California Consumer Privacy Act (CCPA) Notice at Collection for California Residents

The California Consumer Privacy Act (“CCPA”) requires MBO Partners to notify you of the personal information we collect at or before the time personal information is collected including the categories of personal information collected and the purposes for which these categories of personal information will be used. Therefore, this webpage and the section below outline this information. This information is in addition to the terms outlined in our Privacy Policy.

Last Updated:  December 5, 2023

Additional Privacy Terms if You are a California Resident

Last Updated:  December 5, 2023

If you are a California resident, you have certain rights with respect to your personal information in addition to those described in the Privacy Policy. The following is a summary of those rights and additional information applicable to our collection and use of your personal information. For clarity, these Additional Privacy Terms if You are a California Resident are in addition to, and not in lieu of, the information provided in our Privacy Policy. Please note, if you are not a California resident, the rights described in this section do not apply to you. These rights were established, in part, by the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

If you would like to request that we do not sell or share your personal information for cross-context behavioral advertising, please click here Do Not Sell or Share My Personal Information and follow the instructions.

Summary of Our Collection of Your Personal Information

We only use your personal information for the purposes for which it was collected – in most cases this means providing Services to you.

We do not sell your personal information. If your choices for cookies permit, we may share your personal information for cross-context behavioral advertising. Otherwise, we do not share your personal information for cross-context behavioral advertising. You can set your cookie preferences by clicking on Cookie Preferences at the bottom of the page.

We disclose your personal information to suppliers and service providers such as firms that provide us with technology or other services. We have agreements with these service providers that protect your personal information and limit their ability to use personal information only for the purposes of the agreement.

The following is a summary of the categories of personal information that we collect, the purposes for which we collect your personal information, and whether we sell your personal information or share your personal information for cross-context behavioral advertising. As detailed below, the personal information we may collect may be different depending on whether you are a Visitor, Employee, Contractor, or Client. Generally, categories of personal information collected about Employees and Contractors also apply to potential Employees and Contractors (i.e., applicants).

 

Categories of Information About Whom We collect this Information Purposes for which Personal Information is Collected Whether the Personal Information is Sold or Shared The length of time we intend to retain personal information
Identifying Information - such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
  • Visitors
  • Employees and Contractors
  • Clients
  • Manage and maintain our relationship with you
  • Personalize Services to you
  • Improve our Services
  • Comply with legal obligations
  • Prevent, detect, or investigate fraud or security breaches
MBO does not sell identifying information. Except for information permitted to be shared through your cookie preferences, we do not share identifying information with any third parties for cross-context behavioral advertising. Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Protected Characteristics and similar Information Protected by Law
  • Employees and Contractors
  • Comply with legal obligations
  • Offer opportunities to you
  • With your permission, share with your clients
We do not sell protected characteristics and we do not share protected characteristics with any third parties for cross-context behavioral advertising. Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Commercial Information
  • Visitors
  • Employees and Contractors
  • Clients
  • Personalize Services to you
  • Improve your experience on our Websites
  • Comply with legal obligations
We do not share you’re your commercial information and do not share commercial information with any third parties for cross-context behavioral advertising. Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Biometric Information
  • Employees and Contractors
  • To comply with legal requirements
  • To comply with requirements for security clearance
  • Prevent, detect or investigate fraud or security breaches
We do not sell biometric information and do not share biometric information with any third parties for cross-context behavioral advertising Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Activity on our Websites
  • Visitors
  • Employees and Contractors
  • Clients
  • Personalize Services to you
  • Improve your experience on our Websites
  • Prevent, detect, or investigate fraud or security breaches
We do not sell information about your activity on our Websites. Except for information permitted to be shared through your cookie preferences, we do not share information about your activity on our Websites with any third parties for cross-context behavioral advertising. Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Geolocation data
  • Visitors
  • Employees and Contractors
  • Clients
  • Personalize Services to you
  • Improve your experience on our Websites
  • Prevent, detect, or investigate fraud or security breaches
We do not sell geolocation data information. Except for information permitted to be shared through your cookie preferences, we do not share information about your activity on our Websites with any third parties for cross-context behavioral advertising. Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Sensory Data including audio, electronic, visual, thermal, olfactory or similar information
  • Visitors
  • Employees and Contractors
  • Clients
  • For quality control and training purposes, telephone calls to customer support staff may be recorded
  • For security purposes, if you visit our offices, your image may be recorded by our security cameras.
We do not sell sensory data and do not share sensory data with any third parties for cross-context behavioral advertising Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Professional or Employment Related Information
  • Employees and Contractors
  • Provide Services to you.
  • Verify your qualifications for employment or engagement opportunities
  • Provide opportunities for you to be employed or engage with clients
We do not sell professional or employment related information and do not share professional or employment related data with any third parties for cross-context behavioral advertising Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Education Information
  • Employees and Contractors
  • Personalize Services to you
  • Verify your qualifications for employment or engagement opportunities
  • Provide opportunities for you to be employed or engage with clients
We do not sell education information and do not share education information data with any third parties for cross-context behavioral advertising Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Profile Information including inferences drawn from information to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  •  Employees and Contractors
  • Personalize Services to you
We do not sell Profile Information and do not share Profile Information with any third parties for cross-context behavioral advertising Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Sensitive Information – such as (A) social security, driver’s license, state identification card, or passport number.

