Privacy Notice

Personal Data

While using the Service, we may ask you to provide us with certain personal data that can be used to contact or identify you. By providing this data, you do so under your free will and consent to the collection. The following are the categories and types of personal data that we may collect from or about you, depending on how you interact with us:

• Direct identifiers: Direct personal identifiers, such as name, online username or social media handle and alias.
• Contact information: Direct personal identifiers such as email address or phone number and indirect identifiers (e.g., postal address).
• Demographic information: Indirect identifiers such as age, gender, race, education level, and nationality.
• Purchase or Transaction information: Products you have purchased, and payment information such as credit or debit card numbers.
• Communication information: Non-content information (e.g., time of day and addressing information) and content information (i.e., the body of the message you send) through the use of chatrooms, forums, submission forms, or message boards provided by us, or through phone calls, emails, and text messages.

Automatically Collected Information

We collect personal information automatically as you navigate our Service. By browsing the Service, you freely consent to this collection. The technologies deployed through our Service collect your device information, browsing actions, and patterns as follows:

• Usage information: Information about your interaction with our Service, such as the pages you access on our Website, the frequency of access, what you click on, referring URL, traffic data, and when you accessed our Service.
• Location information: Information about your location may be determined through your device’s IP address.
• Device information: Information about the device you are using, such as hardware model, Internet Protocol address, Media Access Control (MAC) address, operating system, web browser type, and your Service preferences.
• Clickstream data: We may record what you have clicked while on our Service. This data can tell us the type of computer or device and browsing software you use and the address of the website from which you linked to our Service. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Service, and how customers navigate to and on our Service.

Information from Third-Party Social Media Services

Our Services may include social media features and plugins, such as social media widgets.

These social media features may use cookies or other tracking technologies to collect information about your internet activity, such as your IP address and which page you are visiting on our Service. We may collect personal data that is already associated with your social media account, such as your name, email address, activities or contact list associated with that account.

Such social media features are hosted by third parties and your interactions with those features are governed by the privacy policies of the companies that provide them. Specifically, Mastermind allows you to use the Service through the following social media services:

• beehiiv
• Google, including YouTube
• LinkedIn
• Thinkific

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on the Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the Service. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use these technologies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide you with services available through the website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These are used to recognize you when you return to our Service in order to improve your experience and allow us to personalize our content for you.
• Analytics / Performance Cookies
  Type: Persistent Cookies
  Administered by: Third Parties
  Purpose: These cookies collect information about how you use our Services, for example how you arrived at our Services, and which pages you visit most often. This helps us to improve the way our Service works. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics.
• Targeting Cookies
  Type: Persistent Cookies
  Administered by: Third Parties
  Purpose: These cookies record your visit to our site, the pages you have visited and the links you have followed. These cookies are usually placed by third-party advertising networks. They remember the other websites you visit, and this information is shared with third-party organizations, for example advertisers.
• Pixels / Web Beacons
  Type: Persistent
  Administered by: Us / Third Parties
  Purpose: We, or third parties, may employ a software technology called web beacons (also known as web bugs, clear gifs or pixels). Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to let us know when content is viewed. We, or our third-party partners, may tie the information gathered by web beacons to the other information we collect about you. This could be used, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Site Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us. We may use email marketing service providers to manage and send emails to you. For more information on our email marketing service providers, beehiiv, please visit: https://www.beehiiv.com/privacy

Mastermind, located in Alpharetta, GA, United States is the data controller because Mastermind alone or jointly with others determines the purposes and means of the processing. Details are included below but Mastermind will gladly help to clarify the specific legal basis that applies to the processing.

The Company may use Personal Data for the following purposes:

• To Provide, Maintain, and Improve our Service: This includes managing the Services, setting up your user account(s), granting access to resources, understanding user behavior, improving performance, securing the Services, and monitoring the usage of the Service. This also includes other internal operations such as financial reporting and business planning.
  Legal Basis: Legitimate interest in ensuring the effective operation of the Services.
• Communication: To attend and manage your requests. To contact you by email, telephone calls, SMS, or other forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  Legal Basis: Legitimate interest in ensuring Service-related communications.
• Sales and Marketing: To advertise or market to you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  Legal Basis: Legitimate interest in sharing resources or offering products or services.
• For Business Transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Mastermind assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
  Legal Basis: Legitimate interest in sharing resources or offering products or services.
• Legal Compliance: To meet our legal obligations.
  Legal Basis: Legitimate interest in preventing fraud, following applicable legal obligations, and cooperating with law enforcement and public authorities.

Disclosure of Information

We disclose personal data to the following categories of recipients as long as there is a business purpose and as long as we have sufficient commitment to controls to protect your personal data:

• With Vendors/Service Providers: We may share your personal data with service providers to host the site, assess site usage, conferencing, messaging, email marketing, productivity tools, workflow automation, learning management, ecommerce management, payment processing, IT services, banking, legal, insurance and accounting services, and facilitation of certification.
• With Affiliates: We may share your personal data with Mastermind affiliates to carry out the Service and to offer you Services related to your interests. Affiliates include the parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• With Business Partners: We may share your personal data with Mastermind business partners to offer you products, services or promotions. For example, Mastermind may hold a webinar with another organization and Mastermind, and the other organization will get access to the contact information of individuals that sign up to attend.
• With Other Users: When you share personal data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. For example, if you interact with other users or register through a social media service, your contacts on the service may see your name, profile, pictures and description of your activity.
• With Law Enforcement: When required to share personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may also disclose your personal data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability
• For Business Transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of the Mastermind business to another company. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Notice.
• With Your Consent: We may disclose your personal data for additional reasons with your consent.

