Personal Data Defined
For purposes of this Policy, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is a human being who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Information We Collect and How We Collect It
Information You Provide
If you provide us with personal data, we may use that information for the purpose for which you provided it. In some jurisdictions, individuals may have the right to withdraw consent to certain uses of personal data. If you reside in such jurisdictions, you may withdraw your consent as detailed in the section entitled “How to Access, Update and Manage Your Information.”
Information We Collect Automatically
• When you visit the Site, we may automatically collect and store certain data that cannot not identify you personally. Such data may include:
• Internet Protocol (IP) address;
• Type of browser and operating system accessing our Website;
• Date and time you accessed the website;
• Pages on the website you access;
• The address of a referring website (if linked from a third party);
• Cookies; and
• Web beacons.
In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data. We may also use anonymized or aggregated information for statistical analysis, research, and other purposes.
How We Use the Information We Collect
We primarily use the information that we collect to provide you with information, products, and services. Specifically, we may use the information we collect from, and about, you (including your personal data) for any of the following purposes:
• To fulfill your requests for our products and services;
• To respond to your inquiries;
• To operate, improve and optimize the Site, our business or our services;
• To review Site usage and operations;
• To address problems with the Site, our business or our services;
• To protect the security or integrity of the Site and our business;
• To monitor the Site for compliance with our terms and conditions and the law;
• To notify you of new services, updates, newsletters and other informational and promotional materials from us;
• To comply with our legal obligations, resolve any disputes we may have with you or others, and to enforce our agreements with third parties; and
• To conduct research.
With Whom We Share Your Information
With Your Consent
We may disclose information collected from, and about, you (including your personal data) with companies, organizations or individuals outside of MS2, with your express consent. We may also share aggregated, anonymized data about Site users with third parties.
For External Processing
For Legal Reasons
We may share information collected from, and about you (including your personal data) with companies, organizations or individuals outside of MS2 if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
• Comply with any applicable law, regulation, legal process or enforceable governmental request;
• Respond to legal process (such as a search warrant, subpoena or court order);
• Enforce our terms of service, including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, security or technical issues; or
• Protect against harm to the rights, property or safety of MS2, third parties, our customers, or the public as required or permitted by law.
We may disclose your personal data to another entity to:
• Outsource a legitimate business function;
• Confirm or update information you provided;
• Notify you of events, and information about our services;
• For other purposes, if disclosed at or before we collected the information; and
• To comply with a legal obligation.
How Long We Keep Your Information
How long we retain your information depends on why we collected it and how we use it. We will not retain your personal data for longer than is necessary for our business purposes or for legal requirements (unless otherwise provided in agreements between you and us).
How to Access, Update and Manage Your Information
Access, Correction, and Deletion
We respect your right to access and correct your personal data. You may exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain certain records, for example those relating to inquiries or customer service matters, for legal and accounting purposes and this will be explained to you if necessary.
If you need assistance correcting or updating your personal data, please contact us using the contact information detailed in the “Contact Us” section below.
Opting Out of Promotional Emails
If you do not wish to receive communications from us about updates and services, you can opt-out of receiving those communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications.
Like many commercial websites, we analyze how visitors use our Site through what is known as "cookie" technology. A cookie is a small text file that is placed on your computer when you access the Site which allows us to recognize you each time you visit the Site.
• Monitor Site usage;
• Manage the Site; and
• Improve the Site and our services.
If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Site, or that we may put on our Site in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.
You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow.
The Site uses web analytics tools provided by Google Analytics. We reserve the right to use other analytics tools in the future.
Security of Your Information
We have adopted and maintain measures designed to handle information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the information we collect from Site visitors. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
Our Policies Concerning Children
We do not intentionally gather Personal Data about Users who are under the age of 13. If we become aware that we have collected Personal Data from a child under the age of 13, we will make reasonable efforts to delete such data from our records.
Third Party Websites
The Site may contain links to third-party websites which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on those websites. Accordingly, we recommend that you review the privacy statement posted on any external site you access before disclosing any personal data. Please contact those websites directly if you have any questions about their privacy policies.
Visitors from Outside the United States—Cross-Border Transfer of Information
Midwestern Software Solutions, LLC
5200 S. State Street, Suite 100
Ann Arbor, MI 48108
If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.
Revised February 2020