(B) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

(C) precise geolocation.

(D) origin, religious or philosophical beliefs, or union membership.

(E) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

(F) A consumer’s genetic data.

  • Employees and Contractors
  • To provide Services to you
  • Comply with legal obligations
  • Prevent, detect, or investigate fraud or security breaches
Except as required by law or with your express consent, we do not disclose Sensitive Information to third parties, do not sell Sensitive Information, and do not share Sensitive Information with any third parties for cross-context behavioral advertising. Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.

 

Summary of Uses and Disclosures of Personal Information

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 and the purpose for sharing the information with third parties.

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

Categories of personal information collected Information is collected about Sources from which the personal information is collected Business purpose for collecting personal information Categories of third parties to whom the information was disclosed Business purpose for disclosing personal information to third parties
Identifying Information such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.  
  • Visitors
  • Employees and Contractors
  • Clients
  • You
  • A person or entity who referred you to us
  • LinkedIn profile or other similar online profile
  • Manage and maintain our relationship with you
  •  Personalize Services to you
  • Provide customer service
  • Maintain and secure your account with us
  • Comply with legal obligations
  • Prevent, detect, or investigate fraud or security breaches
  • Vendors that provide marketing and communication services
  • Technology service providers
  • Service providers
  • Government or law enforcement agencies
  • Manage and maintain our relationship with you
  • Personalize Services to you
  • Provide customer service
  • Maintain and secure your account with us
  • Comply with legal obligations
  • Prevent, detect, or investigate fraud or security breaches
  • Provide opportunities to you
  • Employees and Contractors
  • You
  • LinkedIn profile or other similar online profile
  • Identify you, or validate or verify your identity
Companies with employment or engagement opportunities
  • Identify you, or validate or verify your identity
  •  Employees and Contractors
  • You
  • Comply with legal requirements
Government agencies
  • Comply with legal requirements
  • Employees and Contractors
  • Employees and Contractors Consumer Reporting Agencies
  • Pre-engagement screenings
  • Obtain a consumer report
  • Companies with engagement or employment opportunities for you
  • Pre-engagement screenings
  • Obtain a consumer report
  •  Employees and Contractors
  • You
  • Make payments to you
Banks and other financial institutions
  • Make payments to you
Protected Characteristics – Characteristics and similar Information Protected by Law
  • Employees and Contractors
  • You
  • Comply with legal requirements
  • Provide benefits to you
  • Government agencies
  • Benefit providers
  • With your permission, your clients
  • Comply with legal requirements
  • Provide benefits to you
Commercial Information
  • Visitors
  •  Employees and Contractors
  • Clients
  • You, Cookies
  • Improve your experience on our Websites
  • Personalize Services to you
  • Technology service providers
  • Service providers
  • Improve your experience on our Websites
  • Personalize Services to you
Biometric Information
  • Employees and Contractors
  • You
  • To comply legal requirements for security clearances
  • If you visit our offices, to protect the security of our premises with security cameras
  • Technology service providers
  • Service providers
  • Government agencies as required
  • To comply legal requirements for security clearances
