Privacy Policy

Introduction
This Privacy Policy (the “Policy”) describes the type of information that Medley Living, Inc. (the “Company,” “we” or “us”) gathers from visitors to the Medley Living, Inc. Website (the “Site”) and users of theMedley Living, Inc. support services, coaching services and networking services that may be offered through the Site, a mobile application, and/or live events(the “Service”).  The Service is intended to facilitate online and/or live support groups and services, coaching services and networking services.  The Site exists both to provide a platform to access the Service, and to provide information about the Service and the Company.    
Collection, Use, and Sharing of Personal Information
“Personal Information” means information that can be associated with a particular user.  The two charts below detail –separately with respect to the Service and the Site – what Personal Information we collect, how and why we collect such Personal Information, and how – if at all – such Personal Information is shared. 

Collection, Use, and Sharing With Respect to the Service
What Personal Information We Collect
How We Collect the Personal Information
Why We Collect the Personal Information
Contact/onboarding information, including name, email address, and phone number.
Users provide information through the Site, and as part of communicating for placement with a support and coaching group prior to taking part in a support group or coaching group.
We use this information to communicate with you about use of the Service, such as scheduling support and coaching group sessions and providing Service-related announcements.
Information related to payments.
In the event that a user participates in a part of the Service for which a fee is charged, the user will be asked to provide information related to payment.
This information is necessary in order to bill for fee-based portions of the Service.
Information you provide voluntarily.
Users may communicate various personal information as part of communications with us, or during support and coaching group sessions.  We do not actively solicit such information.
We do not actively solicit more information than is necessary effectively to provide the Service.
Recording of support and coaching group sessions.
Support and coaching group sessions are recorded as part of use of the Service.
We utilize the recordings for internal analysis and training purposes.

We do not share this information, except as explained below under “Third-Party Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of Harm.”   

Collection, Use, and Sharing With Respect to the Site
What Personal Information We Collect
How We Collect the Personal Information
Why We Collect the Personal Information
Information you provide voluntarily.
Users may provide certain information voluntarily as part of interacting with the Site, such as by using a contact form to email a question or comment.
We use this information to communicate with users who choose to contact us about the Site.
Automatic information collection, such as the use of cookies, web beacons, or pixel tags that give information about browsing and search history, as well as interactions with the Site.
When users access the Site, they are asked to consent to the use of cookies and other forms of automatic information collection.  Such collection does not occur if the user does not consent.
Collection of information about use of the Site and how users come to locate the Site is helpful in improving and promoting use of the Site.
We do not share this information, except as explained below under “Third-Party Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of Harm.”

Third-Party Contractors – We may use contractors (“Service Providers”) to perform limited services on our behalf, such as hosting websites and providing email services.  Service Providers are required to obtain only the Personal Information they need to deliver the service, to maintain the confidentiality of Personal Information, and not to use Personal Information for any purpose other than provision of the service.

Compliance with Law and Prevention of Harm – We may disclose your Personal Information or any information submitted via the Sites if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our users, yourself or the public.  We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Business Transitions – We may share information with businesses that are legally part of the same group as the Company, or that become part of that group.  We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Policy.

Aggregated and De-identified Data – As noted above, this Policy addresses the collection and sharing of Personal Information, that is, information that can reasonably be connected with a particular user.  We may occasionally de-identify and/or aggregate Personal Information – to the extent permitted by law – to the point that it can no longer be associated with a particular user.  When that occurs, such information is no longer Personal Information. Sale of Personal Information – We do not sell Personal Information. 
Users’ Rights Regarding Personal Information
Users of both the Site and the Service have the right to request information about our collection, use, and disclosure of their information (a “Request to Know”), including:
  • the categories and specific pieces of Personal Information we have collected about the user;
  • the categories of sources from which we have collected the user’s Personal Information;
  • the business or commercial purpose for collecting or selling the user’s Personal Information;
  • the categories of Personal Information we have sold about the user; and
  • the categories of Third Parties with whom we have shared, disclosed for a business purpose, or sold the user’s Personal Information, and which categories of Personal Information we have sold to which categories of Third Parties.
Requests to Know
Users may submit a Request to Know by completing the form provided at [INSERT] or by emailing us at privacy@withmedley.com.  

