PRIVACY POLICY

Last modified: December 1, 2023

1. Introduction

This Privacy Notice describes how MasterNotes collects and uses Personal Data about you through the use of our Website and through email, and other electronic communications between you and Master Notes.

MasterNotes, LLC (“MasterNotes” or “we” or “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect from you or that you may provide when you visit or interact with our website https://masternotes.com/ (“Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

on our Website;
in email, text, and other electronic messages between you and our Website; and
when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
us offline or through any other means, including on any other website any third-party (including our affiliates and subsidiaries);
us or any of our affiliates or subsidiaries related to any individual’s employment or potential employment with us; or
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Website. By accessing or using this Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

2. Children’s Privacy

Children under the age of 18 must have parental or legal guardian consent to use our Website. Parents and legal guardians can revoke consent at any time and retain certain rights regarding our use, disclosure, and retention of their child’s Personal Data.

MasterNotes is committed to protecting the privacy of children in connection with the use of our Website. This section explains our online information collection, disclosure, and parental consent practices with respect to information collected from children under the age of 18 (“child” or “children”) in accordance with applicable law, including the U.S. Children’s Online Privacy Protection Act and its rules (collectively, “COPPA”), the General Data Protection Regulation (“GDPR”), and the UK Data Protection Act of 2018 (“UK GDPR”). For purposes of this section, any references to a parent also encompasses legal guardians. This section only applies to children under the age of 18 and supplements the other provisions of this Privacy Notice.

Our Website offers an online platform on which children can participate in music classes offered by instructors contracted with MasterNotes. A parent or legal guardian must create a MasterNotes account on behalf of a dependent child and attest that they have legal authority to do so. We require that all accounts be created by a parent or legal guardian in order to ensure that we can comply with our notice and consent obligations under applicable law. MasterNotes is not responsible for information collected by instructors outside the scope of this Privacy Notice, which is separate and distinct from the information collected by MasterNotes in order to create an account and/or use our Website.

During the account registration process, the parent or legal guardian will create an account by following our instructions for doing so and will be asked to provide certain Personal Data about the child, including name, age, information regarding their instrument(s), abilities with regard to the instrument(s), and name of instructor. We may also collect information directly from your child when the client provides it to the instructor or automatically as the child uses our Website, such as when your child attends music lessons, interacts with a lesson plan, or completes an assessment. This can include information about your child’s use of the services, including information about or sent by the mobile device or computer used by the child (e.g., IP address, browser type, operating system, website usage data, unique device identifiers, physical location of the device, etc.).

When creating an account for a child, parents and legal guardians are asked to review and consent to our Notice Regarding the Collection of Children’s Information, which provides parents and guardians with direct notice of our information practices before we collect any Personal Data from their child. Parents and guardians give their consent by checking the appropriate boxes on the account registration page. In addition, before we collect Personal Data from a child, we obtain the parent or guardian’s verifiable parental consent through collecting the parent or guardian’s driver’s license information to verify your identity as the child’s parent or legal guardian or through another method acceptable under applicable law for obtaining verifiable parental consent.

If a parent or legal guardian chooses not to consent to the collection and use of their child’s Personal Data, they may not create an online account for the child to use. At any time, a parent or legal guardian may revoke their consent. Once consent is revoked, a child may not use our Website or services unless a new consent is obtained.

The sections of this Privacy Notice contain details about the information we collect, which extend to information we collect about children. The information we collect will be used and disclosed for the purposes described in this Privacy Notice. We will not require a child to disclose more information than is reasonably necessary to participate in an activity.

No Personal Data about a child will be made available to the public or sold. We may share information with our service providers if necessary for them to perform business, professional, or technology services for us, always in accordance with all applicable laws. You have the right to agree for us to collect and use your child’s Personal Data but still not allow disclosure to third parties unless such disclosure is a necessary part of interacting with our Website.

In addition to your right to revoke your consent for the collection of your child’s Personal Data, you may request to review the Personal Data we have collected from your child or ask to delete the Personal Data we have collected from your child unless we are required by law to maintain that Personal Data. Please submit your request or any questions to us at customersupport@masternotes.com.

3. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any de-identified, anonymous, or aggregated information except where otherwise provided by law.

Generally

We collect Personal Data from various sources, including:

directly from you when you provide it to us;
automatically as you navigate through the Website;
information that we create about you as you use our Website; and
from third parties, for example, our business partners.

