Privacy Policy

Last updated: May 22, 2018

The Molly Sapp Group LLC understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you, and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

  • Account – An Account required to access and/or utilize certain areas/features of Our Site.
  • Cookie – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
  • Our Site – this website, MollySapp.com
  • UK and EU Cookie Law ­– the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
  • We/Us/Our – The Molly Sapp Group LLC, a limited company registered in USA under 08506940, whose registered address is 210 Darwin’s Way, Lakeway, TX 78734 USA
  1. Information About Us
    1. Our Site, com, is owned and operated by The Molly Sapp Group LLC, a limited company registered in USA , whose registered address is 210 Darwin’s Way, Lakeway, TX 78734 USA
  1. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

  1. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies), other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

  1. Name;
  2. Business/company name;
  3. Contact information such as email addresses and telephone numbers;
  4. Demographic information such as zip/post code, preferences and interests;
  5. Financial information such as credit / debit card numbers;
  6. IP address (automatically collected);
  7. Web browser type and version (automatically collected);
  8. Operating system (automatically collected);
  9. A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
  10. Browsing behavior within Our Site to optimize our user experience.

 

  1. How Do We Use Your Data?
    1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679)(GDPR). For more details on security see section 6, below.
    2. We use your data to provide the best possible products and services to you. This includes:
      1. Providing and managing your Account;
      2. Providing and managing your access to Our Site;
      3. Personalizing and tailoring your experience on Our Site;
      4. Supplying Our products and services to you;
      5. Personalizing and tailoring Our products and services for you;
      6. Responding to communications from you;
      7. Supplying you with email communication that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of every email we send);
      8. Market research;
      9. Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
    3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
    4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or direct mail with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
    5. Advertisers whose content appears on Our Site may engage in what is known as “behavioral advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
    6. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
      1. you have given consent to the processing of your personal data for one or more specific purposes;
      2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
      3. processing is necessary for compliance with a legal obligation to which we are subject;
      4. processing is necessary to protect the vital interests of you or of another natural person;
      5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
      6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. For example, we may contact you via email about a product or service related to the same topic as a free PDF document you previously requested.
  1. How and Where Do We Store Your Data?

 

  1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it.
  2. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
  3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
  4. Steps We take to secure and protect your data include:
    1. Using HTTPS (SSL) browsing wherever possible.
    2. Using up-to-date anti-virus and anti-spyware software on all company devices.
    3. Strictly no sharing of company devices with third parties.
  5. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

 

  1. Do We Share Your Data?
    1. We may share your data with other companies in Our group. This includes Our subsidiaries and/or future subsidiaries.
    2. We may contract with third parties to supply products and services to you on Our behalf. These may include – but is not limited to – payment processing, delivery of goods, search engine facilities, conversion optimization, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
    3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties such as employees, freelancers, prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
    4. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
  1. What Happens If Our Business Changes Hands?
    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
    2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted, you will, however, be given the choice to have your data deleted or withheld from the new owner or controller.
  1. How Can You Control Your Data?
    1. When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by contacting us.
  1. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
    1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
    2. You may restrict your internet browser’s use of Cookies. For more information, see section 12.
    3. You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
  1. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details, or using the contact details below in section 14.

  1. What Cookies Do We Use and What For?

 

  1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products.

 

For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

  1. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for advertising services, tracking user behavior to provide a better experience, and conversion tracking to improve our marketing. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.
  2. All Cookies used by and on Our Site are used in accordance with current US and EU Cookie Law.
  3. Before any Cookies are placed on your computer or devicesubject to section 12.5 AND/OR section 12.8, you will be shown a message bar detailing your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
  4. Certain features of Our Site depend on Cookies to function. United Kingdom and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
  5. The following first party Cookies may be placed on your computer or device and used:

 

  • To only track unique sales conversions, avoiding duplicate sales reporting within our advertising campaigns.

 

  • To retain your login information for Our Site, allowing you to access any product(s) and service(s) you have purchased, and/or exclusive members-only content.

 

And the following Third-Party Cookies may be placed on your computer or device:

 

Google Analytics – To track browsing behavior on our website, so we can improve our marketing and user experience.

 

Facebook To track and report conversions within our Facebook Ads Manager, so we can provide a more optimized advertising campaigns.

 

Sumo – Sumo uses cookies to control many different things in user’s browsers. These cookies control everything from determining if a visitor is opted-out of a certain popup to telling Sumo whether or not to display a Welcome Mat or Smart Bar.

 

  1. Our Site uses analytics services provided by Google Analytics, Sumo, and Facebook. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
  2. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Some of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
  3. The analytics service(s) used by Our Site use(s) the Cookies described in section 12.6.
  4. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
  5. You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalization settings.
  6. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

  1. Summary of Your Rights under GDPR

Under the GDPR, you have:

  • the right to request access to, deletion of or correction of, your personal data held by Us;
  • the right to complain to a supervisory authority;
  • be informed of what data processing is taking place;
  • the right to restrict processing;
  • the right to data portability;
  • object to processing of your personal data;
  • rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

 

  1. Automated Decision-Making and Profiling

14.1       In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

14.2 The right described in section 14.1 does not apply in the following circumstances:

  1. The decision is necessary for the entry into, or performance of, a contract between the You and Us;
  2. The decision is authorized by law; or
  3. You have given explicit consent.
  • Where we use your personal data for profiling purposes, the following shall apply:
    1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
    2. Appropriate mathematical or statistical procedures will be used;
    3. Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and
    4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
  • We currently make the following automated decisions:

14.4.1    To check if you have already purchased a product and/or service from us, then display relevant paid offers to avoid repeat purchases of the same product and/or service.

14.5 We currently profile your personal data for the following purposes:

14.5.1   To provide tailored marketing to you regarding our content, products and services.

 

 

  1. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact us. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

 

  1. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Also…

Security
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer
Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy
Only persons age 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Contact Us
If you have any questions about this Privacy Policy, please contact us.