Privacy Policy

MBO Partners^® makes it easier for self-employed professionals and their clients to work together. A key part of that is to protect your privacy.

We respect your privacy.

This Privacy Policy describes how we collect, use, disclose and protect the personal information we process in connection with our Services and Websites. You acknowledge that you understand that we may use your personal information as described in this Privacy Policy and/or as otherwise described in any supplemental notice we provide to you about our collection, use, disclosure and protection of your personal information.

Supplemental Information

We will generally collect, use, share and protect your personal information as described in this Privacy Policy. However, in some circumstances, we may provide you with supplemental information about our use of your personal information and/or, if applicable, we will obtain additional consent from you to use your personal information beyond what is described in this Privacy Policy. We may provide this supplemental information and/or obtain this consent through our Websites or via direct communications with you. Unless we tell you otherwise, the additional information and/or consent will apply in addition to what is described in this Privacy Policy.

In addition, if our contract with you includes supplemental information about privacy practices that are different from those contained in this Privacy Policy, the privacy practices set forth in the contract will apply.

Supplemental Information by Location

If you are located in one of the following areas, please click the applicable link for additional privacy terms and other disclosures applicable to our use of your personal information:

• • Additional Privacy Terms if You are Located in Australia
  • Additional Privacy Terms if You are Located in Europe (including the European Union, Switzerland, and the United Kingdom)
  • Additional Privacy Terms if You are Located in India
  • Additional Privacy Terms if You are Located in New Zealand
  • Additional Privacy Terms if You are Located in Singapore
  • United States
    • • Additional Privacy Terms if You are Located in California

When we refer to "personal information," we are referring to information relating to you. This may include your name, contact information, an online identifier, identification number, address, email address, Taxpayer Identification Number, demographic and historical information, photograph or other digital media, or other information that can be used to identify you or be linked with you as an individual.

Personal information does not include deidentified or aggregated information that cannot be linked to you.

We provide information and services to independent professionals and their clients. In order to provide our Services and to operate our Websites, we collect personal information. This Privacy Policy describes when we collect, how we use and protect your personal information, and when we share or disclose this information.

By using our Services or Websites, sharing your information with us or otherwise making your personal information available to us, you acknowledge that you understand that we may use your personal information as described in this Privacy Policy and/or as otherwise described in any other applicable notice we provide to you about our collection, use, disclosure and protection of your personal information.

Visitors

Visitors are individuals who visit our Websites, download resources, register for events, request information, or request to be contacted, but do not sign a contract with us.

Employees and Contractors

Contractors are individuals who operate as independent professionals or small independent businesses (sometimes referred to as consultants, independent contractors, ICs, freelancers, or contingent workers) and who take steps to enroll with us and sign a contract (a General Service Agreement or Independent Contractor Agreement). A Contractor may be an employee or independent contractor and includes applicants who seek to be an employee or independent contractor.

Employees are individuals employed by MBO and includes applicants who seek to be employees of MBO. If our internal policies, procedures and other documents applicable to employment are different from those contained in this Privacy Policy, the privacy practices set forth in such internal policies, procedures and other documents will apply to our collection, use, disclosure and protection of the personal information associated with our Employees.

Clients

Clients are the organizations for whom our Contractors perform their services or for whom MBO provides Services.

In this Privacy Policy, the term Client refers to a Client's employees, agents, representatives and other individuals that interact with us on behalf of a Client where appropriate.

Services

We help our Contractors by processing invoices and payroll, administering payroll taxes and benefits, giving access to various helpful tools, providing information about products and services useful to independent professionals, and other related services. We may also help Contractors set up a business entity or qualify as an independent contractor. We provide business management software, marketplaces for independent professionals and projects, and other related tools.

For Visitors, we provide educational materials, information on products and services, invitations to events, and opportunities to speak to a staff member and other related services.

Our services to our Clients include comprehensive management of their independent workforces, payroll processing, risk management (as it relates to independent workers), guidance on how to better use independent workers, and other related services. We provide marketplaces to assist Clients in finding independent professionals for their projects, and other related tools.

We provide services through our Websites and our interactions with you.

In this Privacy Policy, all of these, as well as all interactions or engagements arising from or related to the Services or when you otherwise engage with us, are collectively referred to as Services.

Websites

When we talk about our Websites (collectively, our "Websites"), we are referring to websites owned and operated by MBO Partners, which include www.mbopartners.com and www.mindsumo.com, as well as any other website we operate that links to this Privacy Policy, along with the Services, features, functionalities, browser extensions and other services available through our websites and their sub-domains.

