Who we are
Mastermind Consulting, LLC (“Mastermind,” “us,” “we,” or “our”) thanks you for visiting the
online and mobile resources we publish. We use the words “you” and “your” to mean you, the
reader, and other visitors to our online and mobile resources who are, in all cases, over the age of
13. Our privacy statement (“this statement,” “this privacy statement,” and “our statement”)
informs you about from whom and the types of personal information we collect, how we use it,
who we share it with and why, and what we do to try to protect it.
Online and mobile resources means the websites and other internet features we own that allow
you to interact with our websites, as well apps we’ve created and distributed to let our customers
and followers view our online and mobile resources or otherwise interact with the content we
provide.
WHO WE COLLECT PERSONAL INFORMATION FROM
We may collect personal information from the following groups of data subjects: visitors to, and
users of, our online and mobile resources; our customers; current members of our workforce and
those who apply for posted jobs; and third party vendors and business partners.
Personal information generally means information that can be used to identify you or that can
be easily linked to you (for example, your name, address, telephone number, email address,
social security number and date of birth). The privacy laws in some jurisdictions include unique
elements in what they consider to be the personal information of the consumers or data subjects
they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act
(“CCPA”) or European General Data Protection Regulation (“GDPR”), our use of the phrase
“personal information” includes the unique elements required by such laws.
The categories of information we collect from each of these groups, and the ways in which we
use it, differs. As you may have noticed, it’s possible that the same person could fall into more
than one group. Most of this statement addresses our processing and sharing of personal
information collected from visitors to and users of our online and mobile resources and our
customers.
Nonetheless, we collect and retain the types of professional or employment related personal
information you would expect an employer to have about its existing and former workforce and
new job applicants. We provide legally required notices of collection, and describe our use and
sharing of the personal information of our workforce and applicants in greater detail in
confidential internal human resource manuals and documents accessible to members of our
workforce, or by publication on the proprietary workforce/applicant portals and apps we operate.
In some cases, such portals and apps may be operated by third parties who transfer the personal
information to us. In those situations, the legal responsibility to provide notice usually rests with
the third party, not us.
In addition, like all corporate enterprises, we buy goods and services, lease equipment and office
space and attend industry events. In doing so, we interact with many existing and potential
vendors and business partners from whom we necessarily collect certain personal information
in connection with our contractual and business relationships. As with our customers, this
information is typically limited to minimum business contact information. We use and share
personal information collected from our vendors and business partners to manage, administer
and perform under our contracts with them, or share information about our products. We
describe our use of vendor and business partner personal information in greater detail in our
confidential contracts with those parties or on the internal vendor management portals we
operate.
WHAT WE COLLECT
There are two types of information that we obtain from you online and then store and use: (i)
non-personal information that’s collected automatically from each visitor, such as your device
operating system; and (ii) personal information that you voluntarily provide to us or that is
collected automatically.
By using our online and mobile resources or purchasing our products or services, you are
signifying to us that you agree with this section of our privacy statement and that we may use
and disclose your information as described.
Voluntarily Submitted Information.
If you participate in certain activities via our online and mobile resources, you may be asked to
provide us with information about yourself. The types of personal information we collect in
those situations includes identifiers (such as your name, email address, physical address, and
phone number), professional information (such as the business you are in), and financial
account information (such as your credit card information). We do not sell, rent, or trade
voluntarily submitted personal information with third parties.
If you don’t want us to collect this type of personal information, please don’t provide it. This
means you shouldn’t participate in the activities on our online and mobile resources that request
or require it and you may want to communicate with us by phone or regular mail instead.
Participation is strictly your choice. Not participating may limit your ability to take full
advantage of the online and mobile resources, but it will not affect your ability to access certain
information available to the general public on the online and mobile resources.
Some of the ways you voluntarily give us your personal information and how we use it:
Emails and Online Forms – When you send us an email or fill out an online form, such as to
contact us, your email address and any other personal information (e.g., home address or phone
number) that may be in the content of your message or attached to it, are retained by us and used
to respond back directly to you and to process your request. Depending on the personal
information provided, communications from us may be in the form of emails, telephone calls,
and/or text messages. We may also send you information about any of our products or services
we think may be of interest to you.
Registering for an Account – When you register for an account or you register your child for a
sub-account, you submit personal information to us such as your name and email address (or
your child’s name and email address) which we then retain. We use that information to create
and manage your account and in some cases establish a password and profile to communicate
with you and any sub-accounts you created via email.
