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 right to privacy. We share or disclose your personal information in the circumstances described in this policy, or with additional consent from you.

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, background 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 these Services, 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 this Website and sharing your information with us, you agree to and accept the privacy practices described in this Privacy Policy.

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. If our contract with a Contractor is different from this Privacy Policy, we will comply with the terms of the contract.

Employees are individuals employed by MBO and includes applicants who seek to be employees of MBO.

Clients

Clients are the organizations for which our Contractors perform their services. Often, MBO performs additional services for Clients that help them with their relationships with Contractors.

Services

We help our Contractors by processing invoices and payroll, administering payroll taxes and benefits, giving access to various helpful tools (our Products, as defined below), 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. For Visitors, we provide educational materials, information on products, invitations to events, and opportunities to speak to a staff member.

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.

In this Privacy Policy, all these services are collectively referred to as Services.

Products

Our Products include our business management software, mobile applications, a marketplace for independent projects, and other related tools (collectively, our “Products”).

Websites

When we talk about our Websites (collectively, our “Websites”), we are referring to websites owned and operated by MBO Partners, which include mbopartners.com.

We collect personal information related to the information, Services, or Products 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 Products or 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:

A. Identifying Information

• First and last name
• Email address, physical address, and telephone number
• 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

B. Categories of Personal Information described in California law section 1798.80(e)

• 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

C. Information Protected by Law

• Information required for reporting to the Equal Employment Opportunity Commission (EEOC) or other government reporting including age, race, color, sex, disability status, veteran or military status, and salary 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
• 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

D. Commercial Information

• Your preferences and interests
• Products or Services purchased or considered, or service history

E. Biometric Information

• Fingerprints as required for federal security clearance

F. Activity on our Websites

• Your interaction with our Websites or Products (see “When you visit our Websites, we collect other information” below)

G. Geolocation data

• Your interaction with our Websites or Products (see “When you visit our Websites, we collect other information” below)

H. 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

I. Professional or Employment Related Information

• Information required for employment purposes, for example, evidence of your right to work
• Components of pre-engagement screening including background checks and credit checks
• 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

J. Education Information

• Information relating to your education for employment or similar purposes

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, and other information that you may require on invoices that are sent to you. We may also collect information on your interaction 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, 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. 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 the 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 or Products, our systems automatically gather information that allows us to communicate with your computer or device during the visit. We also may use any of the following information: the number of visits to our Websites or Products, which parts of our Websites or Products 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), application type (e.g., 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, Products, and Services.

Cookies: When you use our Websites and Products, your browser stores small text files containing a string of alphanumeric characters known as a cookie. We use session cookies and persistent cookies. If you have chosen to identify yourself on our Websites or Products, we use session cookies containing encrypted information to identify you and facilitate your use of the Websites or Products. Session cookies are required to access much of the content and functionality offered on our Websites or Products. After you leave our Websites or Products and close your browser, a persistent cookie remains. Persistent cookies can be removed by following your help file instructions in your web browser. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Websites or Products, and some features of the Websites or Products may not function properly.

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 or Products.

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 or Products. 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 or Products, 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 products, 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 for pre-engagement screening, as part of our onboarding process, for processing unemployment or Workers’ Compensation claims, or to process requests for security clearances. For example, a Client may refer you to us and send us your name and contact information or we may collect personal information when administering a background check.

We use your personal information to provide our Products and Services

We use your Personal Information to provide our Products and 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
• Conduct pre-engagement screenings
• 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, Products and Services
• Improve our processes through research and analysis
• Help maintain the safety, security and integrity of our Websites, Products 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 Products and 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 Products, 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 third parties to help us provide Products or 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 background or other pre-engagement screening activities
• 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 Products 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 your 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.

The following is a summary of the categories of personal information we collect, whether we collect the information about Visitors, Employees and Contractors, and/or Client, the purposes for which we collect the information, and the categories of third parties with whom we share personal information.

This is a summary of the categories of personal information we have collected and shared in the preceding 12 months.

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

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 warranty 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 Products. You should never share your login username, password, or other account information with others, and you should always log out when finished using the Products.

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.

Social Security Number Policy

We classify Social Security numbers as “Confidential Information” under our Personally Identifiable Information (PII) Security Policy. Accordingly, Social Security numbers may only be accessed by and disclosed when there is a legitimate business need to know in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to physical, electronic, and administrative safeguards, and must be stored, transmitted, and disposed of in accordance with the provisions of our Personally Identifiable Information (PII) Security Policy applicable to Confidential Information. These restrictions apply to all Social Security numbers collected or retained in connection with customer, employee, or other relationships.

Our Services, 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 Products or Websites.

We are not responsible for the content or privacy policies of websites to which our Websites or Products link. In addition, the information practices of websites that link to our Websites or Products 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. We currently utilize the capability to respond to web browsers’ “do not track” signals or other mechanisms that enable you to exercise choice regarding the collection of this information.