  • If you visit our offices, to protect the security of our premises with security cameras
Activity on our Websites
  • Visitors
  • Employees and Contractors
  • Clients
  • You, Cookies
  • Personalize Services to you
  • Manage your preferences
  • Prevent, detect, or investigate fraud or security breaches
  • Technology service providers
  • Service providers
  • Personalize Services to you
  • Manage your preferences
  • Prevent, detect, or investigate fraud or security breaches
Geolocation data
  • Visitors
  •  Employees and Contractors
  • Clients
  • You, Cookies
  • Personalize Services to you
  • Improve our processes
  • Prevent, detect, or investigate fraud or security breaches
  • none
none
Sensory Data including audio, electronic, visual, thermal, olfactory or similar information
  • Visitors
  •  Employees and Contractors
  • Clients
  • You
  • For quality control and training purposes, telephone calls to customer support staff may be recorded
Technology service providers
  • For quality control and training purposes, telephone calls to customer support staff may be recorded
Individuals who visit our offices Individuals who visit our offices
  • Audio/video monitoring of individuals who enter our offices
None None
Professional or Employment Related Information
  •  Employees and Contractors
  • You
  • Verify your qualifications for employment or engagement opportunities
  • Provide opportunities for you
  • Personalize Services to you
  • Companies with engagement or employment opportunities for you
  • Technology providers
  • Service providers
  • Verify your qualifications for employment or engagement opportunities
  • Provide opportunities for you
  • Personalize Services to you
  • Employees and Contractors
  • Consumer Reporting Agencies
  • Pre-engagement screening
  • Obtain a consumer report
  • Companies with engagement or employment opportunities for you
  • Pre-engagement screening
  • Obtain a consumer report
Education Information
  •  Employees and Contractors
  • You, Education institutions
  • Verify your qualifications for opportunities
  • Provide opportunities for you to be employed or engage with clients
  • Companies with engagement or employment opportunities for you
  • Technology service providers
  • Service providers
  • Verify qualifications for opportunities
  • Provide opportunities for you to be employed or engage with clients
Sensitive Information – such as (A) social security, driver’s license, state identification card, or passport number.

(B) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

(C) precise geolocation.

(D) origin, religious or philosophical beliefs, or union membership.

(E) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

(F) A consumer’s genetic data.

  •  Employees and Contractors
  • You
  • To provide Services to you
  • Comply with legal obligations
  • Prevent, detect, or investigate fraud or security breaches
  • Government agencies
  • Technology service providers
  • Service providers
  • To provide Services to you
  • Comply with legal obligations
  • Prevent, detect, or investigate fraud or security breaches

 

We do not use or disclose sensitive personal information for purposes other than those specified in section 7027, subsection (m) of the regulations implementing the California Consumer Privacy Act.

Categories of personal information that we have sold or shared with third parties in the preceding 12 months

We do not sell your personal information or share it for cross-context behavioral advertising. If your choices for cookies permitted, the personal information that can be obtained by the use of cookies may have been shared with a third party for cross-context behavioral advertising. Otherwise, we did not share your personal information for cross-context behavioral advertising. You can set your cookie preferences by clicking on Cookie Preferences at the bottom of the page.