We collect personal information related to the information or Services you wish to receive. The personal information we may collect may be different depending on whether you are a Visitor, Contractor or Client.

Visitors

We may collect identifying information, including your first name, last name, email address, phone number, company name, and/or project information if you inquire about our Services, download guides, request content, request email updates, or participate in a marketing promotion, contest, or event. We may collect information on your interaction with our Websites.

Employees and Contractors

If you are an Employee or Contractor and intend to sign a contract with us, we collect more personal information to enable us to provide additional Services, Products, and information. We may collect some or all of the following or similar information:

A. Identifying Information

• First and last name
• Contact information including email address, physical address, and telephone number
• Signature
• Date of birth
• Banking information
• Information required for benefits administration
• Social Security or Taxpayer Identification Number
• Photograph, video, or other digital media
• Driver's license number
• Passport number
• Other similar information

B. Categories of Personal Information protected by law

• Name
• Signature
• Social Security number
• Physical characteristics or description
• Address
• Telephone number
• Passport number
• Driver's license or state identification card number
• Insurance policy number
• Education
• Employment and employment history
• Bank account number
• Credit card number, debit card number, or any other financial information
• Medical information
• Health insurance information
• Information required for reporting to the Equal Employment Opportunity Commission (EEOC) or other government reporting including age, race, color, gender identity, disability status, veteran or military status, and salary information and/or other similar information
• Information required for us to provide or administer benefits which may include information about your marital status, dependent personal information, medical condition, or claim information or other similar information
• Demographic information you provide in response to surveys or questionnaires or otherwise provide us voluntarily, including but not limited to:
  o Age
  o Gender
  o Gender Identity
  o Ethnicity
  o National Origin
  o Minority and/or Women Owned Business Enterprise status
  o Disabled Veteran Owned Business Enterprise status
  o Socially/Economically Disadvantaged Owned Business Enterprise status
  o Languages you speak

C. Commercial Information

• Your preferences and interests
• Services purchased or considered, or service history
• Transactional information and other similar information

D. Biometric Information

• Fingerprints as required for federal security clearance
• Other similar information

E. Activity on our Websites

• Your interaction with our Websites (see "When you visit our Websites, we collect other information" below)

F. Geolocation data or other similar information

• Your interaction with our Websites (see "When you visit our Websites, we collect other information" below)
• Your location, where you live, where you are located and other similar information

G. Audio, electronic, visual, thermal, olfactory or similar information

• Telephone calls to customer service and similar staff may be recorded for training and quality assurance purposes
• Audio/visual monitoring of people entering our offices
• Audio/visual recordings of interviews during the employment application process

H. Professional or Employment Related Information or other similar information

• Information required for employment purposes, for example, evidence of your right to work
• Consumer reports
• Character, general reputation, and other similar information
• Information about your skills
• Information about your current employment and employment history
• Information related to your business or profession
• Client name(s)
• Other information requested by your client

I. Education Information

• Information relating to your education for employment or other similar information

Clients

We collect information related to our relationship with you. We collect identifying information, including your first name, last name, email address, telephone numbers, company name, physical address, information that you may require on invoices that are sent to you, and/or other similar information. We may also collect information on your interactions with us and/or with our Websites.

We collect personal information from you online, through email, through face to face interactions, over the phone directly from you, when you visit our Websites, when you use our Services, through technology, or from other sources.

You give us your information.

As a Visitor, you may browse our Websites to find out more about our Services. You are not required to give us any personal information to browse our Websites, though we may automatically collect information about you as described in this Privacy Policy (see "When you visit our Websites, we collect other information" below). You only provide information to us when you complete a form on our Websites.

If you intend to enroll with us and sign a General Service Agreement or Independent Contractor Agreement, we will collect and/or ask you for personal information so that we can provide Services to you. If you do not to provide us with personal information, we will not be able to provide you these Services.

You may give us personal information if you respond to a voluntary survey or questionnaire.

We may also collect your personal information if you send us something through electronic or physical mail or if you call us. Your telephone calls to us may be recorded for training and quality control purposes.

When you visit our Websites, we collect other information.

When you use our Websites, our systems automatically gather information that allows us to communicate with your computer or device during the visit. We also may collect information related to any of the following: the number of visits to our Websites, which parts of our Websites you use, your IP address (the Internet address assigned to your computer or device from your Internet Service Provider), domain type, browser type (e.g., Safari or Internet Explorer), the operating system you use (e.g., Windows, iOS or Android), the actions you perform, your location, and the date and time of day. We use this information for statistical purposes to help us design and improve our Websites and Services.

