Sandler Systems, Inc Global Privacy Policy

Effective Date / Last Revised: April 11, 2022

Sandler Systems, Inc. and its affiliates and subsidiaries ("Sandler," "our," "we," or "us") respect your right to privacy.  This Privacy Policy explains the personal data that we collect, share and use about you, and how you can exercise your privacy rights.  This Privacy Policy applies to personal data that we collect through our websites, including Sandler Online, our learning management platform (the "LMS") (collectively, the "Sites"), any offline interactions we have with you, and in the course of providing our products and services (collectively, the "Services").

If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Privacy Policy.

We recommend that you read this Privacy Policy in full to ensure you are fully informed.  However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link below to jump to that section.

    This Privacy Policy does not apply to Sandler's franchisee websites, or our franchisees' collection, use or disclosure of personal data. Each individual franchise is owned by a franchisee as a separate legal entity from Sandler.

    What does Sandler do?

    Sandler is a global training provider for sales, leadership and management, headquartered in the United States. For more information about Sandler, please see the “About Sandler” section of our Site at http://csa.themayfliesusa.com/about.

    What is personal data?

    "personal data" or “personal information” means any information relating to an identified or identifiable natural personal.  Examples include your name, email address, mailing address and phone number, as well as certain online identifiers which may be collected by tracking mechanisms (e.g., cookies) on the Sites, but excluding information that is publicly available.

    What does "Processing" personal data mean?

    "Processing" is a term defined under certain privacy laws, but generally means the collection, use, storage, disclosure, transmission, destruction or alteration of personal data.

    Personal data we collect

    In the chart below, we identify the categories of personal data that we collect, the types of data, the purpose for which we collect and use such data, and our legal basis for Processing your personal data.

    CATEGORY OF PERSONAL DATADATA ELEMENTPURPOSES / USESLEGAL BASIS
    IdentifierFull name
    Email address
    Mailing address
    Shipping address
    IP Address
    Unique personal identifiers
    Employer and Title
    Operational (such as):
  • Process orders
  • Ship products
  • Provide you access to our Services
  • Respond to your requests
  • Provide customer service
  • Manage your account
  • Operate the Sites
  • Fraud Prevention
  • Protect the security of the Sites and the data we collect
  •  

    Services (such as):
  • Develop our Services
  • Improve our Services
  • Improve our user experience
  • Develop training materials
  • Improve our Sites
  • Evaluate Users needs
  •  

    Advertisement, Marketing and Sales (such as):
  • Direct marketing to you
  • Performing market research and data analysis.
  • Customize the Sites.
  • Help us to understand demographics and content preferences
  •  

    Legal (such as):
  • To comply with legal and regulatory requirements, requests or obligations
  • Business transactions
  • To protect legal rights of Sandler, any third parties and you as applicable.
  •  

    Employment (such as)
  • Considering you for employment
  • In connection with administering employee benefits
  • As otherwise necessary in connection with your employment as described below
  • Legitimate Interest

    Performance of a Contract

    Protected ClassificationsBirthdate
    Race
    Citizenship
    Marital status
    Gender
    Ethnicity
    Military or Veteran status
    Disability status (if applicable as our employee)
    EEO job category
    To evaluate your qualifications for employment or an internship.
    To perform our duties as an employer.
    To comply with our legal obligations.

    Legitimate Interest

    Performance of a Contract

    Commercial Information

    Services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

    Services and products in your shopping cart that are not yet purchased

    To fulfill purchases and ship products.
    To provide customer service.
    To advertise and market Sandler products and Services.
    To help us improve the Services and the Sites.
    To develop new Services.
    To evaluate qualifications as a prospective franchisee or business partner of Sandler.
    To evaluate your coursework.