Information You Provide to Us

We may collect the following types of Personal Data directly from you when you access or use our Website: real name, home/work postal address, email address, telephone number, driver’s license information, credit or debit card number, birthdate, record of services purchased, obtained, or considered to be purchased or obtained, audio information, visual information, and any other identifier by which you may be contacted online or offline. In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us.

The Personal Data we collect on or through our Website is collected through:

information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website;
records and copies of your correspondence (including email addresses), if you contact us;
details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website; and
your search queries on the Website.

For users who create an Instructor Profile: You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Website, including information about your equipment, browsing actions, and patterns:

details of your visits to our Website. This includes: browsing history, search history, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with on the Website; and
information about your computer and internet connection, i.e., your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data. We may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences;
customize our Website according to your individual interests;
speed up your searches; and
recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Our Website may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. We only place cookies on your hard drive with your consent. You may withdraw or change your consent at any time by logging into your account and accessing your “Account” page. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Website and track which pages of the Website you access. Session cookies are required to use the Website.
Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, analytics providers, social media companies, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Minors

Please note, however, that we generally do not use the Personal Data of children under the age of 18 for non-essential cookies and tracking technologies.

4. How We Use Your Information

We use your Personal Data for various purposes described below, including to:
• provide our Website to you;
• provide you with information you request from us;
• enforce our rights arising from contracts;
• notify you about changes; and
• provide you with notices about your account

We use information that we collect about you or that you provide to us, including any Personal Data:

to provide and personalize our Website and its content to you;
to provide you with information, or services that you request from us;
to support, develop, troubleshoot, and debug our Website, and services;
to create, maintain, customize, and secure your account with us;
to process your requests, purchases, transactions, and payments and prevent transactional fraud;
to provide you with notices about your account, including expiration and renewal notices;
to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
to personalize your Website experience and to deliver content and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law);
to help maintain the safety, security, and integrity of our Website and services, databases and other technology assets, and business;
for internal testing, research, analysis, and product development, including to develop and improve our Website, and to develop, improve, or demonstrate our services;
auditing relating to a current interaction with you and concurrent transactions, including, but not limited to, counting advertising impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with any applicable specification and other standards;
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
debugging to identify and repair errors that impair existing intended functionality;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Website or services we offer or provide though it;
to allow you to participate in interactive features on our Website;

in any other way we may describe when you provide the information;
to fulfill any other purpose for which you provide it; and
for any other purpose with your consent.

With your consent, we may also use your information to contact you about our own services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your information. If you wish to change your choice, you may do so at any time by logging into the Website and adjusting our user preferences in your account profile by checking or unchecking the relevant box . For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. We disclose your Personal Data to a few third parties, including:

our subsidiaries and our affiliates;
our third-party service providers that we use to support our business;
to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
to comply with our legal obligations;
to enforce our rights; and
with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

to our subsidiaries and affiliates;
to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These entities provide services such as IT and infrastructure support services, and payment processing services. The privacy policy of our payment processor, WooCommerce, may be found at https://automattic.com/privacy/.
to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MasterNotes’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by MasterNotes about our Website’s users is among the assets transferred;
to third parties to market their products or services to you if you have consented to these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
to fulfill the purpose for which you provide it; for example, if you use our Website messaging feature to write a communication to another Website user, we will transmit the contents of that message and your associated account contact to the recipient;
for any other purpose disclosed by us when you provide the information; and
with your consent.

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MasterNotes, our customers, or others.

6. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. We will only share your Personal Data with unaffiliated or non-agent third parties for promotional purposes with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.
Promotional Offers from MasterNotes. We will only use your email address/contact information to promote our own or third parties’ products and services with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data. If you wish to change your choice, you may do so at any time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional email, you may click the unsubscribe link in the body of that email to be omitted from future email distributions. This opt out does not apply to information provided to MasterNotes as a result of a purchase for a service through our Website.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).

Data subjects in the European Economic Area, Switzerland, or the United Kingdom may have additional personal information rights and choices. Please see Jurisdiction-Specific Privacy Rights for more information.

7. Accessing, Correcting, and Deleting Your Personal Data

You may request to access, correct, and delete your Personal Data as noted below. However, we cannot accommodate a request to change your Personal Data if we believe that such change would either violate a legal obligation or cause the Personal Data to be incorrect.

You can review and change your Personal Data by logging into the Website and visiting your account profile page.

You may also contact us to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

8. Jurisdiction-Specific Privacy Rights

The law in certain jurisdictions may provide their residents with additional rights regarding our use of your Personal Data.

