MATLEN SILVER PRIVACY POLICY

Effective Date: June 1, 2023

Last Updated: June 1, 2023

{View our Privacy Notice for California Consultants and Candidates}

This Privacy Policy (“Policy”) covers the Matlen Silver Group, Inc. business (“Matlen Silver,” “we,” “us,” or “our”) including the owned and operated websites www.matlensilver.com, (the “Site”), and any services offered by us or other hosted service (collectively, our “Services”). The Services include services that assist our clients by building workforce and technology solutions to support client initiatives.

This Policy is incorporated into, and is part of, our Terms of Use available here https://matlensilver.com/terms-of-use/, which governs your access and use of the Site and/or Services. If you have entered into a separate written agreement with our business, that separate written agreement controls and those terms within this Policy that conflict with that separate written agreement do not apply.

This Policy describes the types of information we gather, use, transfer, and secure from visitors and users (“you” or “users”) of our Site and Services. By accessing any Site or using any Services, you agree to be bound by this Policy. Each time you use any Site or Services, the current version of our policies apply. Accordingly, when you use any Site or Services, please check the date of our policies at the top of the page and review any changes made since you last reviewed the Policy.

If you do not agree to the terms of this Policy or the Terms of Use, do not use the Site or any of our Services.

Types of Information We Collect

We may have collected the following categories of personal information:

• Identifiers, such as your name, mailing address, email address, zip code, telephone number, government identifiers, or other similar identifiers.
• Customer Records, such as username, company name, job title, business email address, and department.
• Protected Classification Characteristics, such as age, gender, and national origin.
• Commercial Information, such as information about products or services purchased, obtained or considered.
• Internet/Network Information, such as your browsing history, log and analytics data, information about the device(s) used to access the services, domain server, search history and information regarding your interaction with our websites or services and other usage data.
• Geolocation Data, such as information about your physical location collected directly or geolocation features on your device, including your IP address.
• Profession/Employment Information, such as your current or past employer and job title.
• Other Personal Information, such as personal information you provide to us in relation to a survey, comment, question, request or inquiry, information you provide when connecting a third-party account, product or service, and any other content you upload.
• Inferences, including information generated from your work with our clients, including about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
• Sensitive Personal Information, such as government identifiers, ethnic origin, race, and health information.

We obtain the categories of personal information listed above from the following categories of sources:

Personal Information We Collect Directly From You

• We collect personal information that you provide to us when you use our Services. For example, you may provide us with your email address, first name and last name, phone number, or other personal information.
• If you choose to share information publicly through our Site or Services, please understand that we cannot control the actions of third parties who may collect this public information.

Personal Information We Collect From Our Business Customers

• We may collect certain types of identifying information from our business customers, including your personal information.

Information We Collect Through Automatic Data Collection Technologies

• As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
  • Details of your visits to our website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
• We may also use cookies, tags, pixels, and similar tracking technologies (“Cookies”) to provide, customize, evaluate, improve, and secure our Site. A Cookie is a small piece of text that is placed on your website browser when you visit a website. These include our own first-party Cookies as well as third-party Cookies of our service providers and marketing partners.
  • We use Cookies for the following purposes:
    • Website Operation. Cookies help us run our Site securely and enable basic functions like page navigation.
    • Performance and Analytics. Cookies help us analyze how you interact with our Site. This enables us to monitor and improve our Site performance, services, and your experience. For example, we use Google Analytics to analyze Site traffic, how the Services are used, and to improve of our advertising efforts. To disable Google Analytics, please download the Google Analytics Opt-Out Browser Add-On. You also have the option to opt out of Google’s use of Cookies by changing your settings via Google’s advertising opt-out page.
    • Cookies allow us to deliver advertisements that are meaningful to you. Our third-party advertising partners may use the Cookies to build a profile of your interests, deliver relevant advertising on other websites, and measure the effectiveness of the advertisements.
  • You can control Cookies in your browser settings, including by enabling a global privacy control signal. If you disable or reject certain Cookies, our Site or Service may not function as intended.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• to fulfill or meet the reason you provided the information. For example, to provide support for our Services;
• to respond to inquiries, including to investigate and address customer concerns and monitor and improve our responses;
• to help maintain the safety, security, and integrity of our systems, services, databases and other assets;
• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• to present our Site and its contents to you;
• to provide you with information, products, or services that you request from us;
• to provide you with notices about our services;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Site or any services we provide;
• to fulfill any other obligations described when you provide your information;
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred; and,
• for any other purpose with your consent.

