Information Mulligan Collects About You
Mulligan may collect both Personally Identifiable Information—information that identifies you or can be used on its own or with other information to identify, locate or contact you—as well as non-personally identifiable information about how you use the Website. Personally Identifiable Information may include name, address, email address, telephone number, payment information, and other similar information that can be used to identify you. Specifically, we may collect the following:
Information You Choose to Provide When You
- Fill in information on our online forms;
- Contact us; and
- Otherwise post or publish on the Website.
Mulligan uses this information to process your vendor application or other requests, communicate with you about your requests, provide you with information or services you have requested, and evaluate and improve the effectiveness of its Website and the information it contains.
Information We Collect Automatically
Mulligan may use tools (“Automatic Data Collection Technologies”) to automatically collect certain data about the computer or other device you use to reach our Website, such as:
- Device properties including, but not limited to, unique or other device identifiers;
- Device operating system and software;
- IP address and Internet service provider;
- Mobile phone carrier;
- Geographical data such as country or region; and
- Other similar data.
Mulligan also may Automatic Data Collection Technologies to gather and analyze information regarding the Website’s usage, such as the number of hits received, the number of unique visitors, the most/least visited pages, errors experienced by users, browsers and platforms used to connect to the Website, the number of times a user or the computers within a given network visited the Website, the date and time you visited the Website, the pages of the Website that you visited and the order in which you accessed such pages, and the websites you visited before or after you visit our Website.
The information Mulligan collects through the use of Automatic Data Collection technologies may include Personally Identifiable Information or Mulligan may associate it with Personally Identifiable Information we collect in other ways.
This information may be collected via several technologies, including cookies, web beacons, clear GIFs and other means. You can remove certain cookies by following the directions in your Internet browser’s “help” file. If you disable cookies, your ability to use areas of the Website may be limited.
All of this information belongs to Mulligan. Mulligan uses the information for marketing purposes and to improve the effectiveness, content, layout and/or operation of our Website.
Using Your Information
In addition to the uses described above, Mulligan uses the information it collects about you or that you provide on the Website, including any Personally Identifiable Information:
- To present the Website and its contents to you;
- To provide you with information, products or services that you request from us;
- To fulfil any other purpose for which you provide it;
- To carry out our obligations and enforce our rights arising from any contracts entered into between us and others, including for billing and collection;
- To administer and improve the services or Website, including by monitoring and analyzing the Website traffic and usage patterns;
- To notify you about changes to the Website that may affect your use of it;
- In any other way we may describe when you provide the information; or
- For any other purpose with your consent.
Mulligan may also use your Personally Identifiable Information to contact you about Mulligan goods and services that may be of interest to you. If you do not want Mulligan to use your Personally Identifiable Information in this way, please contact us using the below contact information.
Sharing Your Information
Mulligan does not share your Personally Identifiable Information with third-parties for their own marketing purposes. Your Personally Identifiable Information is accessible to certain Mulligan personnel. In addition, Mulligan may share your Personally Identifiable Information:
- With contractors, service providers, and other third-parties Mulligan uses to support the business;
- With sponsors or co-sponsors of webinars, seminars or other events in which Mulligan is participating;
- To fulfil the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information;
- With your consent;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personally Identifiable Information held by us about the Services users is among the assets transferred;
- To enforce any agreement, including any applicable terms of service or for billing and collection purposes;
- To establish or exercise our right to defend against legal claims;
- To law enforcement and other government authorities such as legislatures, courts, agencies and litigants if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of governmental authorities; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) protect the security or integrity of the Website or Mulligan’s information systems; and/or (e) exercise or protect our rights, privacy, safety or those of affiliates, clients, you or others; and
- If we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of Mulligan or others.
Protecting Your Information
Mulligan follows commercially reasonable security practices and procedures designed to protect your Personally Identifiable Information from unauthorized access, use and disclosure. Nevertheless, please be aware that Internet transmissions and information storage systems are never completely private or secure.
Mulligan stores your information for as long as we believe the information to be necessary in carrying out the business purposes for which it was collected.
Privacy Policies of Third-Party Websites to Which the Website Links
Mulligan does not knowingly collect Personally Identifiable Information from any children under age 16. No parts of the Website are directed to or designed to attract anyone under the age of 16.
Data Storage and Processing Conducted in the United States
Regardless of where you are located, Mulligan collects information and processes and stores that information in databases located in the United States. If you are from a country outside the United States, you should be aware that you may transfer Personally Identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Website and submitting any Personally Identifiable Information, you consent to the transfer of such Personally Identifiable Information to the United States.
