Privacy Policy

 Last Updated: August 24, 2022

P. Marshall & Associates, LLC (“P. Marshall & Associates, LLC,” “we,” or “us”) respects privacy and is committed to protecting personal information.  This Privacy Policy (the “Policy”) explains our practices for handling information we may collect and use about website visitors, customers, business partners, and others with whom we interact in providing our services.  This Policy applies to information you provide to us through our website, pmass.com (the “Site”), when you communicate with us, and through our other interactions with you.  It describes the types of personal information we may receive, how we may use and disclose the information, and certain rights and options individuals may have regarding their information.  Use of our Site is also subject to our Terms of Use, which are available here.

Important Information About This Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements.  As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information. 

To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate that you keep us informed of this so we can amend our records accordingly.  By providing us with personal information or using our website, you expressly consent to the information-handling practices described in this Policy.  If you do not agree with this Policy, please do not use our website or provide us with your information.

Information We Receive

A. Personal Information

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual.  Because we are a business-to-business company, the types of personal information we collect are typically limited to the types of information contained in a business card—name, job title, business email, address, and phone number.  Specifically, the personal information we receive can be categorized as follows.

  • Contact information – first name, last name, email address, position, physical address of your organization, billing address, and telephone number.
  • Customer account information – customer ID, account username, account password, account number, and other information that we may request or that you may provide relating to your account.
  • Transactional information – details about your organization’s transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to the services purchased by your organization.
  • Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
  • Communication information – copies of communications and inquiries you have submitted to us, including through email, calls, and features available on our Site.
  • Device and usage information details regarding how and when you use our Site, including the device used to connect to our Site or software, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our Site.

We collect this information when you visit or navigate our Site, fill in forms on our Site, submit orders or engage in transactions with us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”  We may also collect information about you from third-party sources and information about you that is publicly available.  

B. Automatically Collected Usage and Device Information

Like most websites, our Site uses various technologies to automatically collect information about visitors.  Those technologies include:    

  • Cookies.  Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes.  We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our Site traffic.   For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.  Please note that if cookies are disabled, you may not be able to enjoy certain features of our Site.
  • Log Files and Device Identifiers.  We use log files to track actions occurring on the Site and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
  • Web beacons and other technologies.  Our App may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users.  Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
  • Analytics.  Our Site may also use third-party analytics tools such as Google Analytics.  You can find more information about how data is collected and processed in connection with the Google Analytics service here.  You can also read Google’s privacy policy here.

The information collected through these technologies may be combined with personal information or aggregated with other information on Site visits.  We may share information about your use of our Site with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

C. Information from Other Sources

We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to other information we have collected.  We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources.  This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

How We Use Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

  • Negotiating, entering into, and managing our business relationship and agreements with your company, including providing our services and processing payments from your company.  
  • Providing and optimizing your experience on our Site and ensuring that our content is presented to you in the most effective manner. 
  • Communicating with you and responding to your inquiries and communicating regarding our services, our agreements with your company, and other issues.
  • Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
  • Managing customer service issues, including issues relating to the performance of our services and customer feedback.
  • Developing, updating, and improving our services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding customers.
  • Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Site or the purchase or use of our services.
  • Enforcing our agreements with customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
  • Notifying you about changes to our Site, services, or material changes to this Policy.
  • Providing you with surveys or otherwise soliciting feedback from you.
  • Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Choices About the Collection and Use of Personal Information” below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

In addition, we may share your information with the following types of entities:

  • Business partners, service providers, and third-party vendors necessary for the performance of any contract we enter into with you. For example, our IT providers, secure payment processing providers on the Site, shipping providers, customer contact center services, insurance providers and document storage providers.
  • Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information only to perform specific tasks on our behalf and are obliged not to disclose or use it for any other purpose. For example, our service providers include (i) IT and system administration providers, (ii) data storage providers, and (iii) vendors to facilitate payments and payment processing.
  • Marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
  • Analytics vendors in order to understand our Site traffic and usage patterns, optimize our Site, and identify potential new clients.
  • Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
  • Our professional advisors, such as lawyers, accountants, and other similar advisors. 
  • Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
  • Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Your Choices About Personal Information

We respect your right to make choices about the ways we collect, use, and disclose your information.  We try to offer you meaningful choices regarding your personal information.  Some choices you have regarding personal information include the following.

  • Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out” link in any such promotional emails and following the instructions provided. 

  • Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies.  Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Site.

  • Google Analytics – As discussed above, we use Google Analytics in connection with the Site.  If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use.  You can find more information on how Google uses information it collects here.
    • Interest-Based Advertising – To opt-out of personalized or interest-based advertisements, you may be able to adjust the settings on your device.  Please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, has its own instructions on how to prevent the delivery of interest-based advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.  You can also visit https://optout.aboutads.info to opt out of interest-based advertisements.

  • Declining to Provide Information – You can choose not to provide us with information we may request through our Site, but that may result in you being unable to use certain features of our Site, request information about our Services, or initiate other transactions with us
  • Do Not Track Mechanisms – Please note that our Site does not honor “Do Not Track” signals, and such signals will not impact the operation of this Site.  

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Links to Third-Party Websites

Our Site may contain links to third-party websites.  Such websites have separate privacy policies that you should review.  We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.

Rights Afforded to Certain Individuals

A. California Residents

If you are a California resident, please refer to our “Privacy Notice for California Residents” for a description of rights available to you under California law.

B. Canadian Residents

If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), may provide you certain rights with respect to your personal information, including the right to request information about the collection, use, or disclosure of your personal information, to request access to your personal information, and to challenge the accuracy and completeness of your personal information and have it amended as appropriate. 

If you are a Canadian resident and would like to make a request regarding your personal information, please send a request to law@clinellc.com with the subject line, “Canada Resident Request,” or otherwise contact us using the information in the “How to Contact Us” section below. We will attempt to respond to your request as quickly as possible, but may ask you to provide additional information to enable us to locate the personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you. 

International Transfers

P. Marshall & Associates, LLC is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States.  You understand and consent that information you provide may be transferred to the United States.  You also understand that the data protection laws in the United States may be different from those of the country where you reside.  When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.

Children’s Privacy

Our Site is a general audience site and is not directed at, or intended for use by, children under the age of 16 years.  Accordingly, we do not knowingly collect personal information from children under age 16.  Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information. 

Data Storage and Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.  We also consider any specific limitation periods under applicable law.  

Changes to this Policy

Please note that we may change this Policy from time to time.  If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this Site after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Policy periodically for updates.

How to Contact Us

For questions or more information about our privacy practices, please contact us by e-mail at law@clinellc.com or by using the contact information provided below:

P. Marshall & Associates, LLC

c/o [position or dept. to which privacy-related communication should be directed]

law@clinellc.com