Privacy Policy

Privacy Policy

Effective as of July 25, 2020

Table of Contents:

1. Scope and Application

What and who this Policy covers

2. Collection of Information

The sources of and methods by which we, our service providers, and our advertisers collect information from and about you, including information about your interaction with MOHS Training.

Use and Disclosure

How we use the information we collect from and about you, and who we might share it with and why.

3. Security

How we protect your information from loss or misuse

4. User Access and Control

How you can access and control the information we maintain about you

5. Other Important Information

Other things you should know about this Policy and how we handle your information

6. Contact Us

How to contact MOHS Training about this Policy

7. California Consumer Privacy Act Notice

Other things you should know if you reside in California

1) Scope and Application

MOHS Training, (“MOHS Training” or “we” or “our” or “us”) wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with information collected through our services such as websites, mobile sites, applications (“apps”), and widgets (collectively, the “MOHS Training Services”). For example, Services include services and content relating to MOHS Training, and any other MOHS Training service linking to this Privacy Policy. California residents, please see the California Consumer Privacy Act Notice in Section 8 below. at https://mtf.mohstraining.com .


MOHS Training Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.


This Privacy Policy applies to all users, including both those who use the MOHS Training Services without being registered with or subscribing to a MOHS Training Service and those who have registered with or subscribed to a MOHS Training Service. This Privacy Policy applies to our collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes generally our practices for handling certain categories of information that we do not connect to your MOHS Training account or profile

2) Collection of Information

MOHS Training and our service providers may collect the following information from and about you:

Registration Information is the information you submit to register for MOHS Training Services, for example, to create an account, post comments, receive a newsletter, or enter a contest or sweepstakes. Registration Information, depending on the specific service, may include, for example, name, email address, gender, zip code, household income, political views, and birthday.

Public Information and Posts consist of comments or content that you post to the MOHS Training Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.

Information from Social Media. If you access or log-in to a MOHS Training Service through a social media service or connect a MOHS Training Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the MOHS Training Services through social media services or when you connect a MOHS Training Service to social media services, you are authorizing MOHS Training to collect, store, and use such information and content in accordance with this Privacy Policy.

Activity Information. When you access and interact with the MOHS Training Services, MOHS Training and its service providers may collect certain information about those visits. For example, in order to permit your connection to the MOHS Training Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, location (including your precise location), browser type, cookies, and other software or hardware information.Our websites use cookies and other tracking technologies (such as browser cookies, localStorage, pixels, beacons, and Adobe Flash technology including “Flash” cookies) to store or transmit small pieces of data, such as IP address, account information, unique identifiers, and other information. Our websites use these technologies to remember your browser, distinguish you from other users, deliver our services to you as described in this Privacy Policy, and for interest-based advertising. If you access the MOHS Training Services from a mobile or other device, we may collect a unique device identifier associated with the device or other information related to that device and network.

Other parties that support us by serving advertisements or providing services, such as allowing you to share content or to track aggregate usage statistics, may also use these technologies to collect similar information when you use our services or other parties’ services. Those parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. MOHS Training does not control these parties’ technologies. Their use is governed by the privacy policies of the parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.

Your browser may be initially set to accept cookies, but most browsers allow you to change your settings and to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Users can manage the use of Flash technologies with the guidance available at Adobe’s website, see www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the MOHS Training Services. Cookie blocking may also disable privacy choices you make that rely on cookies.

Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, commercially available sources, and information from our Company Affiliates or business partners.

Do Not Track Signals. At this time we do not respond to browser ‘Do Not Track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.


3) Use and Disclosure

We may use the information we collect from and about you to provide the MOHS Training Services and features to you, including: to measure and improve those Services and features and to develop new products and services; to improve your experience with both online and off-line MOHS Training Services by delivering content you will find relevant and interesting, including advertising and marketing messages; to allow you to comment on content, and participate in online games, contests, other promotions, or rewards programs; to provide you with customer support and to respond to inquiries. In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with other parties, to the extent permitted by applicable law.

We use the information we collect from and about you for these additional purposes:

• To allow service providers to assist us in providing and managing the MOHS Training Services. The information we collect from and about you may be made available to certain service providers, such as contractors, analytics and other measurement companies, agents or sponsors, who help us analyze and understand your use of the MOHS Training Services, and manage and/or provide the MOHS Training Services.

• To allow social sharing functionality. If you log in with or connect a social media service account with MOHS Training Services, we may share your user name, picture, and likes, as well as your activities and comments with other MOHS Training Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your MOHS Training Services account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your MOHS Training Services account and do not participate in social sharing on MOHS Training Services.