Registering for Events – When you register for events, conferences or programs we ourselves
may host (rather than outsource to a third party event manager with its own privacy policies),
you will be submitting the types of identifiers described above. If the event requires a fee, we
may also ask you to submit credit card or other financial information. We use this
information to register you for the event and send you communications regarding the event.
Becoming a Subscriber to Our Service – We use any information provided from our customers
to perform our contractual obligations and provide the products and services purchased to them,
to manage their accounts and communicate with them.
Social Media and Community Features – Some of our online and mobile resources may offer
social media-like community features letting users post messages and comments, and/or upload
an image or other files and materials. If you choose to make use of these features, the
information you post, including your screen name and any other personal information, will be in
the public domain and not covered/protected by this statement.
Automatically Collected Information.
When you visit our online and mobile resources, basic information is passively collected through
your web browser via use of tracking technologies, such as a “cookie” which is a small text file
that is downloaded onto your computer or mobile device when you access the online and mobile
resources. It allows us to recognize your computer or mobile device and store some information
about your preferences or past actions.
We allow third party vendors to use cookies or similar technologies to collect information about
your browsing activities over time following your use of the site. For example, we use Google
Analytics, a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses
cookies to help us analyze how you use the online and mobile resources and enhance your
experience when you visit the online and mobile resources. For more information on how
Google uses this data, go to www.google.com/policies/privacy/partners/. You can learn more
about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.
The internet activity information collected through cookies and other similar means includes
such things as: the domain name and IP address from which you accessed our online and mobile
resources; the type of browser and operating system you use; the date and time and length of
your visit; the specific page visited, graphics viewed and any documents downloaded; the
specific links to other sites you accessed from our online and mobile resources; and the specific
links from other sites you used to access our online and mobile resources.
Additionally, if you access our online and mobile resources from a phone or other mobile device,
the mobile services provider may transmit to us uniquely identifiable mobile device information
which allows us to then collect mobile phone numbers and associate them with the mobile device
identification information. Some mobile phone vendors also operate systems that pinpoint the
physical location of devices and we may receive this information as well if location services are
enabled on your device. If you do not want us to collect and use geolocation data, disable
location services through your device settings.
Regardless, we use both automatically collected information and mobile device information to
compile generic reports about popular pages on our online and mobile resources, and to see how
our customers and followers are accessing our online and mobile resources. We then use that
data to administer the online and mobile resources and make them better, make your activities
more convenient and efficient and to enhance the functionality of our online and mobile
resources, such as by remembering certain of your information in order to save you time.
We use and retain your personal information in accordance with applicable law and as long as
necessary to carry out the purposes described above in accordance with our internal data
retention procedures.
User Beware: External Sites, Apps, Links and Social Media.
We maintain a presence on one or more external social media platforms such as Twitter,
Facebook, YouTube and LinkedIn. We may further allow features of our online and mobile
resources to connect with, or be viewable from, that external social media presence. Similarly,
our online and mobile resources may contain links to other websites or apps controlled by third
parties.
We are not responsible for either the content on, or the privacy practices of, social media
platforms, or any third party sites or apps to which we link. Those apps, sites and platforms are
not controlled by us and therefore have their own privacy policies and terms of use. If you have
questions about how those apps, sites and platforms collect and use personal information, you
should carefully read their privacy policies and contact them using the information they provide.
WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION
We use non-personal information to administer our online and mobile resources, make them
better, and to make business decisions about what programs our customers might like.
We use voluntarily provided personal information to respond to your inquiries and provide you
with the services you have requested, amongst other uses as further described below. We do not
sell or rent your personal information to third party data vendors or marketing companies. As
you might expect, we disclose your information when required by law.
Affiliates.
In addition to those third parties set forth above, we may share your information, including
personal information, within our family of companies including but not limited to Etison, LLC
and Mind Mint, LLC. Those companies will use such information in generally the same manner
as we do under this privacy statement which includes sending you information about their
products, services, or initiatives that may be of interest to you.
Legally Compelled Disclosures.
We may disclose your information, including personal information, to government authorities,
and to other third parties when compelled to do so by such government authorities, or at our
discretion or otherwise as required or permitted by law, including but not limited to responding
to court orders and subpoenas.
To Prevent Harm.
We may disclose your information, including personal information, when we have reason to
believe that someone is causing injury to or interference with our rights or property, other users
of the online and mobile resources, or anyone else that could be harmed by such activities.
Business Transfer.