    Legitimate Interest

    Performance of a Contract

    Internet ActivityBrowsing history and preferences
    Device type
    Performance / statistics
    Browser version
    Content you viewed on the Sites
    Sites you visited before and after visiting the Sites
    Links clicked on the Sites
    Landing pages visited within the Sites
    Session cookies
    Unpurchased shopping cart information
    Session ID
    Log-in / log-out activity
    Activities performed on the Sites and within your account
    To offer, operate, maintain, deliver, troubleshoot and update the Sites
    For fraud prevention
    To help us provide safe and reliable Services through the Sites
    To support, analyze, develop, improve, and enhance our products, Services, user experience, trainings, and Sites
    To provide direct marketing to you
    For market research and/or data analysis
    To evaluate user needs and customize the Sites
    To help us understand demographics and content preferences

    Legitimate Interest

    Performance of a Contract

    Sensory DataRecordings of webinars may include your voice or face if you are on camera
    We collect videos of you that you create as part of training homework
    You may upload pictures of yourself when using Sandler Online
    Webinars are posted online for your organization to review such videos for enhanced learning opportunities
    To provide the Services, evaluate your homework and provide instructor feedback
    To perform a contract
    With your consent
    For a legitimate interest
    EmploymentEmployment history
    Employment application
    Resume
    Pay requirements
    References
    Pay requirements
    Licenses and certifications
    Your skills and experience
    Insurance coverage
    Schooling and degree information
    To perform background or credit checks in considering you for employment
    To evaluate your qualifications for employment or an internship
    To perform due diligence in hiring
    To perform Sandler's obligations as an employer
    Performing employer related activities
    Administrating benefits
    To assist in administering our programming and communicating with your employer.
    To perform a contract
    For a legitimate interest
    EducationEducational background
    Graduation dates
    Degrees and certifications
    Membership in professional organizations
    The licenses and certifications you hold
    To evaluate your qualifications for employment or an internship.
    To recommend and advertise additional Services that you may be interested in
    To improve and develop our Services
    To perform a contract
    For a legitimate interest
    InferencesInferences drawn you’re your purchase history and the courses you have taken.
    Creation of a "buyer persona" reflecting a buyer's preferences, characteristics, predispositions, behavior, attitudes, abilities, job duties, and aptitudes
    To recommend or advertise Services to you.
    For market research and/or data analysis.
    To help us understand demographics of the Site, product preferences and content preferences.
    To evaluate user needs and customize the Sites.
    Legitimate interests
    Categories of sources of collection

    We generally collect personal data from the following three categories of sources: (1) you provide personal data directly to us, (2) we automatically collect personal data from you when you use our Site (e.g. cookies) or when we provide Services, or (3) we receive personal data about you from third-party sources (e.g. from public sources).

    We collect personal data you provide

    We collect personal data that you provide directly to us. Personal data is required to use certain features of the Sites, for example, to create an online account, download resources, purchase training or other materials, take courses, submit job applications, send us questions through our Sites, receive or request data from us, and respond to communications from us. We also collect information you provide which may not be considered personal data, such as information about your organization, the team you work on and what brought you to Sandler or its Sites.

    Online Forms. We collect personal data when you fill-out online forms or send other communications through our Sites, such as our "contact us" form, when you sign-up for an account (such as when you want to access the e-Learning Library or create a Sandler Online account), when you request more information about being a franchisee or strategic partner, when you download resources, articles, white papers and other guides, and when you sign-up for a webinar, immersion program, summit or other event.

    Online Accounts / Sandler Online.  We offer several resources that require you to set-up an account with Sandler, such as when you sign-up for Sandler Online or want to use our e-Learning Library. When you create an account with Sandler through our Sites, we collect your contact information and any other information requested from you at such time. You are also required to choose a password which you should keep confidential. When you are signed into your account, we may link your account with the
    activities you perform on our Site.

    Purchases. When you make a purchase through our Sites, you will be re-directed to a PCI-compliant payment processor ("Payment Processor(s)"). Our Payment Processors may be located in other countries, and they may transfer certain personal data to other countries in order to provide us payment processing services, such as transaction processing and fraud prevention. For example, we may use Authorize.net or Shopify to power our online store--you can read more about how Authorize.net uses your personal data here: http://usa.visa.com/legal/privacy-policy.html [authorize.net] and how Shopify uses your personal data here:  http://www.shopify.com/legal/privacy [shopify.com].

