Mogy Privacy and Cookie Policy

v.2019.01
Effective October 1, 2019

APPROVED is the licensing division of Buckley LLP, a limited liability partnership organized under the laws of the District of Columbia and has offices in Washington, D.C., Los Angeles, San Francisco, New York, Chicago, and London (collectively “Buckley” or “we”, “our”, “us”).

This Privacy & Cookie Policy (“Privacy Policy”) describes the personally identifiable and other information that Buckley collects through its proprietary licensing software, Mogy, at mogy.approvedlicensing.com and equivalent domains (the “Site”). This Privacy Policy applies solely to Buckley’s collection of information through the Site and our use of that information and does not apply to our offline practices.

Information may be shared by and between Buckley in the United States and in the United Kingdom. Buckley is the data controller for the processing of such information for purposes of the UK Data Protection Act 2018.

Together with the Mogy Terms of Use Agreement, this Privacy Policy provides you with important information regarding your rights and obligations, and explains how, why and when we collect and process your personal identifiable information. Please read this Privacy Policy carefully before using or registering to use this Site. By visiting the Site, you are accepting and consenting to the practices described in this Privacy Policy.


INFORMATION WE COLLECT

The type of personal information the Site collects depends on the business relationship Buckley has with you and the nature of your business activity. In general, the type of personal information falls into two categories – personally identifiable information and non-personally identifiable information (as further detailed below).

In either case, the Site may process or receive information from third-party sources to supplement Buckley records, improve quality of services, or prevent or detect fraud. For example, the Site may process information from State or Federal Regulatory Agencies (“Agency” or “Agencies”) in conjunction with license applications through the Nationwide Multistate Licensing System (“NMLS”).

A. Personally Identifiable Information

The Site does not collect personally identifiable information about you, such as your name, physical address, email address, and telephone number and/or sensitive personally identifiable information about you such as social security number, criminal history records, financial records, unless you voluntarily provide us this information. We may add certain of the information you voluntarily provide to us to our databases, subscriber lists, and contact lists.

Please see “Contact Us; Opt-Out” below if you decide that you no longer wish to receive our materials. On rare occasions, though, we may email users important administrative information regarding the Site or services because such information may be important to your use of the Site. It may not be possible to “opt out” of receiving these types of emails.

B. Non-Personally Identifiable Information

This Site automatically collects non-personally identifiable information from you when you use the Site. This information is collected through cookies and may include, without limitation, the following: your internet service provider, the type of browser and operating system that you use, and information about your Site visit, including date and time, length of stay, pages viewed, the website address, if any, from which you linked directly to the Site, the website address, if any, to which you travel from the Site, and other traffic information.

We use this non-personally identifiable information to help us improve the Site and the services we provide through it. We may do this by aggregating your non-personally identifiable information with similar information collected from other users.

C. IP Address

We also use cookies to collect the IP (Internet Protocol) address of your computer automatically when you visit the Site. We do not use your IP address to identify you personally. You can restrict or block our use of cookies to collect your IP address and for other purposes as discussed below.


COOKIES

A. Overview

The Site uses cookies, which are small files sent from the Site to your browser or your computer, tablet, or mobile phone (“device”) and then stored on your device’s hard drive. A cookie records on your device information relating to your internet activity, such as whether you have visited the Site before.

We use the cookies to support Site functionality. We may also use them to collect statistical information that we analyze for insights on Site usage. We do not use the cookies to collect any personally identifiable information about you.

You can use your browser’s settings to restrict or block the cookies sent by the Site. This would not prevent you from using the Site.

B. Cookies That Collect Statistical Information

We may use cookies from Google Analytics, a web-analytics service provided by Google Inc., to understand how visitors use the Site.

The Google Analytics cookies collect information about, among other things, which pages are visited the most often, how people move from one link to another, and when users get error messages. The cookies do not gather any information that identifies you. We may aggregate your usage information from these cookies with information from other users on an anonymous basis to gather analytical data on Site performance and in support of potential improvements.

In addition to using your browser settings to restrict or block this Site’s use of Google Analytics cookies, you can restrict or block their use by every website you visit. To do this, visit this Google page.


