MCM-CRM Privacy Policy

MCM CRM LLC (referred to as “Company,” “us” or “we”) recognizes that your privacy is important.

This Policy discloses the privacy practices for MCM CRM’s website (the “Site”), as well as related
products and services we may offer to you (the “Service”). This Policy also covers how personal and
other information that we receive or collect about you and your clients (“Clients”) is treated. Please read
the information below to learn the following regarding your use of this Site.

We reserve the right to change this Privacy Policy from time to time. We will notify you about significant
changes in the way we treat personal information by sending a notice to the primary email address
specified in your account, by placing a prominent notice on our site, and by updating any privacy
information on this page. Your continued use of the Site and/or Services available through this Site after
such modifications will constitute your (a) acknowledgment of the modified Policy; and (b) your
agreement to abide and be bound by that Policy.


1. Types of Information We Collect
In order to better provide you with our Service, we collect two types of information about our users:
Personally Identifiable Information (“PII”) and Aggregate Information.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you
are. When you engage in certain activities on this Site, such as registering for an account, downloading
or purchasing a product or service, submitting content and/or posting content in a public forum on this
Site, or sending us feedback, we may ask you to provide certain information about yourself.

Examples of PII may include your first and last name, email address, mailing address (including zip
code), employer, job title and department, telephone and facsimile numbers, and other identifying information.
When ordering products or services on the Site, you may be asked to provide a credit card number.

Aggregate Information: This refers to information that does not by itself identify a specific individual.
We gather certain information about you based upon where you visit on our Site and what other sites
may have directed you to us. This information, which is collected in a variety of different ways, is
compiled and analyzed on both a personal and an aggregated basis. This information may include the
Website’s Uniform Resource Locator (“URL”) that points to the site you just came from, which URL you
go to after visiting our Site, what browser you are using, and your Internet Protocol (“IP”) address.

2. How We Collect and Use Information
MCM CRM do not collect any PII about you unless you voluntarily provide it to us. However, you may be
required to provide certain PII to us when you elect to use certain products or services available on the
Site. These may include: (a) registering for an account on our Site; (b) uploading individual transaction
data obtained from your thirdparty invoicing or accounting applications (for example, “QuickBooks,”
“Xero,” “Clio” etc.), (c) uploading user generated content and other information uploaded to the Site
(d)sending us an email message; (e) submitting a form or transmitting other information by telephone
or letter; or (e) submitting your credit card or other payment information when ordering and
purchasing products and services on our Site.

We will primarily use your PII to provide product or service offerings to you. We will also use certain
forms of PII to enhance the operation of our Site, improve our internal marketing and promotional
efforts, statistically analyze Site use, improve our product and service offerings, and customize our Site’s
content, layout, and services. We may use certain information about you without identifying you as an
individual to third parties. We do this for purposes such as analyzing how the Service is used, diagnosing
service or technical problems, maintaining security, and personalizing content. We may also use PII to
deliver information to you and to contact you regarding administrative notices. Finally, we may use your
PII to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Site
Terms of Use, and this Privacy Policy.
We may also collect or our third party advertising partners may collect, certain Aggregate Information.
For example, we may use your IP address to diagnose problems with our servers, software, to
administer our Site and to gather demographic information. Our third party advertising partners may
also provide us with aggregate, but not individual, reports that will tell us how many ads were presented
and clicked upon at out Site.

3. Cookies

Depending on how you use our Site, we will store cookies on your computer in order to collect certain
aggregate data about our users and to customize certain aspects of your specific user experience. A
cookie is a small data text file which is stored on your computer that uniquely identifies your browser.
Cookies may also include more personalized information, such as your IP address, browser type, the
server your computer is logged onto, the area code and zip code associated with your server, and your
first name to welcome you back to our Site. We may use cookies to perform tasks such as: monitoring
aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so),
storing account and advertising preferences that you have set, and personalizing the Services we make
available to you. However, we do not use cookies to track your browsing behaviors.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies
or to indicate when a cookie is being sent. However, some aspects of the Site may not function properly
if you elect to disable cookies.

4. Release of Information
MCM CRM will not sell, trade, or rent your PII to others. We do provide some of our product and service
offerings through contractual arrangements made with affiliates, service providers, partners and other
third parties (“Service Partners”). We and our Service Partners may need to use some PII in order to
perform tasks between our respective sites, or to deliver products or services to you. For example, we
must release your credit card information to the cardissuing bank to confirm payment for products and
services purchased on this Site; release your address information to the delivery service to deliver
products that you ordered; and provide order information to third parties that help us provide customer

We will encourage our Service Partners to adopt and promote strong privacy policies. However, the use
of your PII by our Service Partners is governed the respective privacy policies of those providers, and is
not subject to our control. Except as otherwise discussed in this Privacy Policy, this document only
addresses the use and disclosure of information we collect from you. Other Sites accessible through this
Site, including our Advertising and Service Partners, have their own privacy policies and data collection,
use and disclosure practices. Please consult each Site’s privacy policy. We are not responsible for the
policies or practices of third parties.