    Any information that you provide directly to the Payment Processor is governed by that Payment Processor's privacy policy, not this Privacy Policy. Sandler does not receive your credit card, debit card or other financial information when you make a payment - such information is provided directly by you to the Payment Processor. However, Sandler does receive information about your purchase and your contact information (e.g. name, email address, mailing address, phone number). Sandler will keep a record of your purchases. We may collect tax identification numbers you submit for tax-exemption purposes.

    Blog / Forum / Comments. If you leave a comment on our Sites, such as a response to a blog post, those comments may be posted publicly on our Sites or removed from our Sites, in Sandler's sole discretion. Comments you send us will not be kept confidential, and we may identify you as the source of the comment. If you are signed into your account when you comment on our Sites, we may be able to link you and your account to your comments, and others in your organization may be able to read your comments.

    Franchise or Strategic Partner Information. If you apply for or request information about becoming a Sandler franchisee or strategic partner, we will collect the information requested from you in our online forms, and any follow-up information during any screening or application process. We may collect information pertaining to your financial security, such as bank account balances and information pertaining to your spouse. Additional terms and conditions will apply, as agreed to between you and us, if we decide to proceed with your franchisee or strategic partner application.

    Chats with Sandler. If you use the chat feature of a Site, we will collect all text and other data that you submit via that chat feature. If you use a chat feature while signed into your Sandler account, we may link the chat information to your account.

    Meet With Us. If you enter your email, you will gain access to an integrated calendar that will allow you to schedule a meeting with a representative from Sandler.

    ROI Calculator. We collect the information that you provide when using our ROI calculator. We use a third party to help us run the ROI calculator, and they may collect certain personal data about your use of that ROI calculator.

    Marketing Communications.  We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. We may use third-parties or service providers to deliver
    these communications to you. You may opt-out of such emails by using the unsubscribe link in the email or contacting us at [email protected] with “Unsubscribe” in the subject line. To opt-out of other communications (e.g., postal marketing), please contact us as set forth in the "Contact Us" section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.

    Feedback.  When you provide comments or feedback about our Sites, the content on the Sites, or our products or Services ("Feedback"), we will not treat that Feedback as confidential. We may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

    If you choose to submit information pursuant to our #HowToSucceed campaign, you understand that we may use your picture, a video of you and your statements about Sandler publicly, including posted on our Site, without compensation owed to you. We may shorten or modify any statements you make or videos you provide in order to fit within a certain word count or time length for posting on our Site.

    Business Contracts. If you enter into a business relationship with us, such as if you become a franchisee or strategic partner, we may use information collected about you in accordance with any contract agreed to between you and us. If your employer purchased access to our LMS platform, the personal data we received directly from that employer is used pursuant to our contract with that employer; however, any information we collect from users of the LMS (including employees of such employers) is used in accordance with this Privacy Policy.

    Conferences and Trade shows. If you attend one of our trade shows, conferences or events, such as the Sandler Summit, we may collect information to confirm your registration, provide logistics-related information, for marketing purposes, or to send related promotional or future event offers.

    External links

    If any part of the Site links you to other websites, those websites DO NOT operate under this Privacy Policy, but are linked for your convenience only. We recommend you read the privacy notices posted on those websites to understand their procedures for collecting, using and sharing personal data.
    Applying to Work With Sandler. To submit job application materials online to work or intern with Sandler, you will be redirected from our Sites to a website operated by BambooHR (or another service provider we may use to help us collect job application materials). You may be required to create an
    account with that vendor.

    Events. When you sign-up for an event or purchase hotel accommodations for an event, you are re-directed from our Site to a third-party website.

    Evernote. If you choose to download an Evernote template linked on our Sites, you will be re-directed to Evernote's website and you may be required to sign-up for an Evernote account to download such template.

    Podcasts. We use a third-party service provider to host our Sandler podcasts. When you visit the "how to succeed" website to listen to our podcasts, you are visiting a third-party website. Further, our third-party service provider syndicates our podcasts with Apple, Google and Spotify-those third parties may receive data about your interactions with those podcasts.