If we or any of our affiliates, or substantially all of its or their assets, are acquired by one or more
third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or
liquidation, personal information may be one of the transferred assets.
Vendors and Business Partners.
We may share your information, including personal information, with our vendors and other
third parties with whom we have a contractual relationship. We may also share your information,
including personal information, with vendors who provide third party software services that you
have chosen to assist you with your sales funnels. We do our best to disclose only the
information each of those parties need.
We have adopted standards for those vendors and business partners who receive personal
information from us. We attempt to bind such vendors and business partners to those standards
via written contracts. We further attempt to contractually restrict what our vendors and business
partners can do with the personal information we provide to them such that it is used only to the
extent necessary to carry out the business purpose for which it was provided; is not disclosed to
anyone else without our consent or under our instruction; remains, as between us and the
applicable vendor or business partner, our property; and is not transferred out of the United
States without our consent.
Please note, however, that we cannot guarantee that all of our vendors and business partners
will agree to these contractual requirements; nor can we ensure that, even when they do agree,
they will always fully comply.
YOUR RIGHTS AND OPTIONS
You do not have to provide personal information to enjoy most of the features of our online and
mobile resources. Moreover, you can opt out of certain activities like newsletters and
announcements. Residents of California and data subjects whose personal information was
obtained while they were in the GDPR Jurisdictions have certain additional rights.
GDPR Jurisdictions means the countries composed of the European Economic Area, the United
Kingdom (which soon will leave the European Union), Switzerland and Japan which, having
received an “adequacy decision” from the European Commission, adheres to the material terms
of the GDPR.
If we are using personal information you provided to us in order to enable us to send you
materials, such as newsletters or product alerts via text or email, and you decide you don’t want
to receive such materials, you may opt out by following the opt-out instructions in the email or
other communication (e.g., by responding to the text with “STOP”), or by contacting us using the
contact information below. When we receive your request, we will take reasonable steps to
remove your name from our distribution lists. You need to understand it may take a period of
time to remove your name from our lists after your request and due to such latency you may still
receive materials for a period of time after you opt out. In addition to opting out, you have the
ability to access, amend, and delete your personal information by contacting us using the contact
information below.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to
have your online activities tracked. At this time, we do not specifically respond to browser “do
not track” signals.
CHILDREN’S PRIVACY
Federal law imposes special restrictions and obligations on commercial website operators who
direct their operations toward, and collect and use information from, children under the age of
13. We take those age-related requirements very seriously, and consistent with it do not intend
for our online and mobile resources to be used by children under the age of 13 without first
obtaining the verifiable consent of such child’s parent or legal guardian. Moreover, we do not
knowingly collect personal information from minors under the age of 13, only a parent or legal
guardian may provide such information after adhering to our verification process for submitting
such information via the online and mobile resources. If we become aware that anyone under the
age of 18 has submitted personal information to our online and mobile resources, we will delete
that information and will not use it for any purpose whatsoever. If you believe that someone
under the age of 18 has submitted personal information to our online and mobile resources,
please contact us at appsupport@learn.mastermind.com. We encourage parents and legal guardians to
talk with their children about the potential risks of providing personal information over the
Internet.
HOW WE PROTECT COLLECTED PERSONAL INFORMATION
We will take all reasonable security precautions to protect your personal information provided to
our online and mobile resources. We have adopted a security program that includes technical,
organizational, administrative, and other security measures designed to protect, in a manner
consistent with accepted industry standards and applicable law, against anticipated or actual
threats to the security of personal information (the “Security Program”). We cannot, however,
guarantee that your information, whether during transmission or while stored on our systems or
otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or
alteration will not occur. Except for our duty to maintain the Security Program under applicable
law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage
to, or interception of any data or communications including personal information. We have every
reason to believe our Security Program is reasonable and appropriate for our business and the
nature of foreseeable risks to the personal information we collect. We further periodically review
and update our Security Program, including as required by applicable law.
Nonetheless, as part of our Security Program, we have specific incident response and
management procedures that are activated whenever we become aware that your personal
information was likely to have been compromised. We further require, as part of our vendor and
business partner oversight procedures, that such parties notify us immediately if they have any
reason to believe that an incident adversely affecting personal information we provided to them
has occurred.
THE CALIFORNIA CONSUMER PRIVACY ACT
When we collect personal information from California residents we become subject to, and those
residents have rights under, the California Consumer Privacy Act or “CCPA”. This section of our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights.
For purposes of this section, the words “you” and “your” mean only such California residents.
