Supplemental Privacy Policy for California

If you are a California resident, you have certain rights with respect to your personal information in addition to those described in the Privacy Policy. The following is a summary of those rights and additional information applicable to our collection and use of your personal information. For clarity, this Supplemental Privacy Policy for California is in addition to, and not in lieu of, the information provided in our Privacy Policy. Please note, if you are not a California resident, the rights described in this section do not apply to you. These rights were established, in part, by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Summary of Our Collection of Your Personal Information

We only use your personal information for the purposes for which it was collected - in most cases this means providing Services to you.

We do not sell your personal information. If your choices for cookies permit, we may share your personal information for cross-context behavioral advertising. Otherwise, we do not share your personal information for cross-context behavioral advertising. You can set your cookie preferences by clicking Cookie Preferences or the link at the bottom of this page.

We disclose your personal information to suppliers and service providers such as firms that provide us with technology or other services. We have agreements with these service providers that protect your personal information and limit their ability to use personal information only for the purposes of the agreement.

The following is a summary of the categories of personal information that we collect, the purposes for which we collect your personal information, and whether we sell your personal information or share your personal information for cross-context behavioral advertising. As detailed below, the personal information we may collect may be different depending on whether you are a Visitor, Employee, Contractor, or Client. Generally, categories of personal information collected about Employees and Contractors also apply to potential Employees and Contractors (i.e., applicants).

Categories of Information	About Whom We Collect This Information	Purposes for Which Personal Information Is Collected	Whether the Personal Information Is Sold or Shared	Length of Time We Intend to Retain Personal Information
Identifying Information such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Visitors Employees and Contractors Clients	Manage and maintain our relationship with you Personalize Services to you Improve our Services Comply with legal obligations Prevent, detect, or investigate fraud or security breaches	MBO does not sell identifying information. Except for information permitted to be shared through your cookie preferences, we do not share identifying information with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Protected Characteristics and similar Information Protected by Law	Employees and Contractors	Comply with legal obligations Offer opportunities to you With your permission, share with your clients	We do not sell protected characteristics and we do not share protected characteristics with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Commercial Information	Visitors Employees and Contractors Clients	Personalize Services to you Improve your experience on our Websites Comply with legal obligations	We do not share you’re your commercial information and do not share commercial information with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Biometric Information	Employees and Contractors	To comply with legal requirements To comply with requirements for security clearance Prevent, detect or investigate fraud or security breaches	We do not sell biometric information and do not share biometric information with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Activity on our Websites	Visitors Employees and Contractors Clients	Personalize Services to you Improve your experience on our Websites Prevent, detect, or investigate fraud or security breaches	We do not sell information about your activity on our Websites. Except for information permitted to be shared through your cookie preferences, we do not share information about your activity on our Websites with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Geolocation data	Visitors Employees and Contractors Clients	Personalize Services to you Improve your experience on our Websites Prevent, detect, or investigate fraud or security breaches	We does not sell geolocation data information. Except for information permitted to be shared through your cookie preferences, we do not share information about your activity on our Websites with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Sensory Data including audio, electronic, visual, thermal, olfactory or similar information	Visitors Employees and Contractors Clients	For quality control and training purposes, telephone calls to customer support staff may be recorded For security purposes, if you visit our offices, your image may be recorded by our security cameras.	MBO does not sell sensory data and does not share sensory data with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Professional or Employment Related Information	Employees and Contractors	Provide Services to you. Verify your qualifications for employment or engagement opportunities Provide opportunities for you to be employed or engage with clients	MBO does not sell professional or employment related information and does not share professional or employment related data sensory data with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Education Information	Employees and Contractors	Personalize Services to you Verify your qualifications for employment or engagement opportunities Provide opportunities for you to be employed or engage with clients	MBO does not sell education information and does not share education information data with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.
Profile Information including inferences drawn from information to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Employees and Contractors	Personalize Services to you	We do not sell Profile Information and do not share Profile Information with any third parties for cross-context behavioral advertising.	Only as long as reasonably required for the purposes for which it was collected, or to establish, exercise, or defend a legal claim.

California’s Shine the Light Law

Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set in this Privacy Policy. Under California’s Shine the Light Law, you have the right to send us a request at the designated email address listed below to receive the following information:

the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
the names and addresses of the third parties that received the information; and
if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized form that is not specific to you. The designated method for submitting these requests is by completing the Individual Data Request Form.

California Consumer Privacy Act

Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding the personal information businesses collect about them. This includes the rights to know of a business’s collection, use and disclosure of personal information, to request access to personal information, request deletion of personal information, and to direct a business to stop selling personal information.

Right To Know

You have the right to know and access:

the specific pieces of personal information that we collected about you;
the purpose for which we collect your personal information;
the categories of personal information that we collect, the sources from which we have obtained your personal information, and third parties to whom we disclose your personal information.