OUR USE OF PERSONALLY IDENTIFIABLE INFORMATION

We limit our use of your personally identifiable information to your specific needs or requests and to meet business or legal needs in connection with the services the Site provides. In particular, we use personally identifiable information collected by this Site to:

  • Fulfill subscription services you request;
  • Communicate with you regarding membership, licensing, registration and events;
  • Provide customer and operations support, including responding to your inquiries and comments;
  • Verify user identity or information for licensing or registration;
  • Comply with laws and government regulations;
  • Allow you to provide such information to Agencies for the issuance and maintenance of a license or monitor registration on behalf of Agencies, and disseminate data as required by law or regulation, including to the Nationwide Multistate Licensing System & Registry (NMLS);
  • Protect the security and integrity of this Site websites and our business; and
  • Administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.


OUR DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION

Generally, we do not disclose personally identifiable information collected through the Site to unaffiliated third parties without your consent. However, we reserve the right to may provide this information to our employees, contractors, agents, and designees so that they can perform Site-related services on our behalf.

We also may disclose such information to a third party if we believe that we are required to do so: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or our network; or (iv) to protect the rights, property, or safety of Buckley and its affiliates, their partners, members, and employees, users of the Site, or the public.

Buckley reserves the right to transfer any and all information we collect from users, or that we otherwise collect in connection with the Site, including, without limitation, to unaffiliated third parties, in the event of a sale or transfer of assets or portion of our business.

Where We Store Personally Identifiable Information

The personally identifiable information that you give us or that we collect from you may be transferred, stored, or processed outside the European Economic Area. By submitting this information to us, you agree to this transfer, storing, or processing. We take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.


SECURITY

Buckley employs industry-standard security measures designed to protect against loss, misuse, or alteration of personally identifiable information under our control, but no security system, or system of transmitting data over the internet, is 100% secure. For that reason, we do not guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Site.

In the event Buckley becomes aware of a security or privacy breach which it believes has resulted or may result in the unauthorized access, use or disclosure of personally identifiable information Buckley will promptly investigate the matter and notify the applicable individuals and/or Agencies of such breach. The investigation and notification will comply with relevant legal requirements and be undertaken without delay while also taking into consideration: (1) legitimate needs of law enforcement; (2) measures necessary to determine the scope of the breach; (3) efforts to identify the individuals affected; and (4) steps to restore the reasonable integrity of the Site. Buckley will work diligently with all applicable Agencies to coordinate notification of affected individuals and any other parties of any breach, in accordance with applicable law or regulation.


LINKS TO OTHER WEB SITES

The Site may contain links to websites owned by third parties. We are not responsible for the privacy practices of these third parties, and any information you disclose on their sites is not subject to this Privacy Policy. You should consult the privacy policies of each website you visit. A link on this Site to one owned by a third party does not constitute endorsement, approval, association, sponsorship, or affiliation with the linked site unless specifically stated.


CHILDREN UNDER 13

The Site is not directed to children under 13 years of age, from whom we do not knowingly collect personally identifiable information. We ask that users younger than 13 not provide any personally identifiable information while using the Site.


CHANGES TO PRIVACY POLICY

We reserve the right to update, revise, or otherwise change this Privacy Policy at any time, and any changes to the Privacy Policy will be effective upon posting. Use of the Site constitutes acceptance of the currently posted Privacy Policy, and users should review this Privacy Policy regularly to ensure that they are aware of its terms.


ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION

You may request a copy of the information that we hold about you by emailing mogyadmin@approvedlicensing.com. We may charge a fee toward the costs we incur in providing you with the information.


CONTACT US; OPT-OUT

If you would like to update or otherwise change the personally identifiable information you have provided to us, or if you no longer wish to receive materials from us or want your personally identifiable information removed from our databases, please contact us at mogyadmin@approvedlicensing.com Alternatively, when you receive materials from us by email, you may make use of any other “opt out” instructions we provide to stop receiving materials from us.

If you have any questions about this Privacy Policy or our collection and use of your personally identifiable information, please contact us at mogyadmin@approvedlicensing.com.