What did we collect from California Residents?
We collect the following categories of personal information: identifiers such as name, address,
IP address, and other similar identifiers; personal information described in subdivision (e) of
Section 1798.80 (California customer records statute) such as a name, address, telephone
number, credit card number; commercial information such as products or services purchased;
internet/electronic activity such as browsing history and search history; geolocation data
including geographic coordinates/physical location; and audio, video, electronic or other similar
information. We may disclose this information for one or more business purposes permitted by
the CCPA. We do not sell, and within the last 12 months have not sold, personal information to
third parties.
Rights of California Residents
You have the following rights under the CCPA, in summary disclosure, access and delete. More
information can be found here. It’s important to us that you know that if you exercise these
rights, we will not “discriminate” against you by treating you differently from other California
residents who use our sites and mobile resources or purchase our services but did not exercise
their rights.
You can exercise these rights up to two different times every 12 months. To do so, just contact us
at appsupport@learn.mastermind.com or 1-888-411-0243. We may ask you to fill out a request form.
The CCPA only allows us to act on your request if we can verify your identity or your authority
to make the request so you will also need to follow our instructions for identity verification.
If you make a verifiable request per the above, we will confirm our receipt and respond in the
time frames prescribed by the CCPA.
THE EU GENERAL DATA PROTECTION REGULATION
We do collect or otherwise obtain personal information from data subjects located in the GDPR
Jurisdictions. We fulfill our GDPR obligations with respect to our workforce/job applicants, our
customers (and their own end-clients), and our vendors and business partners through a series of
separate notices, contracts or other terms provided to them at the time, and in the manner and
form, GDPR and local law within each GDPR Jurisdiction requires.
We describe, in the immediately following section of this statement, how we comply with the
GDPR for personal information collected from visitors to and users of our online and mobile
resources while they were in a GDPR Jurisdiction. Thus for purposes of that section, the words
“you” and “your” mean only such GDPR Jurisdiction-based visitors and users.
What do we collect from you in the GDPR Jurisdictions and how do we use it?
We collect from you the categories of personal information already described. The lawful basis
on which we rely for such collection, later use and disclosure, is what the GDPR refers to as
legitimate interest. As stated elsewhere in this statement, we do not sell any of your personal
information to third parties nor do we use it for automated decision making.
Cross-border Data Transfers and Third Party Processors
If we transfer personal information from the GDPR Jurisdictions to a location that has not been
deemed by the European Commission to have adequate privacy protections, we do so in the
manner the GDPR permits.
Rights of Data Subjects in the GDPR Jurisdictions
While we attempt to allow all visitors and users of our online and mobile resources to exercise a
degree of control over their personal information, under the GDPR we have a legal obligation to
do so for you. More specifically, with respect to personal information collected from you while
you were in a GDPR Jurisdiction, you have these rights: transparency, access, correction and
deletion, portability, who, what, why and where, and restriction/objection (for more information
click here).
If you would like to exercise any of these rights, please contact appsupport@learn.mastermind.com.
Your ability to exercise these rights is subject to certain conditions and exemptions that you can
read about in Articles 12 through 23 of the GDPR. Among those conditions is our right to
decline part or all of a request if we cannot satisfy our reasonable doubts and concerns about
your identity in a manner that helps us minimize the risk that unauthorized persons might use a
GDPR right to access your personal information. We will respond to all requests without undue delay,
and in accordance with the time frames, if any, prescribed by the GDPR. If you are not satisfied
with how we use your personal information or respond to your requests, you have the right to
complain to your data protection regulator. Contact information for the EU data protection
regulators can be found here.
RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS
In other jurisdictions, with similar data privacy regulations, we may collect from you the
categories of personal information already described. We collect and manage (including
disclose) such data in compliance with applicable local law(s). As noted, we do not sell any of
your personal information to third parties nor do we use it for automated decision making.
CHANGES TO THIS PRIVACY STATEMENT
This privacy statement was drafted on July 30, 2020 and is effective as of this date. The English
language version of this privacy statement is the controlling version regardless of any translation
you may attempt.
We reserve the right to change or update this statement from time to time. Please check our
online and mobile resources periodically for such changes since all information collected is
subject to the statement in place at that time.
CONTACTING US
If you have questions about our privacy statement or privacy practices, please contact us at:
Mastermind Consulting, LLC
Attn: Legal & Compliance Department
2225 N Scottsdale Road
Scottsdale, AZ 85257
appsupport@learn.mastermind.com