• To provide co-branded services and features. We may offer co-branded services or features, such as contests, sweepstakes or other promotions together with other companies (“Co-Branded Services”). These Co-Branded Services may be hosted on MOHS Training Services or on that other party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with that party. That other party’s use of your information will be governed by its privacy policy.

• To deliver relevant advertisements. MOHS Training Services and our service providers may use the information we collect from and about you as described in this Privacy Policy to deliver relevant ads to you when you use the MOHS Training Services or another service (on any of your devices). As noted above, advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information about the different devices you use and your activity on such devices, to assist them in delivering advertising that is more relevant to your interests. To find out more about advertising networks and similar entities that use these technologies, see www.aboutads.info. If you wish to opt out of tailored advertisements in desktop and mobile browsers, please visit http://optout.aboutads.info/ or http://optout.networkadvertising.org/# on each of your devices and browsers.To opt out in mobile apps, you may use your device’s “Limit Ad Tracking” or similar settings or download and use the AppChoices app at www.aboutads.info/appchoices. To opt out on connected TVs, please use the “Limit Ad Tracking,“ “Interest-based Ads,” or equivalent settings on your device. Please note that opting-out does not mean that you will stop seeing all ads.

• To contact you. MOHS Training may periodically send promotional materials or notifications related to the MOHS Training Services. For information related to opting-out of promotional materials, please go to Section 5 below.

• To share with our Company Affiliates. MOHS Training may share your information with our Affiliates for the purposes described in this Privacy Policy. A link to a website that lists MOHS Training Affiliates can be found at the beginning of this policy. Users who visit our Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.

• To share with business partners. MOHS Training may share your information with business partners to permit them to send you marketing communications consistent with your choices.

• To protect the rights of MOHS Training and others. There may be instances when MOHS Training may use or disclose your information, including situations where MOHS Training has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of MOHS Training, our Company Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the MOHS Training Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

• To complete a merger or sale of assets.If MOHS Training sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), MOHS Training may transfer your information to the party or parties involved in the transaction as part of that transaction.

4) Security

MOHS Training uses commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information.

5) User Access and Control

If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us as outlined in Section 7; or using the options provided below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

If you are a resident of California, please see the section entitled “California Consumer Privacy Act Notice,” below, for more information about the rights you have under California law. If you are under 18 and a registered user of the MOHS Training Services, you may ask us to remove content or information that you have posted to the MOHS Training Services by writing to kevin@k-lundy.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

You may request that we not share your personal information on a going-forward basis with our Affiliates or unaffiliated third parties for their direct marketing purposes. You may opt-out of this sharing via email. We will try to comply with your request(s) as soon as reasonably practicable and consistent with applicable law.

You may opt out of receiving promotional communications from us by clicking the “unsubscribe” link in a particular promotional communication. Please note that you cannot opt out from receiving all communications from us, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information. You can choose to receive push notifications from us on your device. If you do not wish to receive push notifications, you can use your device’s settings to turn them off.

6) Other Important Information

Updates to Privacy Policy. MOHS Training may modify this Privacy Policy to reflect changes in the law or the MOHS Training Services or for other reasons. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the MOHS Training Services.

Location of Data. The MOHS Training Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information (which may include information collected through the use of cookies and other technologies, as described above) processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information.

Linked Services. The MOHS Training Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. MOHS Training is not responsible for the privacy practices of unaffiliated companies, and once you leave the MOHS Training Services or click an advertisement you should check the applicable privacy policy of the other service.

In addition, MOHS Training is not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the MOHS Training Services.

Collection of Personal Financial Information by a Payment Service. In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints, or contractual, financial or legal requirements.

7) Contact Us

If you have questions about this Privacy Policy, please contact us at:

Email: kevin@k-lundy.com


8) California Consumer Privacy Act Notice

This California Consumer Privacy Act Notice Section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”). Under the CCPA, and for purposes of this Section, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident and includes the categories listed below. This Section 8 provides details about the categories of Personal Information of California residents that we have collected, disclosed, or “sold” during the last 12 months, as well as rights California residents have under California law.

(1) Categories of Personal Information Collected: We collect the following categories of Personal Information:

A. Name, telephone number, street address, email address, contact information, household income, or financial and payment information, date of birth, age, gender, political views, and marital status;

B. Identifiers such as IP address and other network information, online identifiers, cookie IDs and similar information, mobile device IDs, advertising IDs, device information and characteristics, and browser or device “fingerprint”—not your personal fingerprint but instead a statistical classification of your device or browser;

C. Where voluntarily provided;

D. Commercial information and events, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our websites, mobile, or connected TV applications;

F. Geolocation data, such as device or browser location;

G. Call recordings and emails; and

H. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on the California resident’s interactions with us, MOHS Training may not have collected each of these categories about each individual.