Cookies: Our Websites use cookies, small text files containing a string of alphanumeric characters known as a cookie. When you visit our Websites, our servers may send a cookie to your computer. We may use session cookies and persistent cookies. Session cookies exist only during one session. They disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. We use cookies to enable you to navigate our Websites and use their features, such as accessing secure areas of our Websites. Because required cookies are essential to operate our Websites, there is no option to opt-out of these cookies. Other cookies, such as performance, analytics, and marketing cookies are optional, and you can disable optional cookies through your browser settings and other related functionalities we may make available on our Websites, but please note that disabling cookies may impact some of our Website features and prevent them from operating properly.

We may use or engage a third party that uses Local Stored Objects (LSOs), sometimes referred to as "Flash Cookies", and other technologies to collect and store information about your use of our Websites. A flash cookie is a small data file placed on your device using Adobe Flash technology. Flash cookies are different from the cookies described above because cookie management tools provided in your browser will not remove them. To limit the websites that can store information in flash cookies on your device, please visit the Adobe at: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

For more information about the cookies, web beacons and other related technologies used on our Websites, please review our Cookie Policy, available at Cookies Policy

Log Files: Our servers automatically record certain information (e.g., web request, Internet Protocol ("IP") address, browser type, browser language, URLs, etc.) that your web browser sends whenever you visit our Websites.

Web Beacons: We may employ web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) to track how you use the Websites. We may also use web beacons in our emails to track which emails are opened and which links you click.

Analytics. We may use data analysis tools to help us better serve our Visitors, Contractors, and Clients via improved content, user experience, products, services, and revisions to our Services. This collected information may let us know which content, resources, and linked content you are accessing and viewing within the Websites, as well as device type and hardware features, location, and language settings.

Google Analytics™. We use Google Analytics to help analyze how users interact with our Websites. Google Analytics places a small cookie file on your computer or device, so it recognizes if you visit in the future. This cookie does not collect personal identifying information; it collects standard Internet log information and site visitor behavior information in an anonymous form.

We have implemented and use features of Google Analytics for display advertisers (e.g., remarketing), which includes obtaining specific Visitor cookie data, such as the source, medium, and keyword(s) used to visit our Websites. Under the Google remarketing program, our ads can be shown to you when you visit other websites in the Google Display Network or when you search on Google using certain keywords. We use first-party cookies (such as the Google Analytics cookie) and other information together to inform, optimize, and provide ads based on your past visits to our Websites. We may use remarketing with Google Analytics to display content-specific advertisements to you if you have previously visited our Websites and then go to other websites that have the Google Display Network implemented.

Google Analytics does not collect personal information through its cookie and does not combine, match, or cross-reference our information with any other information. Please review the Google Analytics privacy policy for additional information.

Visitors who wish to disable this web measurement tool will still have full access to our Websites. While the details vary from browser to browser, most modern browsers can be set up to accept, reject, or request user intervention when a site asks to set a cookie. Google Analytics uses a cookie that begins with _utm. If you would like to opt out, you may use this browser add-on.

Mobile Devices: If you use any location-enabled features of our Services, you may be sending us location information. We do not store or use this information other than to provide the Services you requested. Location-enabled features are opt-in on your mobile device. You can have control over your participation and can turn these services off at any time.

Web-enabled mobile applications may use cookies, web beacons, or other methods to customize your browsing experience.

We collect personal information from other sources.

We may collect personal information about you from other sources such as consumer reports, as part of our onboarding process, for processing unemployment or workers' compensation claims, or to process requests for security clearances. For example, a Client or other individual may refer you to us and send us your name, contact information, and/or other information.

We use your personal information to provide and improve our Services and to operate and improve our Websites.

We use your Personal Information to provide our Services to you, process your transactions, or respond to your requests. More specifically, we use your personal information and other information we collect to:

• Create, maintain, customize, and secure your account with us
• Personalize your experience with us
• Communicate with you
• Obtain consumer reports
• Identify you, or validate or verify your identity
• Provide Services, support, and benefits
• Process your requests or transactions
• Provide customer service and respond to your inquiries
• Provide promotional offers
• Provide information updates
• Manage your preferences
• Conduct internal recordkeeping
• Develop and modify our Websites and Services
• Improve our processes through research and analysis
• Help maintain the safety, security and integrity of our Websites and Services and prevent fraud
• Respond to law enforcement requests or as required by law, court order or government regulations
• To evaluate or conduct a merger, restructuring, reorganization, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred
• We use your personal information to provide the Services for which you provided it.

We may also aggregate and/or de-identify personal information so that it does not identify you and use it for statistical, analytical, or other purposes not prohibited by law.

