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Melissa Newcomb Consulting
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Privacy Policy

PRIVACY POLICY

Last updated December 12, 2023

This privacy notice for Melissa Newcomb Consulting (doing business as MN Consulting ("we," "us," or

"our"), describes how and why we might collect, store, use, and/or share ("process") your

information when you use our services ("Services"), such as when you:

Visit our website at https://melissanewcombconsulting.com, or any website of ours that links to

this privacy notice

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights

and choices. If you do not agree with our policies and practices, please do not use our Services. If

you still have any questions or concerns, please contact us at

melissa@melissanewcombconsulting.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details

about any of these topics by clicking the link following each key point or by using our table of

contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may

process personal information depending on how you interact with us and the Services, the choices

you make, and the products and features you use. Learn more about personal information you

disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal

information.

Do we receive any information from third parties? We do not receive any information from third

parties.

How do we process your information? We process your information to provide, improve, and

administer our Services, communicate with you, for security and fraud prevention, and to comply with

law. We may also process your information for other purposes with your consent. We process your

information only when we have a valid legal reason to do so. Learn more about how we process your

information.

In what situations and with which parties do we share personal information? We may share

information in specific situations and with specific third parties. Learn more about when and with

whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and

procedures in place to protect your personal information. However, no electronic transmission over

the internet or information storage technology can be guaranteed to be 100% secure, so we cannot

promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able

to defeat our security and improperly collect, access, steal, or modify your information. Learn more

about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy

law may mean you have certain rights regarding your personal information. Learn more about your

privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting

https://melissanewcombconsulting.com/contact, or by contacting us. We will consider and act upon

any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in

full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the

Services, express an interest in obtaining information about us or our products and Services, when

you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the

context of your interactions with us and the Services, the choices you make, and the products and

features you use. The personal information we collect may include the following:

names

phone numbers

email addresses

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing

social media account details, like your Facebook, Twitter, or other social media account. If you

choose to register in this way, we will collect the information described in the section called "HOW DO

WE HANDLE YOUR SOCIAL LOGINS?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must

notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services,

communicate with you, for security and fraud prevention, and to comply with law. We may also

process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact

with our Services, including:

To facilitate account creation and authentication and otherwise manage user

accounts. We may process your information so you can create and log in to your account, as

well as keep your account in working order.

To respond to user inquiries/offer support to users. We may process your information to

respond to your inquiries and solve any potential issues you might have with the requested

service.

To send administrative information to you. We may process your information to send you

details about our products and services, changes to our terms and policies, and other similar

information.

To deliver targeted advertising to you. We may process your information to develop and

display personalized content and advertising tailored to your interests, location, and more.

To post testimonials. We post testimonials on our Services that may contain personal

information.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL

INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the

following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during

negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion

of our business to another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or

store information. Specific information about how we use such technologies and how you can refuse

certain cookies is set out in our Cookie Notice.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may

have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account

details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain

profile information about you from your social media provider. The profile information we receive may

vary depending on the social media provider concerned, but will often include your name, email

address, friends list, and profile picture, as well as other information you choose to make public on

such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice

or that are otherwise made clear to you on the relevant Services. Please note that we do not control,

and are not responsible for, other uses of your personal information by your third-party social media

provider. We recommend that you review their privacy notice to understand how they collect, use,

and share your personal information, and how you can set your privacy preferences on their sites and

apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this

privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in

this privacy notice, unless a longer retention period is required or permitted by law (such as tax,

accounting, or other legal requirements). No purpose in this notice will require us keeping your

personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will

either delete or anonymize such information, or, if this is not possible (for example, because your

personal information has been stored in backup archives), then we will securely store your personal

information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and

technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures

designed to protect the security of any personal information we process. However, despite our

safeguards and efforts to secure your information, no electronic transmission over the Internet or

information storage technology can be guaranteed to be 100% secure, so we cannot promise or

guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat

our security and improperly collect, access, steal, or modify your information. Although we will do our

best to protect your personal information, transmission of personal information to and from our

Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the

Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor

and consent to such minor dependent’s use of the Services. If we learn that personal information

from users less than 18 years of age has been collected, we will deactivate the account and take

reasonable measures to promptly delete such data from our records. If you become aware of any

data we may have collected from children under age 18, please contact us at

melissa@melissanewcombconsulting.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process your personal information,

which may be express and/or implied consent depending on the applicable law, you have the right to

withdraw your consent at any time. You can withdraw your consent at any time by contacting us by

using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal

nor, when applicable law allows, will it affect the processing of your personal information conducted in

reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our

marketing and promotional communications at any time by clicking on the unsubscribe link in the

emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU

CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists.

However, we may still communicate with you — for example, to send you service-related messages

that are necessary for the administration and use of your account, to respond to service requests, or

for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your

account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and

information from our active databases. However, we may retain some information in our files to

prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or

comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you

prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you

choose to remove cookies or reject cookies, this could affect certain features or services of our

Services.

If you have questions or comments about your privacy rights, you may email us at

melissa@melissanewcombconsulting.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-

Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data

about your online browsing activities monitored and collected. At this stage no uniform technology

standard for recognizing and implementing DNT signals has been finalized. As such, we do not

currently respond to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in

the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted

specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected

A. Identifiers

Contact details, such as real name, alias, postal

address, telephone or mobile contact number,

unique personal identifier, online identifier, Internet

Protocol address, email address, and account

name

NO

B. Personal information as

defined in the California

Customer Records statute

Name, contact information, education,

employment, employment history, and financial

information

NO

C. Protected classification

characteristics under state or

federal law

Gender and date of birth NO

D. Commercial information

Transaction information, purchase history, financial

details, and payment information

NO

E. Biometric information Fingerprints and voiceprints NO

F. Internet or other similar

network activity

Browsing history, search history, online behavior,

interest data, and interactions with our and other

websites, applications, systems, and

advertisements

NO

G. Geolocation data Device location NO

H. Audio, electronic, visual,

thermal, olfactory, or similar

information

Images and audio, video or call recordings created

in connection with our business activities

NO

I. Professional or employmentrelated

information

Business contact details in order to provide you

our Services at a business level or job title, work

history, and professional qualifications if you apply

for a job with us

YES

J. Education Information Student records and directory information YES

K. Inferences drawn from

collected personal information

Inferences drawn from any of the collected

personal information listed above to create a

profile or summary about, for example, an

individual’s preferences and characteristics

NO

L. Sensitive personal Information NO

We will use and retain the collected personal information as needed to provide the Services or for:

Category B - As long as the user has an account with us

Category I - As long as the user has an account with us

Category J - As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where

you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR

INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract

between us and each service provider. Learn more about how we disclose personal information to in

the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking

internal research for technological development and demonstration. This is not considered to be

"selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or

commercial purpose in the preceding twelve (12) months. We will not sell or share personal

information in the future belonging to website visitors, users, and other consumers.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users

who are California residents to request and obtain from us, once a year and free of charge,

information about categories of personal information (if any) we disclosed to third parties for direct

marketing purposes and the names and addresses of all third parties with which we shared personal

information in the immediately preceding calendar year. If you are a California resident and would like

to make such a request, please submit your request in writing to us using the contact information

provided below.

If you are under 18 years of age, reside in California, and have a registered account with the

Services, you have the right to request removal of unwanted data that you publicly post on the

Services. To request removal of such data, please contact us using the contact information provided

below and include the email address associated with your account and a statement that you reside in

California. We will make sure the data is not publicly displayed on the Services, but please be aware

that the data may not be completely or comprehensively removed from all our systems (e.g.,

backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA),

you have the rights listed below.