Additional Terms for EU Visitors
California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of Personally Identifiable Information with third-parties for direct marketing purposes. We do not share any California consumer Personally Identifiable Information with third-parties for marketing purposes without consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.
If you are a California resident, please see our California Resident Privacy Notice, below.
Do Not Track Requests
The Website does not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.
Last revised: April 1, 2021
California Resident Privacy Notice
Information We Collect:
Mulligan may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personally Identifiable Information”). Personally Identifiable Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, Mulligan may have collected the following categories of Personally Identifiable Information within the last twelve (12) months:
| CATEGORY|| EXAMPLES|| COLLECTED AND HOW||HOW DISCLOSED|
| C. Protected classification characteristics under California or federal law.|| Age (40 years or older), race, color, citizenship, physical or mental disability, sex (including gender, gender identity, gender expression).|| NO||Not applicable|
| D. Commercial information.|| Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|| NO||Not applicable|
| E. Biometric information.|| Activity patterns used to extract a template or other identifier or identifying information, such as keystroke. *We do not utilize facial recognition software.|| NO||Not applicable|
| H. Sensory data.|| Audio, electronic and visual.|| NO||Not applicable|
| I. Professional or employment-related information.|| Current or past job history or performance evaluations.|| NO||Not applicable|
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).|| Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as class lists, student identification codes.|| NO||Not applicable|
| K. Inferences drawn from other Personally Identifiable Information.|| Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|| NO||Not applicable|
Use of Personally Identifiable Information
Mulligan will not collect additional categories of Personally Identifiable Information or use the Personally Identifiable Information collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personally Identifiable Information
Disclosures of Personally Identifiable Information for a Business Purpose
In the preceding twelve (12) months, Mulligan has disclosed the following categories of Personally Identifiable Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records Personally Identifiable Information categories.
Sales of Personally Identifiable Information
In the preceding twelve (12) months, Mulligan has not sold Personally Identifiable Information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personally Identifiable Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Mulligan disclose certain information to you about the collection and use of your Personally Identifiable Information over the past twelve (12) months. Once Mulligan receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), Mulligan will disclose to you:
- The categories of Personally Identifiable Information collected about you.
- The categories of sources for the Personally Identifiable Information collected about you.
- The business or commercial purpose for collecting or selling that Personally Identifiable Information.
- The categories of third-parties with whom Mulligan shares that Personally Identifiable Information.
- The specific pieces of Personally Identifiable Information collected about you (also called a data portability request).
- If Mulligan disclosed your Personally Identifiable Information for a business purpose, two separate lists disclosing:
- the disclosures for a business purpose and identifying the Personally Identifiable Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Mulligan delete any of your Personally Identifiable Information that it has collected from you and retained, subject to certain exceptions. Once Mulligan receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), Mulligan will delete (and direct our service providers to delete) your Personally Identifiable Information from Mulligan’s records, unless an exception applies.
Mulligan may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personally Identifiable Information, provide a good or service that you requested, take actions reasonably anticipated within the context of the ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Mulligan by either:
- Calling us at (866) 403-9630
- Emailing Mulligan at firstname.lastname@example.org
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personally Identifiable Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows Mulligan to reasonably verify you are the person about whom Mulligan collected Personally Identifiable Information or an authorized representative, which may include the user’s first name, last name, email address, exam date and time, and exam ID.
- Describe your request with sufficient detail that allows Mulligan to properly understand, evaluate, and respond to it.
- Mulligan cannot respond to your request or provide you with Personally Identifiable Information if we cannot verify your identity or authority to make the request and confirm the Personally Identifiable Information relates to you.
Making a verifiable consumer request does not require you to create an account with Mulligan. However, Mulligan does consider requests made through your password-protected account sufficiently verified when the request relates to Personally Identifiable Information associated with that specific account.
Mulligan will only use Personally Identifiable Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
Mulligan endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Mulligan requires more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with Mulligan, a written response will be delivered to that account. If you do not have an account with Mulligan, we will deliver our written response by mail or electronically, at your option.
Any disclosures Mulligan provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Mulligan provides will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, Mulligan will select a format to provide your Personally Identifiable Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Mulligan does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Mulligan determines that the request warrants a fee, Mulligan will tell you why it made that decision and provide you with a cost estimate before completing your request.
Mulligan will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Mulligan will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, Mulligan may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personally Identifiable Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.