    Information collected automatically

    When you visit the Site, we automatically collect certain information from you through use of cookies and other online tracking mechanisms. Please review our Cookie Policy found here for more information about our use of cookies and online tracking.

    Information collected from third-party sources

    We obtain data about individuals from our franchisees, strategic partners, referral sources, various third-party companies and public sources. We may combine that data with personal data or other data we collect from you. This enhances our existing data about our customers and Site users, improves our ability to contact you, and enhances our marketing capabilities. If you sign-up for a Sandler event through a third-party website, that third party may share certain personal data about you with us. We also receive contact information of prospective new customers from current Sandler customers if
    someone refers a contact to us.

    How is personal data used?

    In addition to the uses described throughout this Privacy Policy, we use personal data for the following purposes:

    As Stated or Agreed to at the Point of Collection.  We may use personal data for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use personal data to respond to your questions, comments, or complaints. We may also use personal data as requested or consented to or by you.

    Administration.  We use personal data for administrative purposes, such as managing your accounts, facilitating transactions and processing payments, refunds and credits, to inform our business strategies, to understand the demographics of our Sites and user preferences, for evaluating applications, to live chat with you, and to provide you materials or resources that you requested or that we think may interest you.

    Management of Sites and Services Improvement.  We use personal data to manage the Sites, such as troubleshooting problems, improving the content and functionality of the Sites, statistical and other analyses of the Sites, and to customize the Sites to you and our users. We may also use your personal data to improve our Services and customer service efforts, and to develop new products or Services.

    Advertising and Notice.  We may use personal data to send you promotions or to perform targeted advertising, to notify you of new Services, products or programs, to notify you of new features of our Sites, to notify you of changes to our Terms or this Privacy Policy, and for other similar communications.

    To Protect Our Rights.  We may use personal data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites. We may also use personal data to address any U.S. DMCA claims or counterclaims, to seek business, financial or legal advice, and to respond to other legal requests.

    Categories of third parties with whom we share personal data

    We may share your personal data with the following categories of third parties and/or service providers:

    Employees, Affiliates and Subsidiaries.  We may share your personal data with our employees, affiliates and subsidiaries who have a need to know the information for our business purposes.  If you are a Sandler employee or independent contractor, other employees can see certain information about you, such as contact information and employment information, through Sandler's HR platform.

    Franchisees. We may share personal data with our franchisees for our business purposes, such as to refer prospects and provide local training offerings.

    Service Providers and Third Parties.  We may share personal data with service providers that provide services for us. For example, we may share personal data with service providers that help us host and manage the Sites; maintain physical storage for paper files and documents; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide public relations; provide email services; provide payment processing services, support delivery of our Services and products, provide data processing; and support or provide the security of the Sites. We may also share personal data with third parties such as event sponsors, referral partners and other strategic partners of Sandler.

    Government Officials / Law Enforcement.  We will cooperate with law enforcement and other governmental agencies, and may disclose personal data: (i) if we believe in good faith we are legally required to disclose that personal data, (ii) if we are advised to disclose personal data by our legal counsel, or (iii) when necessary to identify, contact, respond to or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Sandler or any other party.

    Professional Advisors.  We may share personal data with certain professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Sandler.

    Other Users. In the event of a copyright infringement claim relating to the Site, we may share your personal data with any person or entity to whom the notice or counter-notice relates, in order to facilitate a prompt resolution of the copyright infringement claim. For U.S. residents only, copyright infringement notices and/or counter-notices will be treated in accordance with our Digital Millennium Copyright Act Policy found at: (“DMCA Policy”).  In addition, if you are using Sandler Online, you may be able to chat with other users of Sandler Online, and they can see certain information about you through their accounts with Sandler Online.

    Business Transactions.  We may use your personal data in connection with certain business transactions, including the purchase, sale, merger, rental, combination or any other type of business acquisition, transfer, disposition and securitization of financing as well as in connection with any bankruptcy or similar insolvency proceeding, including as part of any related due diligence process.

