COVID-19 Book:Privacy policy

The book is authored by Michael Sullivan & Associates LLP.

Michael Sullivan & Associates LLP (“MSA”) is committed to safeguarding your privacy online. Please read the following “Privacy Policy” to understand how your personal information will be treated as you make full use of our website, content, and offerings. This policy may change from time to time, so please check back periodically. To make this policy easily accessible, a link to it is made available on our homepage and on every webpage where personal information is requested.

It is intended that this policy be read in conjunction with the Terms of Service, which governs your use of MSA website.

The following is the scope of this Privacy Policy.

1. What information do we gather about you?
MSA collects information from you in several ways from different parts of our website. The information gathered when you interact with our website and services falls into two categories: (1) “personal” information, which includes the information you supply when you register for our website and/or subscribe to our premium services; and (2) non-personal information which is collected through technology, such as tracking information collected by us and third parties.
Personal Information That You Provide Us

• Registration Information. When you register for our website, you will provide certain personal information, including your name, a unique email address, a physical mailing address, telephone and facsimile numbers, and demographic information, including (but not limited to) sex, age, job industry, and job title. • Billing and Credit Card Information. Please note that we collect and store your name, an email address, physical mailing address, telephone number, credit card information, and other billing information in order to enable payment via our website. This information will only be shared with third parties who help to complete the purchase transaction.

• Contests, Sweepstakes, and Special Offers. MSA may collect personal information from you when you participate in sweepstakes, contests, or special offers. If this information is also being collected by a third party other than MSA, we will notify you at the same time. If you do not want any personal information shared, you should not participate in the sweepstakes, contest, or special offers. Non-Personal Information Collected Using Technology

• Information Collected by Us Using Technology. MSA uses various Internet technologies to manage the services of our website and track the use of the our services. Non-personal information that we collect using these technologies may be combined with other information about you.

• Device Information. We may collect non-personal information about the computer, mobile device, or other device you use to access our website or services, including (but not limited to) your IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information.

• Cookies and Other Similar Technologies. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. We use “cookies” as they help us provide faster and more accurate services by allowing our computers to readily identify your computer as an authorized user ( among other details). You may not be able to access certain areas of our website if your computer does not accept cookies from us. We may also transmit non-personally identifiable website usage information to third parties in order to display advertising for Sullivan On Comp when you visit other websites.

• Analytics, Log Files, and Reading History. As is true of most websites, we will gather certain information automatically and store it in log files like most other websites. This information may include Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), browser type, operating system, and other usage information about the use of our website, including a history of the pages you view. We may combine this automatically collected log information with other information we collect about you. This is done so that we may improve the services we offer you. We have also hired third parties to provide us information, reports, and analysis about the usage, browsing patterns of our users. They may independently record the type of device and operating system you are using as well as general location information.

• Third Party Use of Information (Google Analytics Tracking, AdWords Remarketing, Facebook Remarketing). Some of the services and advertisements included on our website and in our services are delivered or served by third-party companies, which may collect information about your use of our services. These companies may place or recognize cookies, Web beacons, or other technology to track certain non-personal information from our website users. For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique cookie on your browser in order to collect certain information about your use of our services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests. We may control or have access to these third parties’ use of cookies or other tracking technologies or how they may be used. We use Google Analytics to understand the way that visitors to our website interact with it. We have enabled the following Google Analytics advertising features:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting
• Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers.

• We use Google AdWords re-marketing technology to market our website throughout the Internet. We place a cookie on your browser, and Google reads these cookies and may serve an ad on third-party website, after you have visited our website. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows a customer to deny or accept the cookie feature; however, as aforementioned, you should note that the cookies may be necessary for a user to access and use certain features available on our website. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-On. You may opt out of ad serving on Google’s opt-out page. We also utilize Facebook Advertising re-marketing technology to market our website throughout the Internet. Facebook may use cookies, web beacons, and similar technologies to collect or receive information from our website and other websites using that information to provide measurement services and ad targeting. You can opt out of the collection and use of information for ad targeting by following Facebook's published opt-out instructions. Additionally, you can opt out of additional web-tracking technologies via the Digital Advertising Alliance’s consumer choice page.

2. What do we do with the information we gather about you?

• Provide the Services You Request. We use the information we gather about you to enable your use of our services and fulfill your requests for certain products and services, such as your request to purchase a paid subscription to our premium services.

• Statistical Analysis. We perform statistical, demographic, and marketing analysis of the users of our services and their subscriptions and purchases. This enables us to provide this informaton to advertisers for analysis purposes including ways to improve our customer relationships.

• Relevant Advertising. We may use the information that we collect through advertising on our website to be targeted to the users for whom they are most pertinent. This means users see advertising that is most likely to interest them, and advertisers send their messages to people who are most likely to be receptive, improving both the viewer’s experience and the effectiveness of the ads. We disclose information to third parties only in aggregate or impersonal form.

• Email Newsletters. MSA will periodically send you email newsletters or promotional email about services offered by MSA and its advertisers.

3. With whom do we share the information that we gather?

• Within MSA. If you have registered to use our services, we will not sell, rent, swap, or authorize any third party to use your email address without your permission. In the future, we may sell, buy, merge, or partner with other companies or businesses. In such transactions, we may include your information among the transferred assets.

• Third Parties. We also share information about our audience in aggregated or de-identified form. Nothing in this Privacy Policy is intended to restrict our use or sharing of aggregated or de-identified information in any way.

• Service Providers. We contract with other companies to provide services on our behalf, including credit-card and billing processing, ad serving, shipping, email distribution, list processing, and analytics or promotion management. We provide these companies only with the information they need to perform their services. These service providers are restricted from using personal information in any other way than to provide services for MSA, and they may not share, resell, or use the data for their own direct marketing purposes. We reserve the right to disclose your opt-out information to third parties so they can suppress your name from future solicitors, in accordance with applicable laws.

4. Are there links to third-party websites?

• Yes. We have included links on our website for your use and reference. We are not responsible for the privacy policies on these websites. You should be aware that the privacy policies of these websites may differ from our own.

5. What is your email policy?
MSA complies with the federal CAN-SPAM Act of 2003. We will not send you marketing messages if you have opted out. You can choose not to receive messages in the future by either: (1) following the “unsubscribe” instructions located near the bottom of each email, or (2) you can opt-out here. We will not share, sell, rent, swap, or authorize any third party to use your email address for commercial purposes without your permission. MSA offers email newsletters. If you no longer wish to receive a specific newsletter, follow the “unsubscribe” instructions located near the bottom of each newsletter. If you send us an email, we will use your email address to respond directly to your questions or comments.
6. How do I change or update my personal information?
You may review and update your MSA membership or account information in the Settings area
7. Is my information protected?
To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put in place commercially reasonable physical, technical, and administrative controls to protect the information. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
8. Other Information

• Compliance With Legal Process. We may access, preserve, and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (i) comply with the law or with legal process; (ii) protect and defend our rights and property; (iii) protect against misuse or unauthorized use of our services; or (iv) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

• COPPA Compliance. MSA does not knowingly collect or store any personal information about children under the age of 13.

• Your California Privacy Rights. Under the California “Shine The Light” law, California residents may opt out of our disclosure of personal information to third parties for their direct marketing purposes. It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.

9. Changes to This Policy.
This Privacy Policy may be amended or altered at any time, at our discretion.