At MTA-USA, we take privacy very seriously and are committed to the safety of information and full disclosure to our clients and customers. This privacy policy (“Privacy Policy”) sets out how we obtain, use, share, and protect personal information, including through your use of our website, data we collect as part and parcel to running our business and any services we may provide (“Services”). It also explains what rights you have to access, change or delete your personal data. By agreeing to these terms and using our services and platform, you consent to use of your personal information to the extent that it is explained herein and agree to the terms of this Privacy Policy. We will only process your personal information in accordance with applicable data protection and privacy laws.
Types of personal information collected.
We collect personal information in a number of ways. We may collect information you provide to us in person, by phone, email, via your data entry into our website, information provided to our shipping and receiving or otherwise. The types of informational data that we may store includes but is not limited to: name; job title and employer; email address; phone number; postal address; employment and background data; information contained in correspondence; and marketing and communications data.
In addition, If you pay registration or annual fees or transact any e-commerce based business with us, you will be engaging in a financial transaction through our website. In any such transaction, you will be asked to provide certain financial information, such as your bank account number and routing details, to effectuate a bank transfer. We retain such information for our records, and may also transfer it to a third party for payment processing. We use technology designed to encrypt the transmission of data to us through the system, as well as financial information we receive, transfer or maintain. If you submit financial information through our website or by any other electronic means, all of that information is submitted directly and securely to a third-party payment processor.
MTA-USA may further collect information from public records and third party sources of information, publicly accessible accounts on social media platforms such as LinkedIn aa well as from third parties. We also may collect, store and use information about your visits to our website and information relating to the communications we sent to you, such as:
- technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, browser plug-in types and versions, operating system and platform, and geographical location;
- information about your visits and use of the our websites, including the full Uniform Resource Locators (URL), clickstream to, through and from our websites, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used;
- information collected by cookies on our website (for more information on cookies, please see the section on cookies below).
- Our Websites may allow you to enter social networking websites such as Facebook, YouTube, LinkedIn, and Twitter. If you choose to follow, like, friend, share, or comment on our social media websites, or otherwise share information on these social networking websites, we may receive information about you. We may use such information about you in a variety of ways, including to enhance your experience with the PCAOB’s outreach and to communicate with you about new PCAOB activities. We may keep all of this information indefinitely.
MTA-USA’s use of personal information.
We may use your personal information to provide you requested information; to send you updates, promotional material and other communications concerning our company and products that we think may be of interest to you; to transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices; to invite you to events, etc.; to make you aware of and enforce the terms and conditions and any contracts between you and MTA-USA; to keep you updated on changes to our policies, other terms and conditions and other administrative information; Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted purpose or are required to do so; to track and facilitate our services, including research, statistical analyses and surveying; to improve our services internally, business and otherwise, to ensure that consent is presented in the most effective manner for you; and to keep our Services operating safe and secure, prevent and address fraud, breach of policies or terms, and threats or harm.
If you object to our use of your personal information and said information is required as part of fulfillment of a contractual obligation with you or your business, it may affect our ability to perform the terms of said contract.
MTA-USA will only use personal information and data for purposes named herein or for the reason that it is collected, unless it is reasonably thought to relate to the original purpose for which it is collected.
Cookies.
Cookies and local storage may be set and accessed on your computer. Upon your first visit to the Services, a cookie or local storage may be sent to your computer that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your computer’s browser and stored on your device when you visit a website. Many major Web services use cookies to provide useful features for their users. Each Web site can send its own cookie to your browser. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign in to the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent. Please be advised that the cookies which may be used on our site include, but are not necessarily limited to, those listed below. Furthermore, MTA-USA has no control over cookies that may be used by third party websites that you may be redirected to while accessing MTA-USA’s site. In addition to the third party terms contained herein, MTA-USA is not responsible for the use of any cookies by third party sites.
To support our Services we or our service providers may use one or more of the following cookies for the purposes set forth below:
| Type of Cookie | Purpose |
|
Analytics and Performance Cookies | These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages that they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB |
| Essential Cookies | These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. |
| Functionality Cookies | These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, remembering which polls you have voted in and in some cases, to show you poll results, and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services. |
| Social Media Cookies | These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this. |
You can find more information about cookies and how they work, what cookies have been set on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
Opting Out of Communications
If you have subscribed to or are otherwise receiving MTA-USA news or similar information from us by email, text message or otherwise and no longer want to receive such information in the future, you may opt out of receiving these emails by contacting us directly at bkielar@mta-usa.com.
Please note that even if you opt out of receiving emails, you may still receive communications related to MTA-USA as required by law or for reasons relating to an existing account relationship. Also note that we may need to keep information we have collected about you for record-keeping, research and other purposes.
Disclosure of personal information to third parties.
