Privacy Policy 

Introduction 

This Privacy Policy (“Policy”) applies to the family of business under Emperion d.b.a. MCN (“Emperion”, “MCN”, “we”, us”, or “our”) including the websites we own and operate, such as MCN.com, and any services provided through these websites (“Site”) or other hosted service (“Service”). These Services include customized solutions designed to meet the specific business needs of the property & casualty and collision repair industries.

This Policy is part of our Terms of Use (“TOU”) which you can find at [Insert Link]. This TOU governs your access and use of the Site and/or Services. If you have entered into a separate written agreement with one of our businesses, any conflicting terms in this Policy will not apply. Unless otherwise specified, capitalized terms used in this Policy will have the same meaning as in the TOU.

For any questions regarding this Policy, please contact us at privacy@emperion.com. 

This Policy outlines the types of information we collect, use, share, protect, and retain from visitors and users (“you” or “users”) of our Site and Services. By accessing the Site or using any Services, you agree to this Policy, or where applicable, our policy on Your California Privacy Rights. Please note that the version of the Policy in effect at the time of your use applies. We recommend checking the date at the top of the Policy regularly to stay informed of any updates.

If you do not agree with the terms of this Policy, or the Terms of Use, please refrain from using our Site or any of our Services.

Information We Collect 

We may collect two types of information from you: 

1)     Personal Information: This includes any information you provide that can be used to identify you (e.g., your name, email address, account number). If you choose to share information publicly through our Site or Services, please be aware that we cannot control how third parties may collect or use that information.

2)     Anonymized Information: This refers to data that cannot be used to identify you (e.g., frequency of site visits, browser type). We may collect this information when you interact with our Site or Services. Additionally, we may use methods to de-identify Personal Information, leaving only Anonymized Information. We may collect, use, store, and share Anonymized Information without limitation.

How We Use the Information 

We use your Personal Information and other collected data for the following purposes: 

·         To fulDill the reason you provided the information (e.g., supporting the Services you use).

·         To respond to inquiries, address customer concerns, and improve our responses.

·         To maintain the safety, security, and integrity of our systems and services.

·         To comply with legal obligations, including laws, court orders, or government regulations.

·         To display our Site and its content to you.

·         To provide you with requested information, products, or services.

·         To send you notices about our products and services.

·         To fulDill contractual obligations and enforce our rights, including billing and collections.

·         To inform you about changes to our Site or Services.

·         To meet any other obligations related to the information you provided.

·         To evaluate or complete mergers, divestitures, or other business transactions where your information may be transferred.

·         For any other purpose with your consent.

Information Sharing and Disclosing 

We may share your Personal Information with third parties, including affiliates and service providers, to help deliver our Services. This includes:

·         Assisting with service delivery.

·         FulDilling the purpose for which you provided the information.

·         Communicating with you about current or future offerings.

These third parties can only use your information for the services they provide and cannot use, share, or retain it for other purposes.

We may also disclose your Personal Information to third parties in the following cases: 

·         To comply with legal obligations, such as laws, court orders, or legal processes.

·         To investigate crimes like fraud or identity theft.

·         During a sale, merger, reorganization, or similar business transaction.

·         To protect the rights, property, or safety of Emperion employees or others.

·         To enforce our Terms of Use or agreements, including billing and collections.

·         For marketing or advertising.

·         As otherwise required or permitted by law.

Data Security 

We take the protection of your Personal Information seriously and implement robust administrative, physical, and technical safeguards to ensure its confidentiality, integrity, and availability. Emperion is committed to using industry-leading security practices such as ISO 27001 and HITRUST. In particular:

·         We comply with the HIPAA Security Rule, where applicable.

·         We encrypt all data at rest and in transit (when it leaves our network).

·         We review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems.

·         We restrict access to Personal Information to Emperion employees, contractors, and agents who need to know that information to process it for us, and who are subject to strict contractual conDidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Despite our best efforts, no security measures are infallible, and we cannot guarantee that unauthorized third parties will never gain access to, alter, disclose, or destroy your Personal Information.

If you receive an email or any communication that claims to be from one of our Sites and requests sensitive information (such as your social security number, password, or financial details), please treat it as unauthorized and suspicious. Do not provide any information and report the incident immediately to us at security@Emperion.com. Your vigilance helps us maintain a secure environment for all our users.

Data Retention 

Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your Personal Information only for as long as we believe it is necessary to fulfill the purposes for which the Personal Information was collected (including the purpose of meeting any legal, accounting, or other reporting requirements or obligations). You may request that we delete the Personal Information about you that we hold, as described above. Where there is no legal, fiscal, administrative, or contractual requirement to retain information for a longer or shorter period, information will be destroyed within 7 years of its collection.

Your Rights 

Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. Subject to your specific use of the Services, your privacy rights include:

·         Transparency and the right to information: Through this policy we explain how we use and share your information; however, if you have questions or need additional information you can contact us at any time at privacy@emperion.com.