At any time, you can opt-out of receiving marketing and informational email communications from us by clicking on the "unsubscribe" link in our emails.

We use your personal information for business purposes and our legitimate interests

We use personal information for certain legitimate business purposes, including:

• Enhancing, modifying, personalizing, or otherwise improving our Services, your experience on our Websites, and related communications for your benefit
• Identifying you, or validating or verifying your identity, and preventing fraud
• Enhancing the security of our network and information systems
• Better understanding how people interact with our Websites
• Providing communications we think will be of interest to you
• Determining the effectiveness of promotional campaigns and advertising
• Maintaining accurate financial records

We share or disclose personal information with third parties to help us provide Services to you.

We may share your personal information with our affiliates and subsidiaries as well as other third parties to help us provide Services to you or comply with legal obligations. For example, we may contract with a third-party provider to administer health, welfare, or retirement benefits for you. We share personal information with third parties to:

• Conduct our business operations
• Provide health, welfare, retirement, or other benefits to you
• Identify you, or validate or verify your identity
• Make payments to you
• Comply with legal obligations (for example, we report taxable income to the appropriate government agencies)
• Communicate with you (for example, send you information that may be useful)
• Manage market research and promotions
• Mail you information (for example, to deliver copies of materials you request)
• Invoice your clients for your services
• Comply with your requests to share your information with specific third parties

We provide these third parties with only the information they need to perform their services and work closely with them to ensure that your privacy and confidentiality are respected and protected. These companies are prohibited from using this information for their own marketing purposes or from sharing your personal information with other third parties except as necessary to provide Services to you or to fulfill their legal obligations.

We may share your personal information with your Client if you respond to a survey after you have provided services to the Client.

We may conduct a voluntary survey of Employees and Contractors who have provided services to one or more Clients. The survey may ask you for demographic information including but not limited to:

• Age
• Gender or Gender Identity
• Ethnicity
• National Origin
• Minority and/or Women Owned Business Enterprise status
• Disabled Veteran Owned Business Enterprise status
• Socially/Economically Disadvantaged Owned Business Enterprise status

Some Clients are exploring the diversity of their networks and request that we provide them with information about Employees and Contractors who have provided services to them. Your participation in these surveys is voluntary and no adverse action will be taken against anyone who does not respond to a survey. We share information with Clients to:

• Provide them information relating to diversity and inclusion
• Provide them relevant information relating to Minority, Women, Disabled Veteran, and/or Socially/Economically Disadvantaged Owned Businesses Enterprises
• Assist you in obtaining, managing, or learning about certifications

We may also share or disclose aggregated and/or de-identified information with third parties for statistical, analytical purposes, or other legitimate business purposes not prohibited by applicable law.

We will disclose your personal information if we are required to by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to:

• Investigate suspected or actual fraud or illegal activities, or assist government enforcement agencies or companies assisting in fraud protection or investigation
• Identify you, or validate or verify your identity
• Enforce our agreement with you
• Investigate or defend ourselves against any claims or allegations, or to avoid criminal or civil liability
• Protect the security or integrity of our Websites and Services
• Exercise or protect the rights or personal safety of MBO, our employees, the public, or others

Your and others' personal information may be disclosed or transferred as part of, or during negotiations of, any merger or sale of our assets or the acquisition of MBO.

We share your personal information with third parties who are looking for Employees and Contractors if you register with MBO's marketplace to look for work opportunities.

By registering with MBO's marketplace to look for work opportunities, you are directing us to share your personal information with companies who are looking for Employees and Contractors. You are using MBO's marketplace to intentionally interact with third parties, particularly companies who are looking to hire Employees or engage with Contractors.

We may use and share your personal information for advertising purposes.

From time-to-time, we engage advertising services to assist us in advertising our Services based upon your interests and in order to display content that is relevant to you ("Interest Based Advertising"). Those services may target advertisements on our Websites as well as third party websites based on cookies or other information indicating previous interaction with our Websites. These third parties may collect information collected about you across different websites and online services. These third party advertisers may be participants in the Network Advertising Initiative and/or the Digital Advertising Alliance, which allow users to opt-out of ad targeting from participating organizations. To learn more about interest-based advertising, or to opt-out of having your information used by certain third parties for behavioral advertising purposes, go to www.aboutads.info/choices or www.networkadvertising.org/choices/.

We do not sell, trade, or rent your personal information to any unaffiliated third parties for any monetary compensation.

We employ physical, administrative, and technical security measures to protect your personal information from loss, misuse, or alteration while it is under our control. We require that any third parties to whom we may transfer your personal information take comparable steps to protect that security. Unfortunately, no security measures are 100% secure and we cannot guarantee or warrant the absolute security of your personal information.