    Your Employer and Our Trainers.  When you sign-up for Sandler Online to take courses provided through your employer, we may share certain information with your employer, such as whether you complete certain courses.  When taking courses using Sandler Online, Sandler or you may share your personal data with Sandler employees, contractors, trainers or franchisees that are providing training to you through Sandler Online.

    Other.  We may share personal data with third parties or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

    INFORMATION WE DO NOT INTEND TO COLLECT

    Special Categories of personal data.  “Special Categories of personal data” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a person, data concerning health or a person’s sex life and/or sexual orientation, and any other data that is considered "sensitive data" under applicable law.  Except as described above when you apply to work with Sandler, we do not knowingly collect Special Categories of personal data from you.  Your provision of Special Categories of personal data, or other sensitive data, is not mandatory; however, we may not be able to consider you for employment with Sandler if you do not provide certain, requested information. Please refrain from sending Special Categories of personal data to us unless requested during your job application process.

    Information from Minors.  We do not knowingly collect personal data from persons under the age of majority in their place of residence (typically 18 years old).  Do not send us personal data if you are under the age of majority.  If you are a parent or guardian and you believe your child provided us with their personal data, you may contact us as described in the "Contact Us" section below and we will make good faith efforts to delete that data.

    Your rights and choices regarding personal data*

    *Various countries throughout the world and various US states have different privacy laws giving their residents certain rights.  These rights may include any of the following.  We will comply with any rights you have under the laws of the country or state in which you reside that are applicable.  We may require you to prove your identity before we respond to your request.   If there are any country or state specific sections that apply to you at the end of this Privacy Policy, those sections shall control in the event they conflict with or are inconsistent with this section.

    • Right of Access - You may have the right to be informed of and request access to the personal data we process about you.  This may allow you to receive a copy of the personal data we process about you.
    • Right to Rectification - You may have the right to request that we amend or update inaccurate or incomplete personal data about you.
    • Right to Erasure (Deletion) - Under certain circumstances, you may have the right to request deletion of your personal data.
    • Right to Restrict - Under certain circumstances, you may have the right to request that we temporarily or permanently stop processing all or some of your personal data.
    • Right to Object - Under certain circumstances, you may have the right to object to our processing of your personal data (including profiling).
    • Right to Data Portability - Under certain circumstances, you have the right to request a copy of your personal data in electronic format and further request that we send such personal data to you or to another party.
    • Right To Withdraw Your Consent.  In the event we ask for, and receive, your consent to process certain personal data about you, you may withdraw your consent at any time by emailing us at [email protected], and we will comply with such request if required by applicable law.  This provision also applies if we secured your consent for marketing purposes.
    • Automated Decision Making.  Sandler does not make any Automated Decisions on your behalf or about you without first obtaining your consent.  In the event we secure your consent to do so, you have the right to object to the processing of personal data via Automated Decision making at any time by contacting us at [email protected].  “Automated Decision” means an automated decision made about an individual person by automated means without any human involvement, including profiling, often where meaningful logic is involved, that produces legal effects that significantly affects the involved individual.
    • Non-Discrimination. You may have the right to not receive discriminatory treatment for exercising your rights under applicable privacy laws. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this provision. 
    • Sale of Personal Data.  Various states and countries define "sale" of personal data differently.  If Sandler "sells" your personal data, as such term is described under applicable data privacy law, you may have the right to opt-out of the sale of your personal data.  You may submit your opt-out request here: [insert the “DO NOT SELL MY PERSONAL INFORMATION" button]
    • Right to Lodge a Complaint. You have the right to lodge a legitimate complaint with the applicable supervisory authority.  

    How to Exercise Your Rights.  To exercise any rights you have under privacy laws that apply to you, please contact us.  We will respond to your request within a reasonable period of time.  Requests may be denied pursuant to applicable law or if certain exceptions under applicable law apply. Ways to contact us include: 

    oll Free:  800-669-3537
    Email:  [email protected]

    The consequences of not providing personal data

    Sandler will not be able to provide some Services or provide you with access to certain parts of the Sites without processing certain personal data.  For example, we need to collect login and contact information from you when you access certain parts of our Sites, and we need to collect certain contact information from you when you make a purchase.