Visitors

We keep your personal information for no longer than five (5) years. We may keep your personal information longer to comply with legal obligations, resolve disputes, maintain security, prevent fraud or abuse, or fulfill your request to “unsubscribe” from further messages from us.

Employees and Contractors 

In general, we keep your personal information for as long as necessary to provide Services to you or your clients. We will keep your personal information as long as you have a General Service Agreement or Independent Contractor Agreement with us, or:

• As required by our contract with a client to whom you provided services,
• For six (6) years after your agreement with us ends, or
• As required by law,

whichever is longer.

We keep your personal information after your agreement ends to comply with legal or contractual obligations, resolve disputes, respond to inquiries or claims, maintain security, or prevent fraud and abuse. For example, we will keep your personal information longer if the contract with one of your clients requires us to do so.

We will also keep a small amount of your personal information that is incorporated in our financial records (such as invoicing to your client) until our financial records for that period are destroyed.

Your General Service Agreement or Independent Contractor Agreement typically extends beyond individual assignments and can be terminated by you at any time by providing us with written notice. Until you end your agreement, we keep your personal information so that we may provide Services to you even if you only work with us intermittently. If you wish to end your agreement with us, please contact us at the address below (see Contact Us).

Before your agreement ends, we may securely dispose of some of your personal information to protect you, your personal information, or us from security threats or fraud, or to comply with laws that apply to us or our Services.

Clients

We will keep your personal information for as long as

• required by our contract with you,
• for six (6) years after your contract with us ends, or
• as required by law,

whichever is longer. In addition, we may keep a limited amount of personal information that is stored as part of the invoicing process until we destroy the invoice records for the period of the invoice, in accordance with our policy for destroying our financial records.

We respect your privacy and your rights. Your rights include the right to:

1. Be informed. You have the right to know how and why we collect and use your personal information. You have the right to know
   • the categories of personal information that we collect,
   • the sources of the information,
   • the purposes for collecting the information,
   • the categories of third parties with whom we share the information, and
   • the disclosures we make for business purposes and the categories of personal information
2. Opt out of marketing communications. You may opt out of marketing or informational 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.
3. Access your personal information. You have the right to access your personal information at any time by contacting us. You have the right to know the specific pieces of personal information that we collected about you.
4. Make corrections. You have the right to correct any inaccurate personal information that we have by contacting us.
5. Withdraw your consent. You have the right to withdraw your consent to processing your personal information by contacting us.
6. Object. You have the right to object to our processing of your personal information when we are processing it based on our legitimate interest where our legitimate interests are overridden by your data subject rights by contacting us.
7. Delete your personal information. You have the right to have your personal information deleted but it may be limited by legal or contractual obligations.
8. Restrict the processing of your personal information. You have the right to restrict the processing of your personal information:
   • when you are contesting the accuracy of it;
   • when the processing is unlawful instead of having it be deleted;
   • when your personal information is no longer needed for processing by us but you need it for legal reasons; or
   • when you are contesting the processing of your personal information for our legitimate interests.
9. Nondiscrimination. We will not discriminate against you because you have exercised any of these rights.

Please see Contact Us to contact us about any of your rights. We will verify that the request comes from you before responding.

In some limited circumstances, we may not be able to comply with your objection or request to delete your personal information because:

• we need to retain it to prevent fraud or abuse, detect security incidents, protect against illegal activities, or prosecute those responsible for illegal activities;
• we must comply with a legal or contractual obligation, or
• we need to exercise or defend a legal claim.

If we are not able to comply with your request, we will inform you in writing of our decision.

We comply with applicable data protection laws. If the General Data Protection Regulation (GDPR) applies, then we are the Controller, as defined in GDPR and we determine how we process the personal data collected on this Website.

Transfer of Data

Your information, including Personal Data, may be transferred to the United States and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it in the United States. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

You acknowledge and agree:

• that the information you submit to our Websites is being sent to the United States of America;
• that the European Commission has determined that United States laws do not provide an adequate level of protection for personal data;
• that other foreign data protection authorities have not determined that the United States laws provide an adequate level of protection for personal data; and
• to transfer your personal data to the United States to be used in accordance with this Privacy Policy.

California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please Contact Us.

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

Write to us at:

MBO Partners
Attn: Privacy Officer
13454 Sunrise Valley Dr. Suite 300
Herndon, Virginia 20171 USA

Call us at: 1-800-220-0469

Or send an email to: privacy@mbopartners.com

Please include your full name, address, telephone number, and email address in case we have any questions, and please let us know how you would like us to communicate with you (email or direct mail).

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 and Products, 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, Products, or Services constitutes your agreement to the terms of this Privacy Policy.

If you have questions or comments regarding this Privacy Policy, please contact privacy@mbopartners.com.

You and MBO agree to resolve all disputes in connection with this Privacy Policy pursuant to and in accordance with the Arbitration Agreement.