Based on your location and applicable laws, you may have certain rights related to your personal data. Mastermind will review rights requests and respond within a reasonable period of time. Our response may include whether an exception or limitation applies and whether we need more time.

• Request access to Your Personal Data. The right to access or update the information we have on you. Whenever made possible, you can access or update your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data (Stop Processing). This right may exist where we are relying on a legitimate interest as the legal basis for Mastermind’s processing and there is something about your particular situation which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
• Not to be subject to any Automated Decision Making and Profiling. We do not make decisions based solely on automated processing, but you may reach out to learn more.
• Challenge Adherence to Privacy Principles. To complain about a perceived breach of privacy principles, such as to challenge adherence to the Fair Information Privacy Principles (FIPPS) or Australian Privacy Principles (APPs) you may contact us as defined below.

Exercising Your Rights

You may exercise your rights by contacting us (see the Contact Us section below). Please note that we may ask you to verify your identity and the applicable law before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a Data Protection Authority about Mastermind’s collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Retention of Your Personal Data

The Company will retain your personal data and usage data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Security of Your Personal Data

We use industry standard technical and organizational measures to secure your information. Due to the fallibility of these measures and the systems they protect, we cannot guarantee that data, including personal data, is absolutely safe from intrusion or other unauthorized access.

The Service is controlled and operated by us from the United States. Mastermind may process, transfer, and store your information on servers located in a number of countries, including the United States. As a result, your personal data may be subject to data protection and other laws that may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial processes in the countries in which we operate. By using the Service, or by providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside or are a citizen.

Your personal data may be transferred to, stored, and processed in another country than where it was collected. It may be processed by individuals who work for Mastermind or Mastermind’s sub processors. Mastermind is headquartered in the United States. Because of this, most data we process will be transferred to the United States. In cases where the personal data originates in the EEA/EU or UK and is transferred to the United States, we will take appropriate steps to ensure an adequate level of data protection of the recipient. Technical and Organizational Measures (TOMS) are in place to provide administrative, physical, and technical safeguards for Personal Data. Measures include:

• Encrypted storage.
• Physical security controls restrict access to systems that store or can access Personal Data.
• Access Controls include unique usernames, complex passwords, and two factor authentication (when available).

Mastermind customers using Assessment Services requiring transfers out of the EU/EEA can take advantage of a data processing agreement as well as Standard Contractual Clauses and the UK International Data Transfer Addendum (if applicable).

Subprocessors & Third Parties Handling Personal Information

• Microsoft
  Purpose: Microsoft 365, including Outlook and Teams
  Headquarters: One Microsoft Way, Redmond, WA 98052, United States
  Hosting & DPA: Hosted via Microsoft servers located in the United States, DPA contains Standard Contractual Clauses (SCCs) available here. Additionally, Microsoft maintains accredited certification to ISO/IEC 27001 and ISO/IEC 27701.
• OpenAI
  Purpose: Technical writing, including document analysis
  Headquarters: 3180 18th Street, Suite 100, San Francisco, CA 94110, United States
  Hosting & DPA: Hosted via Microsoft Azure servers located in the United States, DPA contains Standard Contractual Clauses (SCCs) available here.
• Zoom
  Purpose: Web conferencing software
  Headquarters: 55 Almaden Boulevard, Sixth Floor, San Jose, CA 95113, United States
  Hosting & DPA: Hosted via AWS servers located in the United States, DPA contains Standard Contractual Clauses (SCCs) available here. Additionally, Zoom maintains accredited certification to ISO/IEC 27001.
• Slack
  Purpose: Electronic messaging, including internal, client, and partner communications
  Headquarters: 50 Fremont Street, San Francisco, CA 94105, United States
  Hosting & DPA: Hosted via AWS servers located in the United States, DPA contains Standard Contractual Clauses (SCCs) available here. Additionally, Slack maintains accredited certification to ISO/IEC 27001 and ISO/IEC 27701.
• beehiiv
  Purpose: Email marketing
  Headquarters: 228 Park Avenue, Suite 2329976, New York, NY 10003, United States
  Hosting & DPA: Hosted via AWS servers located in the United States and maintains additional terms specific to EU users.
• Thinkific
  Purpose: Learning management system for delivering training courses
  Headquarters: 369 Terminal Avenue, Suite 400, Vancouver, BC V6A 4C4, Canada
  Hosting & DPA: Hosted via AWS servers located in the United States, DPA contains Standard Contractual Clauses (SCCs) available here.
• Credly by Pearson
  Purpose: Digital badge generation and credential verification for training-related certification recipients
  Headquarters: 368 9th Avenue, Sixth Floor, New York, NY 10001, United States
  Hosting & DPA: Hosted by AWS servers, DPA contains Standard Contractual Clauses (SCCs) available here. Additionally, Credly by Pearson maintains accredited certification to ISO/IEC 27001 and ISO/IEC 27701.
• Fourthwall
  Purpose: E-commerce provider for merchandise
  Headquarters: 212 Pacific Avenue, Venice, CA 90291, United States
  Hosting & DPA: Hosting is located in the United States. Services are accessible to users in the European Economic Area and the United Kingdom, with additional privacy terms applicable to these regions.
• Zapier
  Purpose: Workflow automation platform for integrating apps and services
  Headquarters: 548 Market Street, Suite 62411, San Francisco, CA 94104, United States
  Hosting & DPA: Hosted via AWS servers located in the United States, DPA contains Standard Contractual Clauses (SCCs) available here.