    Data retention

    Sandler will only keep your personal data for so long as it has a reasonable business purpose for doing so or where we are required to keep it by applicable law.

    De-Identified or aggregated information

    Sandler may collect, use, share, transfer, create and otherwise Process de-identified and aggregated information for any purpose in compliance with applicable laws. Sandler is the sole and exclusive owner of such de-identified and aggregated information, including if Sandler de-identifies personal data so that it is no longer considered personal data under applicable laws

    Social Media

    We are active on social media. The Sites may allow you to connect and share data with social media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such social media platforms to facilitate those communications and features. The Sites may also use advertising networks and services offered by social media platforms to deliver advertising content. Use of these services requires the applicable social media platforms to implement cookies or pixel tags to deliver ads to you while you access a Site.

    Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our social media pages any comments or content that you post on our social media pages. Your use of social media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Privacy Policy. We encourage you to review those policies and terms before using any social media features provided through our Sites or third-party websites.

    Information security

    We make commercially reasonable efforts to protect personal data.  We protect personal data using technical and organization measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration of personal data appropriate to the type of personal data processed.  If a breach of your personal data occurs, we will notify you of the breach if and as required under applicable law.

    HOWEVER, NO DATA TRANSMISSION OVER THE INTERNET OR A DEVICE CAN BE GUARANTEED TO BE 100% SECURE.  WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.

    Access to personal data in other countries

    If you access the Sites from outside the United States, please be aware that personal data may be transferred to, stored in, and Processed in the United States. Certain governmental authorities may not consider the level of protection of personal data in the United States to be equivalent to that required in other jurisdictions.

    The European Union (EU) and the United Kingdom (UK) specifically have determined that the United States does not have an adequate level of protection for personal data.  Further, certain countries require that personal data transferred to other countries can only occur if the recipient resides in a country with materially similar data protection laws.  Given that the U.S. does not have data protection laws in every state that provide a materially similar level of protection of personal data as certain other countries, Sandler uses (1) the Standard Contractual Clauses in transferring personal data of EU or UK citizens across international borders or other approved methods by the EU, and (2) other data transfer agreements that may be required by other countries in order to transfer personal data across country borders.  You may request a summary of the appropriate safeguards or seek inquiries regarding such safeguards by contacting us at [email protected].  We will respond to your request or inquiry within a reasonable time period.


    Additional terms applicable to California residents

    The CCPA and Personal Information.  If you are a California resident, you may have additional rights (or different rights than described above) under the California Consumer Privacy Act, as amended, and its implementing regulations (the "CCPA").  Although the terms "personal information" and "personal data" can often be used interchangeably, in this section when referring to "personal information", we are referring to how that term is defined under the CCPA.

    Collection, Source, Purpose and Sharing of Personal Information.  To view the categories of personal information we collect, the sources from which personal information is collected, the purposes for which we collect personal information, and the categories of third parties and/or service providers with whom we share personal information, please click on the applicable hyperlink in this paragraph, or see the applicable section in this Privacy Policy above.

    Selling or Disclosing Personal Information for a Business Purpose.

    In the last 12 months we sold, or disclosed your personal information for a business purpose, if indicated below. See the section above titled “Personal Data We Collect” for more detail on the type of personal information in each category.

    Category of Personal InformationPersonal Information is/was sold in the last 12 monthsPersonal Information is/was disclosed for a business purpose in the last 12 months
    IdentifiersYesYes
    Protected ClassificationsNoYes
    Commercial InformationYesYes
    Internet ActivityYesYes
    Sensory DataNoYes
    Employment InformationNoYes
    Education InformationNoYes
    Employment InformationNoYes
    InferencesNoYes

    Your Rights to Opt-Out of the Sale of Personal Information.