We collect and use sensitive personal information in ways that are consistent with the permissible uses under the CCPA.

Disclosing Personal Information to Third Parties

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose your personal information to a third party for a business purpose.  We may share your personal information with the following categories of third parties:

• Identifiers: Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.
• Customer Records, Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.
• Protected Classification Characteristics, Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.
• Commercial Information, Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.
• Internet/Network Information: Vendors who help us provide our website.
• Profession/Employment Information: Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.
• Inferences: Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.
• Sensitive Personal Information: Our clients where consultants are placed, our affiliates and subsidiaries to provide you with aspects of our Service, and our vendors who help us provide our Services, including data storage and hosting, customer support.

We may also transfer your personal information to third parties under the following circumstances:

• to comply with a legal requirement, judicial proceeding, court order, or legal process served on us;
• to investigate a possible crime, such as fraud or identity theft;
• in connection with the sale, purchase, merger, reorganization, liquidation, or dissolution of Matlen Silver;
• when we believe it is necessary to protect the rights, property, or safety of our business or other persons;
• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
• for marketing or advertising purposes; or
• as otherwise required or permitted by law, including any contractual obligations of Matlen Silver.

Retention of Information

Matlen Silver will generally retain information about you for so long as we have a legal or business purpose for it or a legal requirement to maintain it.  The criteria used to determine our retention periods include:

• the length of time we have an ongoing relationship with you (for example, for as long as you are working as a consultant with Matlen Silver or a prospective consultant) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
• whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
• whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Children and Privacy

We do not knowingly collect personal information from children in connection with the features of our Sites or Services. If we become aware that an individual under the age of 13 has provided personal information through our Sites or Services, we will immediately remove the individual’s personal information from our files.

Individual State Privacy Rights and Your Choices

If you are a California resident, or resident of another state providing you with privacy rights under the law, you may have additional privacy rights. This section describes those rights and tells you how to exercise those rights.

Sales and Sharing of Personal Information

Under the California Consumer Privacy Act (CCPA) and other similar laws, we may use cookies and other tracking technologies that enable certain advertising networks, social media companies, analytics services, and other third-party businesses to collect and disclose your personal information directly from your browser or device when you visit or interact with our Service or otherwise engage with us online. In some cases, we may upload personal information to certain of these partners for advertising or analytics purposes. This may be considered “selling” or “sharing” personal information as those terms are defined under applicable laws.

To opt-out of these “sales” or “sharing” of personal information, you must:

• Toggle cookies off in your browser or enable a global privacy control signal; and
• Submit a request using our form https://matlensilver.com/contact/ or emailing us at [email protected].

Privacy Rights

You may be able to exercise the following rights in relations to the personal information we have collected about you, subject to certain limitations under the law:

• The Right to Know and Data Portability Rights: In certain circumstances, you may have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
• The Right to Request Deletion: You may have the right to request that we delete your personal information that we collected from you and retained, subject to certain exceptions.
• The Right to Request Correction: You may have the right to request that we correct any inaccurate personal information we may hold about you. We will use commercially reasonable efforts to correct inaccurate personal information, taking into account the nature of the personal information and the purpose for our processing.
• The Right to Opt Out of Personal Information Sales or Sharing: You may have the right to opt out of the sharing or sales of your personal information to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights.

Exercising Rights

To exercise your rights described above or to appeal a decision we have made about the exercise of your rights (where applicable), please submit a request by either:

1. Sending us an email at [email protected].
2. Calling us at 908-393-8600.
3. https://matlensilver.com/contact/

We may need to validate your request.  In order to validate your request, we may ask you for the following information such as your name, your organization and when you interacted with us. Only you or an authorized agent may make a request related to your personal information. To designate an authorized agent to make a request on your behalf, please provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also verify the identity of your designated agent.

Third Party Sites and Links

Some links on our Site may redirect you to third-party websites and services that we do not operate. The privacy practices of these websites and services are governed by their own policies. We make no representations or warranties as to the privacy practices of any third parties. If you are submitting information to any third party through our Site or Services, you should review and understand that party’s applicable privacy practices — including their privacy policy — before providing your information.

Updates to this Policy

Each time you use our Site or Services the current version of the Policy will apply. When you use our Site, you should check the date of this Policy, which appears at the top of the Policy, and review any changes since the last version.

Contacting Us

If you have any questions or comments about this notice or the ways in which Matlen Silver collects and uses your information, please contact us:

• By email: [email protected]
• By telephone: 908-393-8600