This privacy notice section for California residents supplements the information contained in Mastermind’s Privacy Notice and it applies solely to all visitors, users, and others who reside in the State of California. Business, for the purpose of CCPA/CPRA, refers to Mastermind as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California. CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”). Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Types of Collected Personal Information

• Identifiers
  Example: Real name, alias, postal address, and email address.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  Example: Name, signature, address, telephone number, insurance policy number, education, employment history, and other skills or credentials.
• Internet or other similar network activity
  Example: Interaction with our Service or advertisement.
• Sensitive personal information
  Example: Account login and password information, geolocation data.

Sources of Collected Personal Information

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

• Directly from You
  For example, from the forms you complete on our Service, preferences you express or provide through our Service.
• Indirectly from You
  For example, from observing your activity on our Service.
• Automatically from You
  For example, through cookies we or our Service Providers set on your device as you navigate through our Service.
• From Service Providers
  For example, organizations to monitor and analyze the use of our Service, or organizations that we use to provide the Service to you.

Use of Collected Personal Information

We may use or disclose personal information we collect for business purposes or commercial purposes. See the “Use of Collected Information” section above for details.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Identifiers
  Example: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  Example: Name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
• Internet or other similar network activity
  Example: Interaction with our Service or advertisement.

The categories listed above are defined in the CCPA/CPRA and not all of the examples of that category of personal information were disclosed. When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sharing of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers
• Mastermind’s affiliates
• Mastermind’s business partners
• Third party vendors to whom you or your agents authorize us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use your personal information for the business purposes described in Mastermind’s Privacy Notice, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Identifiers
  Example: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  Example: Name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
• Internet or other similar network activity
  Example: Interaction with our Service or advertisement.

The categories listed above are defined in the CCPA/CPRA and not all of the examples of that category of personal information were disclosed.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers we know are less than 16 years of age, unless we receive affirmative authorization from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt in to the sale of personal information may opt out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If You have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• Right to Notice
  You have the right to be notified which categories of personal information are being collected and the purposes for which the personal information is being used.
• Right to Know/Access
  You have the right to request that we disclose information to you about Mastermind’s collection, use, sale, disclosure for business purposes and share of personal information.
• Right to Opt-out of Sale/Sharing
  You have the right to direct us to not sell/share your personal information. Under the CCPA, these concepts are broadly defined. See the sections above on sale and sharing for more detail.
• Right to Correct
  You have the right to correct or rectify any inaccurate personal information about you that we collected. An exception may apply.
• Right to Limit Use and Disclosure of Sensitive Personal Data
  You have the right to request to limit the use or disclosure of certain sensitive personal information we collected about you, unless an exception applies.
• Right to Delete
  You have the right to request the deletion of your personal data under certain circumstances, subject to certain exceptions.
• Non-Discrimination
  You have the right not to be discriminated against for exercising any of your consumer rights. Based on exercising your rights we will not deny goods or services to you, charge different rates, or provide a different level of quality.

Exercising Your CCPA/CPRA Data Protection Rights

If you are a California resident, in order to exercise any of your rights under the CCPA/CPRA, you can contact us:

• By email: privacy@mastermindassurance.com
• By visiting this page on our website: https://mastermindassurance.com/contact
• Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom We collected personal information or an authorized representative (nominee).
• Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request
• And confirm that the personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined above, you have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

If applicable, click “Privacy Preferences”, “Update Privacy Preferences” or “Do Not Sell My Personal Information” buttons listed on the Service to review Your privacy preferences and opt out of cookies and other technologies that We may use. Please note that you will need to opt out from each browser that you use to access the Service.

Additionally, you can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform: http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on Your mobile device.

California Online Privacy Protection Act (CalOPPA)

Mastermind’s Service does not respond to Do Not Track (DNT) signals. DNT is a concept that was promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

California Shine the Light Law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Mastermind’s Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13, we take steps to remove that information from Mastermind’s servers. If you are using this Service from a jurisdiction where there may be a different age threshold, contact us and we are happy to clarify the requirements.

Mastermind’s Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Notice. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We may update Mastermind’s Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page. You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.

If you have any questions about this Privacy Notice, a right to exercise, or a grievance to address, you can contact us:

• By email: privacy@mastermindassurance.com
• By visiting our website: https://mastermindassurance.com/contact