     We do not sell your personal information to other companies for money. We do share personal information with certain companies to help us and them advertise to you, and as part of our strategic partner and referral relationships. Under California law, this sharing of personal information is considered the sale of personal information.

    California residents may direct us not to “sell” their Personal Information at any time (this is your right to “opt-out”). You may submit your opt-out request here: [insert the “DO NOT SELL MY PERSONAL INFORMATION" button]

    To opt-out online, please use the following web-form: [insert link].  Other ways you may opt-out include:

    Toll Free:  800-669-3537
    Email:  [email protected]

    Your Rights to Access and Deletion.  California residents have the right to request certain information or request deletion of their personal information.  Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:

    Right to Access.  You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting or selling your personal information, (d) the categories of third parties with whom we shared your personal information, (e) the specific pieces of personal information we collected from you (i.e. "data portability"), and (f) a list of categories of personal information we sold or disclosed for a business purpose in the last 12 months.

    Right to Request Deletion.  You have a right to request that we delete personal information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

    How to Exercise Your Rights of Access and to Request Deletion.  To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:

    Toll Free:  800-669-3537
    Email:  [email protected]

    http://csa.themayfliesusa.com
    Mail:  Attn:  Legal Department
    300 Red Brook Boulevard, Suite 400
    Owings Mills, Maryland, 21117, USA

    Verifiable Consumer RequestIn order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information.

    When we receive your request, we may ask you to provide additional information to verify your identity, including personal information. We will only use personal information we collect during the verification process for the purpose of verifying your identity.  If you maintain an account with us, we may use that account to respond to your request and/or verify your identity.  If we are unable to verify your identity as required by applicable laws and regulations, we may decline to comply with your request, and will let you know why.

    When We Will RespondWe will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select the format to provide such personal information. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

    Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.

    Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with Sandler, and (c) directly confirm with Sandler that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.  We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.  Furthermore, a parent or legal guardian may make a request on behalf of their child.

    California Shine The Light.  Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom the Sandler may have disclosed your personal information within the past year for direct marketing purposes; and (b) a description of the categories of personal information disclosed. Please contact us as set forth at the end of this Privacy Policy to receive this information.

    CALIFORNIA'S "DO NOT TRACK" REQUIREMENT.  WE DO NOT REACT TO "DO NOT TRACK" OR "DNT" BROWSER SIGNALS AT THIS TIME.

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    Other country-specific terms

    Australia.  This Section provides additional terms and information that apply to residents of Australia.  If you are not satisfied with our response to a question, you may contact the Australian Information Commissioner at:

    Mail: GPO Box 5218
    Sydney NSW 2001
    Phone: 1300 363 992
    Email: [email protected]
    Online: http://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint

    Brazil.  This Section provides additional terms and information that apply to residents of Brazil, pursuant to Brazil's General Personal Data Protection Law ("LGPD").  In lieu of the rights described in the main body of this Privacy Policy, residents of Brazil have the following rights under the LGPD:

        • I – confirmation of the existence of the processing;
        • II – access to personal data;
        • III – correction of incomplete, inaccurate or out-of-date personal data;
        • IV – anonymization, blocking or deletion of unnecessary or excessive personal data or personal data processed in noncompliance with the provisions of this the LGPD;
        • V – portability of the personal data (excluding anonymized data) to another service provider or product provider, by the means of an express request, pursuant with the regulations of the national authority, and subject to commercial and industrial secrets;
        • VI – deletion of personal data processed with the consent of the data subject, subject to the exceptions of the LGPD;
        • VII – information about public and private entities with which the controller has shared personal data;
        • VIII – information about the possibility of denying consent and the consequences of such denial; and
        • IX – revocation of consent, including if we are not complying with the LGPD.

    You also have the right to petition, against Sandler, before the national authority if you believe we are not complying with the LGPD.