Consumers Under 16 years of Age

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 submit your request to remove your child's personal information from our systems by completing the Individual Data Request Form or by using the mailing address or phone number provided below.

California's Shine the Light Law

Under California's Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set in this Privacy Policy.  Under California's Shine the Light Law, you have the right to send us a request at the designated email address listed in the ‘Contact Us’ section below to receive the following information:

  • The categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
  • the names and addresses of the third parties that received the information; and
  • if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized form that is not specific to you. The designated method for submitting these requests is by completing the Individual Data Request Form.

California Consumer Privacy Act

Under the California Consumer Privacy Act ("CCPA"), California residents have certain rights regarding the personal information businesses collect about them. This includes the rights to know of a business's collection, use and disclosure of personal information, to request access to personal information, request deletion of personal information, and to direct a business to stop selling personal information.

RIGHT TO KNOW

You have the right to know and access:

  • the specific pieces of personal information that we collected about you
  • the business purpose for which we collect your personal information, and the business purposes for which we disclose, sell, or share your personal information
  • the categories of personal information that we collect, the categories of the sources from which we have obtained your personal information, and the categories of third parties to which we disclose, sell or share your personal information.

Please see the Summary of Our Collection of Your Personal Information section above.

RIGHT TO CORRECT

You have the right to have us correct inaccurate personal information held about you.

RIGHT TO DELETION

You have the right to have us delete your personal information, subject to certain exceptions.

RIGHT TO OPT-OUT

You have the right to opt-out of the sale or sharing of your personal information to third parties.

Please note, except for the information permitted to be transferred by your cookie preferences, we do not sell your personal information or share it with any third parties for cross-context behavioral advertising. In addition, we share your information as permitted by you when additional consent is appropriate or only as described in our Privacy Policy.

RIGHT TO LIMIT USE AND DISCLOSURE

You have the right to limit the use and disclosure of your sensitive personal information, subject to certain limitations.

Please note, we disclose your sensitive information only as required to enable us to provide our Services to you and only as described in our Privacy Policy.

RIGHT TO NON-DISCRIMINATORY TREATMENT We will not discriminate or retaliate against you for exercising any privacy right. We will not deny services, charge different prices or rates, provide you with a different level of quality of services, or engage in any other form of discrimination.

HOW YOU CAN EXERCISE YOUR RIGHTS

If you would like to exercise any of your privacy rights or would like your authorized agent to make a request to exercise your privacy rights on your behalf, please use one of the following methods:

We will promptly take steps to verify the request by contacting you and determining if your request is a verifiable consumer request. If your request is verified, we will disclose and deliver any required information or a response within 45 days of receiving your request.

Request by Authorized Agent

An authorized agent can make a request on your behalf by writing directly to us at the address below and providing evidence of your authorization or by submitting a Individual Data Request Form and providing information about your authorization in the comments section. We may require the authorized agent to provide proof that you gave the authorized agent signed permission to submit the request;  require you to verify your own identity directly’ or directly confirm with us that you provided the authorized agent permission to submit the request.

CONTACT US

If you have questions, wish to exercise your rights under this Privacy Policy, or need to contact us for another reason, you may:

Write to us at:

MBO Partners, Inc.
Attn: Privacy Officer
20370 Exchange Street Suite 250
Ashburn, VA 20147 USA

Call us at: 1-800-220-0469

We recommend you complete and submit the Individual Data Request Form or the Do Not Sell or Share My Personal Information form to expediate your request. However, you may also contact us using any method 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.

Changes to Additional Privacy Terms If You are a California Resident

We may update the Additional Privacy Terms if You are a California Resident from time to time. When we do update them, we will post a notice on our Websites and Products, make the updated version of these Additional Privacy Terms if You are a California Resident available on this page, and indicate the date it was last updated above. For clarity, any updates will apply from the date they are posted. Please check back periodically to see if these Additional Privacy Terms if You are a California Resident have been updated.