Privacy Policy

Last Updated: March 26, 2024 

Markstein Consulting, LLC (“Company,” “we,” “our,” and/or “us”) values the privacy of individuals who use our Site and its contents. This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Site (“Users”).  By using our Site, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes.  Beyond the Privacy Policy, your use of our Site is also subject to our Terms above in this Agreement.  Any and all capitalized terms not defined herein shall have the meaning ascribed to them in our Terms.  

1. INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below.

1.1 Information You Provide to Us.  
(A) Registration and ID Information. When you register to use the Site, we collect and retain your name, phone number, email, and zip code and other pertinent personal information.  We also collect this information whenever you make updates to the aforementioned information. 
(B) Communications. If you contact us directly, we may receive additional information about you.  For example, when you contact our customer support team, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.  If you subscribe to our newsletter, or other emails, or other means of constant contact, then we will collect certain information from you, such as your email address.  When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Site.  Additionally, you may provide us certain information from you in person at applicable Company events.
(C) Payment Information.  If you make a purchase or other monetary transaction through our Site, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
(D) Geo-Location.  Some of the services on the Site may collect precise geo-location information (e.g., GPS and WiFi) from your computer or mobile device.  Of course, you can turn off collection of your geo-location at any time by accessing the privacy settings of your device’s operating system and applications.  We also may have access to metadata in the photographs you upload.
(E) Job Inquiries.  When you apply for a job, we collect the employment-related information you submit, such as job preferences, work history and similar information provided in your application.
(F) Social Media.  You also can engage with us through social media plug-ins, integrations, and applications, such as Facebook and Twitter.  When you engage with Company through these social media services, you may allow us to have access to information in your profile, such as your name, email address, photos, gender, birthday, location, social media profile ID, likes, friends, connections, follows, and posts. For more information, please visit the relevant social media privacy policy and terms of service/use to learn how to manage your privacy settings.
(G) Other Sources.  Company also collects information from other sources, such as contact lists that we acquire from our clients and business partners, and may combine that information with other information we collect.

1.2 Information We Collect When You Use Our Site.
(A) Device Information.  We receive information about the device and software you use to access our Site, including IP address, web browser type, operating system version, phone carrier and manufacturer, device identifiers, mobile advertising identifiers, and push notification tokens.
(B) Usage Information.  To help us understand how you use our Site and to help us improve it, we automatically receive information about your interactions with our Site, like the features you use, and the dates and times of your visits.
(C) Information from Cookies and Similar Technologies. 
– We and third-party partners collect information using cookies, pixel tags, or similar technologies.  Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services.  Cookies are small text files containing a string of alphanumeric characters.  We may use both session cookies and persistent cookies.  A session cookie disappears after you close your browser.  A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site.  Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.  You can set your web browser to reject cookies. You do not need to have cookies turned on to use most of the Site.  You may, however, find that some areas on the Site are slower or do not function at all if cookies are disabled.  Some cookies – known as “essential” or “strictly necessary” cookies – are required for technical reasons in order for our Site to operate.  To learn more about cookies generally, visit the website http://www.allaboutcookies.org.  
– The Site also may from time to time use clear GIFs (also known as pixel tags or web beacons). A clear GIF is computer code that contains a unique identifier that enables us to monitor user activity and traffic relating to the Site.  We use GIFs to gather aggregate information on visits to the Site, track usage of website links, and assist with features of the Site.
– We also use Google Analytics, which collects aggregate information about use of the Site and reports website trends to us.  Google Analytics does not directly identify individual users.  We also use Google’s targeted advertising services.  You can learn about Google’s practices at https://safety.google/privacy/privacy-controls/.
(D) Our Policy On Do Not Track Signals.  Most web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser blocks that website from collecting certain personal information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including Company, do not respond to DNT signals.

2. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect: 

• To provide, maintain, improve, and enhance the Site, including the services you request to engage in; 
• To customize your experience of the Site’s services; 
• To understand and analyze how you use the Site and develop new products, services, features, and functionality; 
• To communicate with you, provide you with updates and other information relating to the Site, provide information that you request, respond to comments and questions, and otherwise provide customer support; 
• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you; 
• To facilitate transactions and payments; 
• To find and prevent fraud, and respond to trust and safety issues that may arise; 
• For compliance purposes, including enforcing our Terms or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and 
• For other purposes for which we provide specific notice at the time the information is collected.