Sources of Personal Information. We collect this Personal Information directly from California residents themselves, as well as from social media platforms; joint marketing, co-branding, co- promotional, or advertising partners; Affiliates; and other sources of demographic information. Depending on the individual’s interactions with us, MOHS Training may not have collected Personal Information from each of these categories of sources.

Purposes. We may use this Personal Information, subject to applicable law, for the following purposes:

• to operate, manage, and maintain our business;

• to provide our products and services; and

• to accomplish our business purposes and objectives, including:

o developing, improving, repairing, and maintaining our products and services;

o personalizing content and advertising, and marketing our products and services;

o conducting research, analytics, and data analysis;

o maintaining our facilities and infrastructure;

o quality and safety assurance measures;

o conducting risk and security controls and monitoring;

o detecting and preventing fraud;

o performing identity verification;

o performing accounting, audit, and other internal functions;

o complying with law, legal process, and internal policies;

o maintaining records; and

o exercising and defending legal claims.

Depending on the California resident’s interactions with us, MOHS Training may not have used Personal Information collected about that resident for each of these purposes.

(2) Disclosures of Personal Information. We disclose the following categories of Personal Information to our service providers, Affiliates, and other parties for our operational business purposes:

A. Name, telephone number, street address, email address, contact information, household income, or financial and payment information, date of birth, age, gender, political views, and marital status;

B. Identifiers such as IP address and other network information, online identifiers, cookie IDs and similar information, mobile device IDs, advertising IDs, device information and characteristics, and browser or device “fingerprint”—not your personal fingerprint but instead a statistical classification of your device or browser;

C. Where voluntarily provided;

D. Commercial information and events, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our websites, mobile, or connected TV applications;

F. Geolocation data, such as device or browser location;

G. Call recordings and emails; and

H. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Depending on the California resident’s interactions with us, MOHS Training may not have disclosed Personal Information collected about that resident for each of these purposes.

(3) “Sales” of Personal Information. We disclose some categories of Personal Information in connection with certain types of advertisements, which could be considered a “sale” under the CCPA:

A. Name, telephone number, street address, email address, contact information, household income, or financial and payment information, date of birth, age, gender, political views, and marital status;

B. Identifiers such as IP address and other network information, online identifiers, cookie IDs and similar information, mobile device IDs, advertising IDs, device information and characteristics, and browser or device “fingerprint”—not your personal fingerprint but instead a statistical classification of your device or browser; and

C. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on the California resident’s interactions with us, MOHS Training may not have sold any Personal Information collected about that resident.

Please note that the CCPA definition of “sale” does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving of all or any portion of our business.

California Rights. If you are a California consumer, you have the following rights:

(1) Right to Know. You have the right to request that we disclose to you the following information:

o The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information during the 12 months prior to your request;

o The specific pieces of Personal Information we collected about you during that time period;

o The business or commercial purpose for collecting, disclosing, or selling Personal Information about you;

o The categories of Personal Information about you that we sold and the categories of third parties to whom we sold that Personal Information; and

o The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or disclosed that Personal Information.

To make a request for your Personal Information, please email kevin@k-lundy.com. Please note that, in some instances, we may decline to honor your request, where, for example, we are unable to verify your identity or an exception to this right applies.

(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.

To make a request for deletion, please kevin@k-lundy.com. Please note that, in some instances, we may decline to honor your request where, for example, we are unable to verify your identity or an exception to this right applies.

(3) Right to Opt-Out of Sale. As noted above in this section, we share some categories of Personal Information in connection with certain types of advertisements. If you wish to opt out of the sharing of your Personal Information in connection with tailored advertising in desktop and mobile browsers, please visit http://optout.aboutads.info/#/ or http://optout.networkadvertising.org/#. To opt out in mobile apps, you may use your device’s “Limit Ad Tracking” or similar settings or download and use the AppChoices app at http://www.aboutads.info/appchoices. To opt out on connected TVs, please use the “Limit Ad Tracking,” “Interest-based Ads,” or equivalent settings on your device. Please note that opting out does not mean that you will stop seeing all ads.

You can link to our “Do Not Sell My Personal Information” Internet Webpage here

(4) Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.