The California Code of Regulations defines a "residents" as:

(1) every individual who is in the State of California for other than a temporary or transitory

purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California

for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations

regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal

information, we will respect your request and delete your personal information, subject to certain

exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or

her right to free speech, our compliance requirements resulting from a legal obligation, or any

processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a business

purpose;

the categories of third parties to whom the personal information was sold, shared, or disclosed

for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information

that is de-identified in response to a consumer request or to re-identify individual data to verify a

consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same

person about whom we have the information in our system. These verification efforts require us to

ask you to provide information so that we can match it with information you have previously provided

us. For instance, depending on the type of request you submit, we may ask you to provide certain

information so that we can match the information you provide with the information we already have on

file, or we may contact you through a communication method (e.g., phone or email) that you have

previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to

make the request. To the extent possible, we will avoid requesting additional information from you for

the purposes of verification. However, if we cannot verify your identity from the information already

maintained by us, we may request that you provide additional information for the purposes of

verifying your identity and for security or fraud-prevention purposes. We will delete such additionally

provided information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask

to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on your behalf. We

may deny a request from an authorized agent that does not submit proof that they have been

validly authorized to act on your behalf in accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal information to third

parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly

possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by visiting

https://melissanewcombconsulting.com/contact, by visiting

https://melissanewcombconsulting.com/contact, or by referring to the contact details at the bottom of

this document. If you have a complaint about how we handle your data, we would like to hear from

you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the

rights listed below. However, these rights are not absolute, and in certain cases, we may decline your

request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising, the

sale of personal data, or profiling in furtherance of decisions that produce legal or similarly

significant effects ("profiling")

To submit a request to exercise these rights described above, please email

melissa@melissanewcombconsulting.com or visit https://melissanewcombconsulting.com/contact.

If we decline to take action regarding your request and you wish to appeal our decision, please email

us at melissa@melissanewcombconsulting.com. Within forty-five (45) days of receipt of an appeal,

we will inform you in writing of any action taken or not taken in response to the appeal, including a

written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA),

you have the rights listed below. However, these rights are not absolute, and in certain cases, we

may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising, the

sale of personal data, or profiling in furtherance of decisions that produce legal or similarly

significant effects ("profiling")

To submit a request to exercise these rights described above, please email

melissa@melissanewcombconsulting.com or visit https://melissanewcombconsulting.com/contact.

If we decline to take action regarding your request and you wish to appeal our decision, please email

us at melissa@melissanewcombconsulting.com. Within sixty (60) days of receipt of an appeal, we will

inform you in writing of any action taken or not taken in response to the appeal, including a written

explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have

the rights listed below. However, these rights are not absolute, and in certain cases, we may decline

your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising or

the sale of personal data

To submit a request to exercise these rights described above, please email

melissa@melissanewcombconsulting.com or visit https://melissanewcombconsulting.com/contact.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an

individual or household context. It does not include a natural person acting in a commercial or

employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or

identifiable natural person. "Personal data" does not include de-identified data or publicly available

information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations

regarding your personal data.

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising, the

sale of personal data, or profiling in furtherance of decisions that produce legal or similarly

significant effects ("profiling")

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at melissa@melissanewcombconsulting.com or visit

https://melissanewcombconsulting.com/contact.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized

agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your

consumer's request. If you submit the request through an authorized agent, we may need to collect

additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five

(45) days of receipt. The response period may be extended once by forty-five (45) additional days

when reasonably necessary. We will inform you of any such extension within the initial 45-day

response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning

behind it. If you wish to appeal our decision, please email us at

melissa@melissanewcombconsulting.com. Within sixty (60) days of receipt of an appeal, we will

inform you in writing of any action taken or not taken in response to the appeal, including a written

explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney

General to submit a complaint.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an

updated "Revised" date and the updated version will be effective as soon as it is accessible. If we

make material changes to this privacy notice, we may notify you either by prominently posting a

notice of such changes or by directly sending you a notification. We encourage you to review this

privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at

melissa@melissanewcombconsulting.com or contact us by post at:

Melissa Newcomb Consulting

__________

__________

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the

personal information we collect from you, change that information, or delete it. To request to review,

update, or delete your personal information, please

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