The safety and security of your personal information also depends on you. You are responsible for keeping confidential passwords we have given you (or you have chosen) for access to certain parts of our Websites and Services. You should never share your login username, password, or other account information with others, and you should always log out when finished using our Websites or Services.

You are responsible for notifying us immediately if you suspect there has been any breach or unauthorized use of your login credentials or if you suspect there has been an authorized disclosure of your personal information. You must also inform us immediately if you believe your private login information has been compromised. We are not responsible if you allow third parties access to your account.

Email is not a secure form of communication. Do not send us your credit card number, Social Security number, passwords or any other sensitive personal information via email.

Our Websites and email communications may contain links to other websites on the Internet that are owned and operated by third parties. Other websites may also link to our Websites.

We are not responsible for the content or privacy policies of websites to which our Websites link. In addition, the information practices of websites that link to our Websites are not covered by this Privacy Policy. We encourage you to review the privacy policies of other websites.

Third parties may collect information about you across different websites, including our Website. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. To the extent you employ such browser do-not-track signals or other similar mechanisms, we will use commercially reasonable efforts to honor such requests received by us to the extent we have the capacity and resources to identify and process your request. Due to the potential for rapid and diverse developments of technology in this area, we cannot guarantee that we can process every type of request that exists or may be developed in the future. As noted above, third parties, such as those that conduct Interest Based Advertising, may collect data that relates to you. We cannot control third parties' responses to do-not-track signals or other such mechanisms. Third parties' use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

We reserve the right to retain any information as long as it is needed to fulfill the purposes for which we collected the information, including for the purposes of satisfying any legal, accounting or reporting requirements.

We are an international company and the personal information we collect may be stored and processed in any country in which we or our affiliates, suppliers, service providers and/or agents maintain facilities, including, but not limited to, the United States of America and the European Union.

Our Websites and Services are not intended for anyone under 16 years of age. We do not knowingly collect or allow the collection of personal information in connection with our Websites or Services from anyone under the age of 16. If we learn that we have collected the personal information of anyone under the age of 16, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 16 and discover that your child has submitted personal information to us, you may contact us using the mailing address or phone number provided in the Contact Us section below or submit your request to remove your child's personal information from our systems by completing the Individual Data Request Form.

We offer several choices to you to allow you to control how we use your personal information.

1. Opt out of marketing communications. You may opt out of marketing email communications at any time by clicking the "Unsubscribe" link at the bottom of the email. You may opt out of physical mail communications by contacting us at the addresses provided in the Contact Us section below. Your opt-out request will be processed promptly, though this process may take several days. During that processing period, you may receive additional emails or physical mail from us. Please note, opting out of marketing communications will only apply to marketing and other promotional communications and will not apply to any other communications, email or otherwise, sent for non-marketing purposes, including, but not limited to, emails and communications about Services you receive.
2. Make corrections. If you want to update any of your personal information, update your preferences, control communications we send or otherwise contact us about your personal information, please submit your request by completing the Individual Data Request Form.
3. Targeted Advertising. If you do not want us to use your personal information to deliver advertisements according to our third party marketing partners' target audience preferences, you can opt-out submitting your request using the Individual Data Request Form.  As noted above, we do not control third parties' collection or use of your personal information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your personal information used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative on their website, located at www.networkadvertising.org, and from members of the Digital Advertising Alliance on their website, located at www.aboutads.info.

Please contact us if you have any questions about this Privacy Policy.

Write to us at:

MBO Partners
Attn: Privacy Officer
20405 Exchange Street Suite 301
Ashburn, VA 20147 USA

Call us at: 1-800-220-0469

Or for requests related to the management of your personal information, we strongly recommend you complete the Individual Data Request Form. However, you may also conatct us using the additional methods provided.

For all contact methods, please include your full name, address, telephone number, and email address in case we have any questions.

We will confirm your identity before we disclose personal information to you.

Before disclosing any personal information to you, we will authenticate your identity. If we cannot authenticate your identity, we will err on the side of protecting your personal information. We will inform you in writing of our decision.

We may update this Privacy Policy from time to time. When we do update it, we will post a notice on our Websites, make the updated policy available on this page, and indicate the date it was last updated below. Please check back periodically to see if our Privacy Policy has been updated.

Your continued use of the Websites or Services constitutes your continued acknowledgement that you understand that we may continue to use your personal information as described in this Privacy Policy.

If you have questions or comments regarding this Privacy Policy, please contact us using the mailing address or phone number provided in the Contact Us section, or submit a request by completing the Individual Data Request Form.