Right To Correct

You have the right to have us correct inaccurate personal information held about you.

Right To Delete

You have the right to have us delete your personal information, subject to certain exceptions.

Right To Opt-Out

You have the right to opt-out of the sale or sharing of your personal information to third parties.

Please Note: Except for the information permitted to be transferred by your cookie preferences, we do not sell your personal information or share it with any third parties for cross-context behavioral advertising. In addition, we share your information as permitted by you when additional consent is appropriate or only as described in our Privacy Policy.

Right To Limit Use and Disclosure

You have the right to limit the use and disclosure of your sensitive personal information, subject to certain limitations.

Please Note: We disclose your sensitive information only as required to enable us to provide our Services to you and only as described in our Privacy Policy.

Right To Non-discriminatory Treatment

We will not discriminate or retaliate against you for exercising any privacy right. We will not deny services, charge different prices or rates, provide you with a different level of quality of services, or engage in any other form of discrimination.

Request Process

If you would like to exercise any of your privacy rights or would like your authorized agent to make a request to exercise your privacy rights on your behalf, please use the Individual Data Request Form or the information in the ’Contact Us’ section in the Privacy Policy to submit a written request. We will promptly take steps to determine whether your request is a verifiable consumer request and disclose and deliver any required information or a response within 45 days of receiving your request.

Summary of Uses and Disclosures of Personal Information

The following is a summary of the categories of personal information we collect, whether we collect the information about Visitors, Employees and Contractors, and/or Client, the purposes for which we collect the information, and the categories of third parties with whom we share personal information. This is also a summary of the categories of personal information we have collected and shared in the preceding 12 months.

Category of Information	About Whom We Collect This Information	Sources From Whom Information Was Collected	Purposes for Which Personal Information Is Collected	Categories of Third Parties With Whom We Share Personal Information
Identifying Information such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Visitors Employees and Contractors Clients	You	Manage and maintain our relationship with you Personalize Services to you Provide customer service Maintain and secure your account with us Comply with legal obligations Prevent, detect, or investigate fraud or security breaches	Vendors that provide marketing and communication services Technology service providers Service providers Government or law enforcement agencies
	Employees and Contractors	You	Identify you, or validate or verify your identity	Companies with employment or engagement opportunities
	Employees and Contractors	You	Comply with legal requirements	Government agencies
	Employees and Contractors	Employees and Contractors Consumer Reporting Agencies	Pre-engagement screenings Obtain a consumer report	Companies with engagement or employment opportunities for you
	Employees and Contractors	You	Make payments to you	Banks and other financial institutions
Protected Characteristics - Characteristics and similar Information Protected by Law	Employees and Contractors	You	Comply with legal requirements Provide benefits to you	Government agencies Benefit providers With your permission, your clients
Commercial Information	Visitors Employees and Contractors Clients	You Cookies	Improve your experience on our Websites Personalize Services to you	Technology service providers Service providers
Biometric Information	Employees and Contractors	You	To comply legal requirements for security clearances If you visit our offices, to protect the security of our premises with security cameras	Technology service providers Service providers Government agencies as required
Activity on our Websites	Visitors Employees and Contractors Clients	You Cookies	Personalize Services to you Manage your preferences Prevent, detect, or investigate fraud or security breaches	Technology service providers Service providers
Geolocation data	Visitors Employees and Contractors Clients	You Cookies	Personalize Services to you Improve our processes Prevent, detect, or investigate fraud or security breaches	None
Sensory Data including audio, electronic, visual, thermal, olfactory or similar information	Visitors Employees and Contractors Clients	You	For quality control and training purposes, telephone calls to customer support staff may be recorded	Technology service providers
	Individuals who visit our offices	Individuals who visit our offices	Audio/video monitoring of individuals who enter our offices	None
Professional or Employment Related Information	Employees and Contractors	You	Verify your qualifications for employment or engagement opportunities Provide opportunities for you Personalize Services to you	Companies with opportunities Technology providers Service providers
	Employees and Contractors	Consumer Reporting Agencies	Pre-engagement screening Obtain a consumer report	Companies with opportunities for you
Education Information	Employees and Contractors	You Education Institutions	Verify your qualifications for opportunities Provide opportunities for you to be employed or engage with clients	Third parties who may have opportunities Technology service providers Service providers

Changes to This Supplemental Privacy Policy for California

We may update this Supplemental Privacy Policy for California from time to time. When we do update them, we will post a notice on our Websites and Products, make the updated version of this Supplemental Privacy Policy for California available on this page, and indicate the date it was last updated above. For clarity, any updates will apply from the date they are posted. Please check back periodically to see if this ‘Supplemental Privacy Policy for California’ has been updated.