Users may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that we have collected about you in the past twelve months; or (2) a request for the categories of Personal Information that we have collected about you in the past twelve months, and we have used and disclosed that Personal Information.

When you submit a Request to Know, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number.  If you submit a Request to Know for the specific pieces of information that we have collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.

If we are able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why we are not required to provide the requested information.  If we are unable to verify your identity, we will respond by explaining why we cannot verify your identity.  We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.

If we provide the information requested, we will provide the information free of charge and in a readily useable portable format.  We have no obligation to provide Personal Information to you more than twice in a 12-month period.  If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.
Requests to Delete
Users may submit a Request to Delete by completing the form provided at [INSERT] or by emailing us at privacy@withmedley.com.  When you submit a Request to Delete, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number.  If we are able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why we are not required to delete your Personal Information.  We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the Personal Information.  We will specify the manner in which we delete your Personal Information.

If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete.
Protection and Retention of Personal Information
We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information.  The appropriate administrative, physical, and technical safeguards employed by us may vary depending on the nature of Personal Information collected, with more stringent measures applied to information of a sensitive nature.  

However, no method of transmission over the Internet, or method of electronic storage, is entirely secure.  Therefore, while we strive to use commercially reasonable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality.  Please be aware that certain Personal Information and other information provided by you in connection with your use of the Site may be stored on your device (even if that information is not collected by us).  You are solely responsible for maintaining the security of your device from unauthorized access.

Personal Information will be retained for as long as is reasonably necessary to achieve the purposes set forth in this Policy, and to comply with all applicable laws.
Other Provisions
Accessibility and Language – Any person that is unable to access this Policy through the Site may request this Policy in an alternative format or language by contacting us at privacy@withmedley.com.

International Users – The Company and its servers are located in the United States and are subject to applicable local, state, and federal laws.  Users who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules and regulations.  Users who choose to access the Site consent to the use and disclosure of information in accordance with this Policy and subject to such laws.  We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.  We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any other jurisdiction.

As to residents of the EU, this means that, if you choose to use the Site and/or to communicate with us through the Site, information about you – including Personal Information – will be transmitted outside of the EU to the United States.  The European Commission has the authority, pursuant to Article 45 of the GDPR, to determine that the laws of states outside of the EU provide residents of the EU with an adequate level of data protection similar to that of the GDPR.  Please note that, to date, the European Commission has not determined that the federal and state laws of the United States provide EU residents with an adequate level of data protection.

Children’s Privacy – The Site is neither directed to nor structured to attract Users under the age of 18.  If you are under the age of 18, you are not permitted to use the Site.  The Company does not knowingly collect Personal Information from users under the age of 18.  If you are a parent with concerns about children’s privacy issues in conjunction with the use of the Site, please contact the Company at privacy@withmedley.com.

Do Not Track Signals and Collection of Information for Third-Party Advertising – The Company is required to disclose how it responds to “Do Not Track Signals” and whether third parties collect personally identifiable information about users when they use online services.  The Company honors "do not track" signals and does not track, use cookies, or use advertising when a “do not track” mechanism is in place.  The Company does not authorize the collection of personally identifiable information from our users for third-party use through advertising technologies.

Amendments – We may modify or amend this Privacy Policy from time to time.  If we make any material changes, as determined by us, to this Privacy Policy, including in the way in which Personal Information is collected, used or transferred, we will notify you by e-mail to the address specified in your profile or by means of a notice on the Site prior to the change becoming effective.
Contact Information
If you have questions about this Policy, please contact us at privacy@withmedley.com.
Effective Date
The effective date of this Policy is June 24, 2020.