3. HOW WE SHARE THE INFORMATION WE COLLECT

3.1 Affiliates.  We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

3.2 Vendors and Service Providers.  We may share any information we receive with vendors and service providers retained in connection with the provision of the Site.

3.3 Clients, Sponsors, and Co-Branding Partners.  We may share information with partner brands, clients, sponsors, retailers, events, charities, sports leagues, and other agencies to create promotions and campaigns to engage customers, pursuant and subject to the use requirements in this Privacy Policy. 

3.4 Analytics Partners.  We use analytics services to collect and process certain analytics data.  These services may also collect information about your use of other websites, applications, and online resources.  To help us understand how you use the Site and to help us improve it, we automatically receive information about your interactions with the Site, like the functionality you use and the dates and times of your visits.

3.5 As Required By Law and Similar Disclosures.  We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

3.6 Merger, Sale, or Other Asset Transfers.  We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.  The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

3.7 Consent.  We may also disclose your information with your permission.

4. YOUR CHOICES

You can unsubscribe from our promotional emails via the link provided in the emails.  Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative and/or operational messages from us.

5. THIRD PARTIES

Our Site may contain links to other websites, products, or services that we do not own or operate.  We are not responsible for the privacy practices of these third parties.  Please be aware that this Privacy Policy does not apply to your activities on these third-party websites, products, and/or services or any information you disclose to these third parties.  We encourage you to read their privacy policies before providing any information to them.

6. SECURITY

6.1 We make reasonable efforts to protect your information by using physical, technical, and organizational measures designed to protect your personal information against unauthorized access and loss.  We restrict access to your personal information to those employees and authorized suppliers who need to know that information to perform their job functions.  Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure, and we can make no guarantees as to the security or privacy of your information.  Please use your own security measures to protect your personal information.  If you create an account with us, please protect your password – actions taken through your user account are deemed authorized by you.  If you believe that your account or information is no longer secure, please notify us immediately at info@markstein.co.

6.2 We may suspend your use of all or part of the Site without notice if we suspect or detect any breach of security.  You understand and agree that we may deliver electronic notifications about breaches of security to the email address associated with your account or in our database.

6.3 We retain your personal information for as long as needed to fulfill the purpose for which it was collected unless a longer retention period is required or permitted by law.  When your personal information is no longer needed, we securely destroy it as required by law.

7. CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under thirteen (13) years of age, and no part of the Site is directed to children.  If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at info@markstein.co.  Immediately upon learning that a minor has provided us with personal information, we delete that personal information from our records.

8. YOUR CALIFORNIA PRIVACY RIGHTS

8.1 The California Consumer Privacy Act of 2018 (“CCPA”) offers residents of the State of California – referred to as “Consumers” in CCPA – certain privacy rights with respect to their Personal Information. This California Privacy Notice describes the privacy rights available to California Consumers and how to exercise them.  In the CCPA, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

8.2 If you are a California Consumer, then CCPA gives you the following rights:

• You have the right to request information about the Personal Information that we collected about you (see table below) and how and why we collect it. 
• You have the right to opt out of Company’s sale of your Personal Information when and if Company determines the purpose and means of processing your Personal Information.  (In the CCPA, “sale” means transferring or making available Personal Information to third parties for monetary or other valuable consideration.) Please email us at info@markstein.co for details about how to opt out of the sale of Personal Information.   
• You have the right to request information about our disclosure for business purposes of your Personal Information to third parties. 
• You have the right to request the deletion of your Personal Information. 
• You have the right to not be discriminated against for exercising any of these rights.

8.3 The following table lists categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA.  We indicate for each listed category the specific types of Personal Information in the category that we have collected within the past twelve (12) months.  We use all of the Personal Information that we collect for the purposes described in this Privacy Policy and table below.  Since we share most of this Personal Information with other businesses (such as our clients, sponsors, and co-branding partners) and this sharing enables Company to generate valuable consideration (such as sponsorships and advertising), it is likely that each of these categories was “sold” within the meaning of CCPA in the past twelve (12) months.  We provide more information about how we use and disclose personal information above in this Privacy Policy.