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see below.

Your GDPR Privacy Rights

If you are in the European Economic Area, Switzerland, or the United Kingdom, you have the additional rights described in our GDPR Privacy Addendum.

9. Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Note that we generally do not engage in this behavioral tracking for children under age 18. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

10. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, except in the case of a minor, with a parent/guardian. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website.

11. Consent to Processing of Personal Data in the United States

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

In order to provide our Website, products, and services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located, including in the United States.

12. Changes to Our Privacy Notice

We will post any changes to our Privacy Notice on our Website. If we make material changes to our Privacy Notice, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Notice at any time and at our sole discretion. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

YOUR CONTINUED USE OF OUR WEBSITE FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.

13. Contact Information

You may ask questions about this Privacy Notice and our privacy practices by contacting us at the contact information below.

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below.

MasterNotes, LLC

14900 Conference Center, Suite 200

Chantilly, VA 20151

Customersupport@masternotes.com

MasterNotes GDPR Privacy Addendum

Last modified: December 1, 2023

14. Introduction

This GDPR Privacy Addendum supplements the information in our Privacy Notice if you are located in the European Economic Area, the United Kingdom, or Switzerland.

This GDPR Privacy Addendum (the “GDPR Privacy Addendum”) supplements the information contained in our Privacy Notice (our “Privacy Notice”) and applies solely to the users of our Website who are located in the European Economic Area, the United Kingdom, or Switzerland. We adopt this GDPR Privacy Addendum to comply with the European Union’s General Data Protection Regulation, and any laws implementing the foregoing by any member states of the European Economic Area, the United Kingdom (including the UK Data Protection Act and the UK-GDPR), and or Switzerland (collectively, the “GDPR”). Unless otherwise defined in this GDPR Privacy Addendum, any terms defined in the GDPR or our Privacy Notice have the same meaning when used in this GDPR Privacy Addendum. When this GDPR Privacy Addendum is applicable to you, it takes precedence over anything contradictory in our Privacy Notice.

15. Data Controller, Data Protection Officer, and Representative

MasterNotes is the data controller of the Personal Data you provide on the Website. MasterNotes has appointed a Data Protection Officer, a representative in the European Union, and a representative in the United Kingdom.

MasterNotes is the data controller of your Personal Data. MasterNotes has appointed a Data Protection Officer and a representative in both the European Union and the United Kingdom in compliance with the GDPR and the UK GDPR. MasterNotes, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Information” Section of this GDPR Privacy Addendum.

16. Information We Collect About You and How We Collect It

The Personal Data we collect about you and how we collect it is described in our Privacy Notice.

The Personal Data we collect and the ways in which we collect it is described in our Privacy Notice. The Personal Data we collect from you is required to enter into a contract with MasterNotes, for MasterNotes to perform under the contract, and to provide you with our services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data (when appropriate), then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

17. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

The processing of your Personal Data is lawful only if it is permitted under the GDPR. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

Consent. By using our Website, you consent to our collection, use, and sharing of your Personal Data as described in our Privacy Notice and this GDPR Privacy Addendum. If you do not consent to the terms of our Privacy Notice and this GDPR Privacy Addendum, please do not use the Website;
Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your interests and rights and freedoms and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between MasterNotes and you; detect and correct bugs and to improve our Website; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; and develop our services;

To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our services to you; and
As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

18. Special Categories of Information

We generally do not request you provide and do not process any special categories of Personal Data.

MasterNotes does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.

19. Automated Decision Making

We generally do not use your Personal Data with any automated decision making processes.

MasterNotes does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

20. How We Use Your Information

We only use your Personal Data as described in our Privacy Notice.

We use your Personal Data as described in our Privacy Notice.

21. Disclosure of Your Information

We only share or disclose your Personal Data to the entities and for the purposes described in our Privacy Notice.

We do not share or otherwise disclose your Personal Data for purposes other than to the entities and for the purposes described in our Privacy Notice.

22. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You have certain rights with respect to your Personal Data under the GDPR, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

The GDPR provides you with certain rights with regards to our processing of your Personal Data. These rights replace the similar rights provided in our Privacy Notice or are supplemental to such rights.

Access and Update. You can review and change your Personal Data by logging into the Website and visiting your “Account” page. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
Portability. To the extent the Personal Data you provide MasterNotes is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.

Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

23. Consent to Processing of Personal Data In Other Countries Outside the European Economic Area or the United Kingdom

In order to provide our Website and services to you, we may send and store your Personal Data outside of the EEA or the United Kingdom, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by MasterNotes to another country only if it is required or permitted under the GDPR and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with our Privacy Notice and this GDPR Privacy Addendum when we transfer it to a third party, MasterNotes uses Data Protection Agreements between MasterNotes and all other recipients of your data that include, where applicable, the standard contractual clauses adopted by the European Commission and/or the Information Commissioner’s Office in the United Kingdom (collectively, the “Standard Contractual Clauses”). The European Commission and the Information Commissioner’s Office in the United Kingdom have determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data, however, the Standard Contractual Clauses may need to be supplemented in some cases with additional measures on a case-by-case basis after an analysis that such supplemental measures can provide you with an essentially equivalent level of protection as afforded in the EEA and/or the UK. When, as a result of this analysis, we believe this to be appropriate and necessary, the Standard Contractual Clauses have been supplemented in this way. Under these Standard Contractual Clauses, you have the same rights as if your Personal Data was not transferred to such third country. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.

24. Data Retention Periods

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

on our backup and disaster recovery systems;
for as long as necessary to protect our legal interests; and
and to comply with other legal requirements.

MasterNotes will retain your Personal Data for as long as MasterNotes has a business reason to retain the Personal Data, or for any of the reasons listed below, whichever is longer:

for as long as necessary to comply with any legal requirement;
on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

25. Changes to This GDPR Privacy Addendum

We will post any changes to our GDPR Privacy Addendum on our Website. If we make material changes to this GDPR Privacy Addendum, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this GDPR Privacy Addendum at any time at our sole discretion. It is our policy to post any changes we make to our GDPR Privacy Addendum on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website’ home page. The date this GDPR Privacy Addendum was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this GDPR Privacy Addendum to check for any changes.

26. Contact Information

You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact both us and our representative through the contact information below.

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or this GDPR Privacy Addendum, have any requests related to your Personal Data described in the Privacy Notice or this GDPR Privacy Addendum, or otherwise need to contact us, you must contact both us and our representative in the European Union at the contact information below.

To Contact MasterNotes (Controller)

MasterNotes, LLC

14900 Conference Center, Suite 200

Chantilly, VA 20151

United States

DavidLoughran@qpimail.com

To Contact Our Representative in the EU

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Company’s Name

has appointed European Data Protection Office (EDPO) as its GDPR Representative

in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

-by using EDPO’s online request form: https://edpo.com/gdpr-data-request/

-by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

To Contact Our Representative in the UK

UK General Data Protection Regulation (GDPR) – UK Representative

Pursuant to Article 27 of the UK GDPR, Company’s Name has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/

– by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

To Contact Our Representative in Switzerland

FADP Article 14 Representative

Pursuant to Article 14 of the FADP, Company’s Name has appointed EDPO Switzerland as its Representative in Switzerland. You can contact EDPO Switzerland regarding matters pertaining to the FADP:-by using EDPO Switzerland’s online request form: https://edpo.com/swiss-data-request/-by writing to EDPO Switzerland at Rue de Lausanne 37, 1201 Geneva, Switzerland

To Contact Our Data Protection Officer

MasterNotes, LLC

14900 Conference Center, Suite 200

Chantilly, VA 20151

United States

DavidLoughran@qpimail.com

PRIVACY POLICY

Last modified: December 1, 2023

1. Introduction

2. Children’s Privacy

3. Information We Collect About You and How We Collect It

4. How We Use Your Information

5. Disclosure of Your Information

6. Choices About How We Use and Disclose Your Information

7. Accessing, Correcting, and Deleting Your Personal Data

8. Jurisdiction-Specific Privacy Rights

9. Do Not Track Signals

10. Data Security

11. Consent to Processing of Personal Data in the United States

12. Changes to Our Privacy Notice

13. Contact Information

14. Introduction

15. Data Controller, Data Protection Officer, and Representative

16. Information We Collect About You and How We Collect It

17. Lawful Basis for Processing Your Personal Data

18. Special Categories of Information

19. Automated Decision Making

20. How We Use Your Information

21. Disclosure of Your Information

22. Your Rights Regarding Your Information and Accessing and Correcting Your Information

23. Consent to Processing of Personal Data In Other Countries Outside the European Economic Area or the United Kingdom

24. Data Retention Periods

25. Changes to This GDPR Privacy Addendum

26. Contact Information

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