "Contact Us" section and indicating your preference not to have your Personal Information disclosed to such parties.
- With Your Consent. With your prior consent, TML may disclose information about you.
Use of Cookies
When you visit the Web Site, we place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the web site that placed the cookie on your hard drive. The cookie functions similarly to an identification card and allows the Web Site to identify you and to record your passwords and preferences. The cookie allows TML to track your visit to the Web Site so that TML can better understand your use of the Web Site and your interest in the services provided therein so that TML can customize and tailor the Web Site to better meet your needs.
Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a web site placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages. If you choose not to accept the cookies placed on your hard drive by TML, you will not be able to access a number of web pages found on the Web Site.
Retention
Technical Information and Personal Information will be retained by TML for as long as TML believes it is necessary to fulfill the purpose for which it was collected. TML has, and is putting in place records management protocols which outline the procedures for the retention and subsequent destruction of TML records, including those that contain Personal Information.
Security
TML endeavors to maintain physical, procedural and technical security with respect to the Web Site and its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. TML has security measures in place to prevent the modification, misuse, loss or misappropriation of information about you, including the provision of a secure environment in which the information is stored and controlling access to such information by parties external to TML.
One such security measure used by TML is assigning you a user identification and password upon setting up an Account with MSE. You acknowledge and agree that the user identification provided by TML to you so that you may access, utilize or otherwise enjoy the Web Site and the password selected by and used by you in conjunction with the user identification to access, utilize or otherwise enjoy the Web Site are to be kept secret and confidential. You shall not disclose the user identification or password to any other party without the express written permission of MSS. You further acknowledge and agree that you will be responsible for each and every access, use or enjoyment of the products or services and of the content that occurs in conjunction with the password and user identification given to you by TML, and that TML is authorized to accept the user identification and password as conclusive evidence that you have accessed, utilized, or otherwise enjoyed the products or services or the content.
If any individual misuses the Personal Information of another individual, this will be considered a serious offence for which disciplinary action may be taken, up to and including termination of access rights to the Web Site or employment, if the circumstances warrant such action.
ACCESSING, CHANGING OR UPDATING YOUR INFORMATION OR YOUR PRIVACY PREFERENCES
TML permits access to and review of Personal Information held by TML about you unless TML is otherwise permitted or required by law to not provide such access. You may, at any time, access, view or update all of your information stored in your Account, including your privacy preferences, by either logging into your Account on the Web Site and following the appropriate links or by contacting TML directly as set out in the "Contact Us" section below. We ask that you review your Account information regularly to assist TML in ensuring that your information remains accurate and up-to-date.
Otherwise, upon receipt by the Privacy Officer of a written request by an individual, TML will, subject to the terms of this policy, provide that individual access to the Personal Information requested within a reasonable time. Where such time is expected to be longer than 45 days following such request, TML will advise the individual of the reason for the delay. TML will only provide access where the written request contains sufficient detail to enable TML, with reasonable effort, to identify the information in respect of which the written request is made. Should an individual require assistance with the submission of a written request, the individual may contact the Privacy Officer for assistance. While TML's response will generally be provided at a reasonable cost, each individual making a request will be informed in advance of any charges that apply in connection with the information request. Charges may relate, for example, to the transportation, reproduction or transmission of Personal Information. To guard against improper or fraudulent requests for access, TML will require sufficient information to allow it to confirm that the person making the request is authorized to do so before granting access or making corrections. This may occur, for example, where an authorized representative seeks information about an individual or where law enforcement authorities seek information about an individual.
If an individual believes any Personal Information concerning that individual is not correct, that person may request an update of that information by sending a request to the Privacy Officer. TML reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate.
If TML decides not to provide an individual with access to their Personal Information, TML will provide the individual making the request with an explanation as to why the request has been all or partially denied.
Please further note that even if you delete or change your information stored by us, information about you will continue to be stored by us indefinitely and may be used and disclosed by us for the purposes set out under the heading "Disclosure for Legal Purposes" under the "Use and Disclosure of Information" section above. Also, you should note that information may still be stored in places outside of our control such as in our agents', contractors', or third party databases (including those being used for archival purposes). In the event that you are having difficulties in reviewing or amending your information, please contact us directly as set out in the "Contact Us" section below.
Accountability and Complaints
TML has designated a privacy officer for you to contact to raise issues or concerns with respect to the collection, use and disclosure of your information about you. Please contact the privacy officer directly with your questions or concerns, call [PHONE NUMBER].
Contact Us
You may contact The McShane Letter at [PHONE NUMBER] or by e-mail at TheMcShaneLetter@gmail.com.
Amendment of this Policy
This policy is in effect as of December 1, 2004. You acknowledge and agree that TML may change, alter, amend or replace all or any part of the Privacy Policy at any time, and that such changes, alterations, amendments or replacements shall be effective as of the time of posting of the amended Privacy Policy to the Web Site. TML will provide notice on the Web Site of any material changes made to the Privacy Policy and your continued use of the Web Site after the time of posting of such notice will constitute evidence of your acceptance of the changed, altered, amended or replaced Privacy Policy. You further agree to regularly review the Privacy Policy for such changes, alterations, amendments or replacements. If you do not use or access the Web Site or information, material, products or services provided therein. If at any time you wish to withdraw your consent to the collection, use and disclosure described herein of your personal information by TML, you may do so by contacting TML in the manner specified in the "Accessing, Changing or Updating Your Information or Your Privacy Preferences" above.
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