    Czech Republic.  As a resident of the Czech Republic, you have the right to lodge a complaint with the Czech Republic’s Office for Personal Data Protection. They may be contacted at:

    Pplk. Sochora 27
    170 00 Praha 7
    Czech Republic
    [email protected]

    +420 234 665 800 (GDPR infoline)
    +420 234 665 111 (Phone)
    +420 234 665 555
    +420 234 665 444

    France.  As a resident of France, you have the right to lodge a complaint with the French data protection authority ("CNIL"). They may be contacted at: http://www.cnil.fr/en/contact-cnil

     Commission Nationale de l'Informatique et des Libertés
    3 Place de Fontenoy
    TSA 80715
    75334 PARIS CEDEX 07
    France
    Tel: +33 (0)1.53.73.22.22
    Fax: +33 (0)1.53.73.22.00

    Germany.  As a resident of Germany, you have the right to lodge a complaint with the relevant data protection authority.  Germany has a federal data protection authority and 16 Lander (state) data protection authorities.  A list of the various contact details of Germany's data protections authorities can be found here: http://www.datenschutzkonferenz-online.de/datenschutzaufsichtsbehoerden.html

    Mexico.  This Section provides additional terms and information that apply to residents of Mexico pursuant to the Federal Law on Protection of Personal Data in the Possession of Private Parties (Ley Federal de Protección de Datos Personales en Posesión de Particulares) ("LPPD").  Subject to the LPPD, you have a right to access, rectify, cancel and object to the processing of your personal data, which are called your "ARCO Rights." See the main body of this Privacy Policy for a more detailed description of these rights and how to exercise them.  If you believe that your right to protection of your personal data is improperly used in violation of the LPPD, you may reach out to Mexico's IFAI with an official complaint. For more information, please visit their website at www.ifai.org.mx.

    South Africa.  This Section provides additional terms and information that apply to residents of South Africa, pursuant to South Africa’s Protection of Personal Information Act ("POPIA").  "Personal Information", as used in this section, has the definition set forth in POPIA. In terms of POPIA you have the following rights in relation to your personal information:

        • to request access to, and information regarding the nature of personal information held and to whom it has been disclosed; such request for access may be refused on the basis of the grounds of refusal in the Promotion of Access to Information Act, 2000;
        • to request the restriction of processing of personal information in the circumstances contemplated in POPIA;
        • to not have personal information processed for direct marketing purposes by means of unsolicited electronic communications, save for in the circumstances permitted by POPIA;
        • to not to be subjected to a decision which is based solely on the automated processing of personal information intended to provide a profile of such person, save for in the circumstances permitted by POPIA;
        • to request to rectify or correct personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, subject to POPIA;
        • to request deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully or where we are no longer authorized to retain it, subject to POPIA;
        • to object to processing of personal information where the processing is on the basis that it protects your legitimate interests; where the processing is on the basis that it is necessary for pursuing our legitimate interests or a third party to whom it is disclosed; or where the processing is for the purposes of direct marketing other than by unsolicited electronic communications; and
        • to institute civil proceedings regarding the alleged interference with the protection of your personal information.

    In addition, you have the right to lodge a complaint with the Information Regulator in South Africa. The Information Regulator's details are as follows:

    The Information Regulator (South Africa)
    33 Hoofd Street
    Forum III, 3rd Floor Braampark
    Braamfontein, Johannesburg
    Email: [email protected]  / [email protected]

    United Kingdom.  As a resident of the United Kingdom, you also have the right to lodge a complaint with the Information Commission's Office. They may be contacted at:  http://ico.org.uk/make-a-complaint/data-protection-complaints/

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    Updates to this Privacy Policy

    We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site.  We will conspicuously provide notice if we make any material changes to this Privacy Policy or otherwise communicate such updates to you.

    You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

    Translations

    Translations to this Privacy Policy may be provided; however, in the event of conflict between the English version and any other version of this Privacy Policy, the English version shall control unless the laws of your country of residence require otherwise.

    Contact us

    If you have any questions or concerns about our use of your personal data, please contact the Vice President of Legal, using the following details: [email protected] or (410) 559-2020.

    Data ControllerSandler Systems, Inc., 300 Red Brook Boulevard, Suite 400, Owings Mills, Maryland, 21117, USA