Last Updated: May 28, 2020

This Privacy Policy explains how information about you is collected, used and disclosed by Messina Group, Inc., (“TMG”). This Privacy Policy applies to information we collect when you use themessinagroup.com (the “Site”).

TMG understands that your privacy is important and is committed to protecting your privacy and the personal information you provide or as you access and use materials on the Site, including the Site subscription pages or other websites or apps that post a link to this Privacy Policy. In addition, information that you submit to TMG in response to an email request for information or other outreach from TMG, or through TMG’s employment application processes, will be treated in accordance with this Privacy Policy. TMG does not take responsibility for the privacy practices of any third party sites to which we link. We encourage you to review the privacy policies of any such sites before you submit information there.

TMG may change this Privacy Policy from time to time in its discretion. If we make material changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy whenever you access the Site to stay informed about our information practices and the ways you can help protect your privacy.

Collection of Information

Information You Provide to Us:

We collect information you provide directly to us. For example, we may collect information when you fill out a form, request information, leave a comment, send us an email, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include: your name, email address, postal address, phone number, demographic information, and other contact or identifying information you choose to provide.

Information We Collect Automatically When You Use the Site:

When you access or use our Site, we automatically collect information about you, including:

• Log Information: We log information about your use of the Site, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Site.
• Device Information: We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers and mobile network information.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect and analyze information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Site and your experience, see which areas and features of our Site are popular and count visits and track and analyze your activity. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Site or emails and help deliver cookies, count visits, track your activity, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information We Collect From Other Sources:

We may also obtain information from other sources and combine that with information we collect through our Site.

Use of Information

We may use information about you for various purposes, including to:

• Provide, maintain and improve our Site;
  Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by TMG and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with our Site;
• Personalize and improve the Site and provide advertisements, content or features that match user profiles or interests;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected.

TMG is based in the United States and US law governs the information we collect. By accessing or using the Site or otherwise providing information to us, you consent to the processing and transfer of information in and to the US and other countries.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
• When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of TMG or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction, including if we notify you through our Site that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or anonymized information that does not directly identify you.

Advertising and Analytics Services Provided by Others

We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Site and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by TMG and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site and other websites and better understand your online activity.

For example, we may use Google Analytics for Display Advertising and Remarketing with Google Analytics or other remarketing tools to advertise online. This enables third-party vendors, including Google, to show our ads on sites across the Internet. Such third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our Site. If you don’t want your data collected with Google Analytics, you can opt out by visiting the Google Analytics opt-out page and installing the add-on for your browser. You can also customize Google Display Network ads using the Ads Preferences Manager.

Some of these activities may be considered “sales” under California law. You can find instructions on how to opt out of sales in the relevant section below.

Security

TMG takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Links to Other Web Sites
This website contains links to other web sites not operated by TMG. TMG is not responsible for the privacy practices or the content of any non-TMG web sites to which we link from the Site. We are not responsible for the protection and privacy of any information you provide while visiting other websites and sites not governed by our Privacy Policy. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.

Access Rights
In accordance with applicable data protection laws, including but not limited to the European Union’s General Data Protection Regulation, you have a right to request a copy of the personal information we hold about you and details of how we use that information. If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it, please follow the process outlined below and we will amend our records where appropriate. You also have the right to require us to erase your personal data, stop processing your personal data, restricting the processing of your personal information, right of portability of your personal information and/or to withdraw your consent to processing. This may not apply if there are other legal justifications to continue processing. If you think we may have incorrect personal information, or would like a copy of the personal information we hold on you, or to exercise any other data protection right, please contact us at info@themessinagroup.com. Please note that we need you to prove who you are before we can provide you with any information. You also have a right to lodge a complaint with a relevant supervisory authority.

Children

TMG understands the importance of protecting children’s privacy, particularly in their online interactions. This Site is not designed for and does not intentionally target or solicit to children 18 years of age and younger.

Your Choices

Promotional Communications
In order to receive promotional messages from TMG, you must opt-in and confirm your email address to be subscribed to our list. You may opt out of receiving promotional messages from TMG by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site.

California Privacy Rights

If you are a California resident, please review these additional privacy disclosures, which provide a summary of how we collect, use, and disclose personal information about you and explain your rights under California law.

Categories of Information We Collect, Use, and Disclose for Business Purposes
We collect the information as described in “What information does TMG obtain and how do we use customer information?” above. In the prior 12 months, we have collected the following categories of personal information:

• Identifiers, such as name, email address, mailing address, cookie and device identifiers, and IP address.
• Demographic information, such as your gender and age.
• Internet or other electronic network activity information, such as log data and information about the devices and computers you use to access our websites.
• Professional or employment-related information and education information, when you apply for a job with us.
• Other information you provide, such as responses to surveys.
• Inferences drawn from any of the above, including the content or ads that may be of interest of you.

We collect this information from you, your devices, third parties, or as otherwise described in this Privacy Policy. We use these categories of personal information as described in “Use of Information” above. We disclose these categories of Personal Information for the business purposes described in “Sharing of Information” above.

Your Rights as a California Resident
Under the California Consumer Privacy Act (CCPA), California residents have the right to request access to or deletion of their personal information, to request additional details about our information practices, to opt out of the “sale” of personal information (if applicable), and to not be discriminated against for exercising their rights. To request to exercise your access or deletion rights, please email us at info@themessinagroup.com or send a request to 1155 Connecticut Avenue, N.W., 4th Floor, Washington DC 20036. Upon receipt of your request to exercise your rights to access or delete your personal information, we will verify your identity to protect your security and privacy. Note that even if we honor your request to delete your information, we may retain certain information as required or permitted by law.

Other Privacy Rights

TMG operates globally and may need to transfer personal information that is collected on the Site or through other means to various TMG offices to operate our business efficiently. This could include third parties located in different countries around the world, including the United States, the European Economic Area, Asia, Africa, and Latin America. These arrangements may involve your personal information being located in various countries around the world where privacy laws differ. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect information held in that country. In addition, the Site may be viewed and accessed anywhere in the world including countries that may not have laws regulating the use and transfer of personally identifiable information. By using the Site, submitting information through this site, or submitting personal information to TMG through other means you voluntarily consent to such international transfer and hosting of such information to those countries and parties.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: info@themessinagroup.com.