MTA-USA will not share, rent, sell or otherwise disclose any personal information collected about you through our Websites, except in any of the following situations or otherwise described in this Privacy Policy:
You knowingly request or allow the dissemination of personal information;
When we perceive that disclosure is required to do so by law, applicable regulations, or where reasonably necessary to protect our rights or a third party’s rights, for example, in response to a court order, a subpoena, a request by a law enforcement agency or to respond to claims that any content violates the rights of any third party;
In order to prevent, investigate, detect or prosecute criminal offenses or attacks on the technical integrity of our websites or our network; and to protect the rights, property and safety of our firm, the users of our websites and the public. We may also disclose personal information to enforce or apply our terms and conditions or to establish, exercise or defend the rights of our firm, our staff, customers or others;
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or if all or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
Other than those instances listed above, MTA-USA will not share your personal data with third parties unless explicitly stated in the policy. We may share your information among employees and officers of MTA-USA; our marketing and promotional partners; third party IT and tech support partners or data storage services. Our third party processors and service providers are subject to security and confidentiality agreements and are only permitted to process your personal data consistent with our instructions; which do not include unauthorized third party dissemination.
Safeguarding of Information.
MTA-USA will make diligent efforts to maintain the security, integrity and privacy of any personal information you provide. Though we will venture to protect against unauthorized disclosures, we can’t guarantee that personal information in the possession of MTA-USA will not be disseminated to third parties in a manner inconsistent with this Privacy Policy. Inadvertent disclosures may occur. We will retain your personal information for only as long as is reasonably necessary to provide you with services pursuant to an agreement or contract, for our lawful business purposes or pursuant to applicable local, state and federal law or regulation.
Storage and security of information on third party websites.
Our website may contain links to third party sites. Neither we nor our employees, agents or representatives are responsible for the privacy practices of these sites. These sites may have their own privacy policies and customer service policies, or no policies at all. We encourage you to read the privacy policies of sites which link to or from MTA-USA’s website to see how your information will be handled before disseminating your personal information. Nothing in this paragraph should be read to conclude that MTA-USA will provide your personal information to these third party sites.
Alterations or notice to dispose of personal information.
To inquire as to what information MTA-USA has stored, to change or update said information, to question dissemination of said information or to change the information we have stored, please e-mail us a request to bkielar@MTA-USA.com. MTA-USA reserves the right to refuse to comply with excessive, broad, burdensome, repetitive requests; where a request in in conflict with existing law, regulation or agreement with you; or where deletion of said information would render legal obligation or fulfillment of obligation under a contract more difficult or impossible.
Information from users outside the U.S.A. and consent to transfer information.
Our Services are operated in the United States as well as internationally. If you are located outside the United States, please be aware that information you provide to us will be transferred to, stored and processed in the U.S.A. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the U.S.A., a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
In situations other than those listed in this Privacy Policy, you will be informed if your personal information will be disclosed to third parties and will have the opportunity to opt out of such disclosure, unless such disclosure to third parties is pursuant to the regulatory activities of MTA-USA or is otherwise required by law.
Application of the Privacy Policy to children.
Our websites are not directed to children under the age of 18. We prohibit children under the age of 18 from using all interactive portions of the website. We will not knowingly collect personally identifiable information from children under 18. We understand that young people need special safeguards and privacy protection. We realize that they may not understand all the provisions of our Privacy Policy or be able to make thoughtful decisions about the choices that are made available to our adult users. We strongly urge all parents to participate in their children’s exploration of the Internet and any online services, and to teach their children about protecting their personal information while online.
California Privacy Rights requirements.
We do not share personal information with third parties for their direct marketing purposes, as defined by California Civil Code Section 1798.83, unless we give you choice (opt-in or opt-out) before sharing with those third parties. If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us by sending an email to law@cll.com. You must put the statement “My California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via the telephone or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. There currently is no consensus among industry participants as to what “Do Not Track” means in this context. Therefore, like many websites and online services, MTA-USA does not alter its practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Modifications.
We may modify this Privacy Policy at any time and at our sole discretion, by posting the modifications on our websites. The modifications will be effective upon posting (unless some other date is specified). You should review this Privacy Policy periodically so that you are aware of any modifications. Your use of any of our websites constitutes your full acceptance of the Privacy Policy in its then-current form each time you use of any of our websites.
Governing Law
By choosing to visit our Websites or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of New York. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreement that we have with you.
Dispute Resolution.
Any disputes, actions or proceedings relating to this Privacy Policy, or to our handling of personal information, will be governed by the laws of the State of New York, without regard to its conflict of law rules, and must be brought in the federal or state courts in the City and County of New York. By using any of our websites, you irrevocably consent to the exclusive jurisdiction and venue of those courts.
Questions or Comments.
Feel free to address any questions or comments regarding our Privacy Policy to info@mta-usa.com