Occasionally we may be required by law enforcement or judicial authorities to provide PII to the
appropriate governmental authorities. In such cases, we will disclose PII upon receipt of a court order,

subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law

enforcement agencies in identifying those who use our services for illegal activities. We reserve the right
to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may also provide Aggregate Information about our customers’ sales, traffic patterns, and related Site
information to third party advertisers, but these statistics do not include any Personally Identifiable

5. Updating and Correcting Information
We believe you should have the ability to access and edit the PII that you have provided to us. You may
change any of your PII in your account online at any time by linking to your account in accordance with
instructions posted elsewhere on this Site.

We encourage you to promptly update your PII if it changes. You may ask to have the information on
your account deleted or removed; however, some information, such as past transactions, logs of
technical support calls, or other information may not be deleted. In addition, it may be impossible to
completely delete your information without some residual information because of backups.

6. User Choices on Collection and Use of Information
We may, from time to time, send you email regarding new products and services that we feel may
interest you. In addition, if you indicated upon registration that you are interested in receiving offers or
information from us and our partners, we may occasionally call or send you direct mail about products
and services that may be of interest to you. Only MCM CRM (or agents working on behalf of MCM CRM
and under confidentiality agreements) will send you these solicitations, and only if you have previously
indicated that you wish to receive them. If you do not want to receive solicitations from us, you can
“optout” by accessing your account online editing your account information to no longer receive such
offers and mailings.

You also have choices with respect to cookies, as described above. By modifying your browser
preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all
cookies. If you choose to reject all cookies some parts of our Site may not work properly in your case.

7. Security of Your PII

At our Site you can be assured that your PII is secure, consistent with current industry standards. We
strive to take appropriate security measures to protect against unauthorized access to or unauthorized
alteration, disclosure or destruction of your PII. For example:
• We work hard to ensure that the data we collect is reliable, accurate, complete and current. We encrypt
all PII, in order to prevent unauthorized parties from viewing such information when it is transmitted to
us. We also only keep collected information: only for as long as reasonably necessary and use it only for
the purposes for which it was collected or to comply with any applicable legal or ethical reporting or
document retention requirements.

• We limit access to PII only to specific employees, contractors and agents who have a reasonable need
to come into contact with your information. For example, we may provide members of our technical
support team with limited access to your account in order to allow them to troubleshoot problems you
may be having with the Site.

• Additionally, we also employ a number of physical, electronic, and procedural safeguards to protect
PII. Our secure servers and our data centers are protected by industrystandard encryption, and our
servers reside behind firewalls and employ highlevel password protection.

• Finally, access by you to your PII is available through a password and unique customer ID selected by
you. This password is encrypted. We recommend that you do not divulge your password to anyone.
In order to most effectively serve you, credit card transactions and order fulfillment are handled by
established third party banking institutions and processing agents (such as e.g. PayPal). They receive the
information needed to verify and authorize your credit card or other payment information and to
process and ship your order.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be
100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are
security and privacy limitations inherent to the Internet which are beyond our control; and (b) the
security, integrity and privacy of any and all information and data exchanged between you and us
through this Site cannot be guaranteed. As we have no control or ability to monitor the security of your
device, you should take measures reasonably available to secure your device.

In the event that PII is compromised as a result of a breach of security, MCM CRM will promptly notify
those persons whose PII has been compromised, in accordance with the notification procedures set
forth in this Privacy Policy, by email, or as otherwise required by applicable law. You agree to

immediately notify us and your Clients if you have experienced a breach of security on your device

which may have affected the security of our Site or Service.

8. Miscellaneous
You must be at least 18 years old to have our permission to use this Site. By agreeing to Our Policy, you
are hereby confirming that you are at least of 18 years old. Our policy is that we do not knowingly
collect, use or disclose PII about minor visitors.

You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e.
your name, email address, etc.) in the discussion forums or other public areas on this Site, that
information, along with any information disclosed in your communication, can be collected and used by
third parties and may result in unsolicited messages (including unwanted spam messages) from third
parties. Such activities are beyond our control and this Policy does not apply to such information. Please
consult our Site Terms and Conditions of Use Agreement for our Site Conduct policies.

If you have any questions, concerns or inquiries about our Privacy Policy, or our use of your PII, or our
privacy practices, please contact us at: support@MCMCRM.com. You can also reach our Privacy
Compliance Officer by sending written correspondence to:

Email: support@MCMCRM.com
Attn: Privacy Compliance Officer

9. GDPR: European or UK data subjects
Our clients use the MCM CRM software to collect and process the personal data of individuals, which
may include individuals in the EU and/or the UK. In particular, they use the software to manage their
marketing lists and campaigns, which includes the processing of the personal data of their customers.

For the purposes of the GDPR (and the UK GDPR) MCM CRM acts as a processor of the personal data of
data subjects. The controller of the data subjects’ personal data is either our client, or the customers of
our client.

We only process such personal data in accordance with the instructions of our client and in compliance
with our obligations as a processor. We ensure that a data processing agreement is entered into
between us and our client in order to ensure that appropriate safeguards are in place.
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