·         Right of access, restriction of processing, erasure: You may contact us to request information about the Personal Information we have collected from you or to request that your Personal Information be deleted. We will make every effort to fulDill your requests, subject to any legal, ethical, or contractual obligations. To submit a request or inquire about our data practices, please email us at privacy@emperion.com. 

When requesting access to your Personal Information, we may ask for speciDic details to conDirm your identity and right to access the data, as well as to locate and provide you with the relevant information. You may also designate an authorized agent to make a request on your behalf, if they comply with our veriDication procedures to conDirm your authorization.

 Please note that your right to access or delete your Personal Information is not absolute. There may be situations where legal or regulatory requirements prevent us from taking certain actions regarding your data. Additionally, some or all the information may have already been destroyed, erased, or anonymized. If we are unable to provide access to or delete your Personal Information, we will explain the reasons for this, subject to any applicable legal or regulatory restrictions. 

·         Right to correct your information: We strive to ensure that Personal Information in our possession is accurate, current, and complete. If an individual believes that the Personal Information about them is incorrect, incomplete, or outdated, they may request the revision or correction of that information. We reserve the right not to change any Personal Information we consider accurate. If it is determined that Personal Information is inaccurate, incomplete or outdated, we will use reasonable efforts to revise it and, if necessary, use reasonable efforts to inform agents, service providers or third parties, which were provided with inaccurate information so records in their possession may be corrected or updated.

·         Right to withdraw your consent at any time: When we process your Personal Information based upon your consent, you have the right to withdraw that consent at any time. You may withdraw your consent by contacting us at privacy@emperion.com. Withdrawing your consent may significantly limit your ability to use the Services.

·         Right to object or opt out at any time: You have the right to object to any processing of your Personal Information or to participate in any of the Services by contacting us at privacy@emperion.com. We will consider any request you make to us, and provide a reply in a timely manner, according to our legal, ethical, and contractual obligations. Some non- marketing communications are not subject to a general right to opt out (e.g., communications about transactions and disclosures) to comply with legal and ethical requirements.

·         Right to data portability: You have the right to data portability of your own personal data by contacting us at privacy@emperion.com. There are instances where applicable law or regulatory requirements allow or require us to refrain from transmitting your Personal Information to certain recipients or may require additional documentation before transmitting your information. Additionally, some or all the Personal Information may have been destroyed, erased, or made anonymous. If we cannot fulDill your data portability request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

·         Right not to be subjected to an automated decision: We do not make automated decisions using your Personal Information that may negatively impact you.

·         Right to lodge a complaint: You have the right to lodge a complaint with the competent regulatory authority, such as your state’s attorney general, if you believe that the processing of your Personal Information does not comply with the applicable legal requirements.

Cookies and Tracking Technologies 

Our Site uses cookies, tags, pixels, and similar tracking technologies (“Cookies”) to help provide, customize, evaluate, improve, and secure the Site. A Cookie is a small piece of text placed in your browser when you visit a website. This includes both our own first-party Cookies and third-party Cookies from our service providers and marketing partners.

Some Cookies are temporary and are deleted each time you close your browser. Others, called persistent Cookies, remain in your browser after you close it and may collect and store data for a set period after you’ve left our Site. To learn more about Cookies and how they work, you can visit Cookiepedia (http://www.cookielaw.org/cookiepedia/).

We use Cookies for the following purposes: 

·         Website Operation: Cookies are essential for running our Site securely and enabling basic functions such as page navigation.

·         Performance Analytics: Cookies help us understand how you interact with our Site. This allows us to monitor and improve the performance of our Site, Services, and your overall experience. We use Google Analytics to analyze site trafDic, track how our services are used, and enhance our advertising efforts. To opt out of Google Analytics, you can download the Google Analytics Opt-Out Browser Add-On (https://tools.google.com/dlpage/gaoptout). You can also adjust your settings on Google’s advertising opt-out page to prevent the use of Cookies for advertising.

·         Advertisements: Cookies allow us to show you relevant advertisements. Our third-party advertising partners may use these Cookies to create a proDile of your interests, deliver targeted ads on other websites, and measure ad effectiveness.

You can control how Cookies are used through your browser settings, including enabling a global privacy control signal. Please note that disabling or rejecting certain Cookies may cause our Site or Services to not function properly.

Children and Privacy

We do not knowingly collect Personal Information from children in connection with the features of our Sites or Services. If we become aware that an individual under the age of 13 has provided Personal Information through our Sites or Services, we will immediately remove the individual’s Personal Information from our files.

Changes to this Policy

Each time you use our Site or Services, the current version of the Policy will apply. When you use our Site, you should check the date of this Policy, which appears at the top of the Policy, and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. We will provide a Privacy Policy Update Notice on our website whenever there is a material change to the privacy policy.

Unless stated otherwise, our current Policy applies to all your information that we possess. We will not materially change our policies and practices to make them less protective of your privacy without first notifying you and gaining your consent.

Contact Information

To contact us with your questions or comments regarding this Policy or our information collection practices, please email us at privacy@emperion.com.