Thank you for visiting our website (“Site”). Mullins & McGinn Publishing LLC (“Mullins & McGinn Publishing LLC” or the “Company”) is committed to treating the personal and corporate information of our Site users, customers, and vendors with respect and sensitivity. We’ve updated our Privacy Policy and improved our privacy practices so we can better safeguard your data. This Site also uses cookies to personalize your experience and target advertising. By continuing to use our Site, you accept the terms of this Privacy Policy, our Terms of Use, and our Cookies policy. To learn how to opt out of our use of Cookies on this Site, click here, but please note that if you disable cookies you may not be able to use all the features of our site. This Privacy Policy (together with our Terms of Use and any other policies referenced) identifies how we will collect and process any personally identifiable information, such as your name, email, address, financial account information, etc., that we collect from you, or that you provide to us. If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any CCPA-specific information is identified in this Policy. If you are a resident of the European Economic Area (“EEA”), this Privacy Policy also outlines additional policies applicable to our collection and processing of your personal information. As our services evolve and we perceive the need or desirability of using your personal data collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our Site frequently to review the current Privacy Policy in effect and any changes that may have been made to it. By providing your Personal Information to us in any format (e.g., via email, telephone, fax, or in person) and/or continuing to use any of our services or visiting our Site you accept and consent to the practices described in this Privacy Policy and Information Notice.

1. Introduction

This Privacy Policy describes how the Company collects, uses, and shares information about visitors to our website at mullinsandmcginn.com, attendees of our programs, individuals who contact us to purchase materials or request information, and other users of our services. The Website and our other programs and services are the “Services.” This Policy describes how we obtain and use personal data (which can be used to identify a specific individual) and anonymous data (which cannot).

Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., the EU or California). Otherwise, the Policy applies to all users of our Services, regardless of location. Children. The Services of Mullins & McGinn Publishing LLC are not directed to children. If you become aware that a child (based on the jurisdiction where the child lives, which in the United States means someone under the age of 13) has provided us with Personal data without parental consent, contact us at the location identified below in the Contact Us section.

2. What Personal Information Does the Company Collect?

We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, make purchases, request information, or register for or attend our programs. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features. For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper based filing systems) relating to a living individual who can be identified from that data. Personal Information comprises the categories of Personal Information defined by the CCPA.

Information You Give Us

When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, or attend a Mullins & McGinn Publishing LLC event, we may collect Personal Information including:

• Identifiers: name, address, email, and phone; for current or prospective affiliates, suppliers, and subcontractors, personal information such as social security number, federal tax ID number, or other relevant information, as applicable.
• Other Data (1798.80): credit card and account information collected when you purchase products or services; self-assessment data and results, such as information you input when taking self-assessment quizzes, assessment tests, and the like.
• Protected classes: gender, sexual orientation, self-assessment data and results (i.e., information you input when taking self-assessment quizzes, DISC assessment tests, and registering for seminars).
• Professional Data: for those considering careers with Mullins & McGinn Publishing LLC, professional data and education information such as résumé or C.V., salary history, education history, citizenship information, and position sought, as applicable.
• Education Information: as needed for participation in programs and live events.
• Inferences: Personal information about your goals and aspirations for our products, services, and live events, or inferences derived from that information.

We do not collect or receive Biometric Information or Sensory Data.

Information We Collect Automatically

Internet Activity: When you visit our Site, our web server automatically collects and stores the following information: The Internet protocol (IP) address used to connect your computer to the Internet, referring website address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Information about your visit, including the full URL, clickstream to, through and from our site (including date and time), pages on our Site you viewed, page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Our Site uses cookies and pixel tags to collect this information.

Information We Receive from Other Sources

This is information we receive about you from third parties who operate other sites or services we use in order to provide our products and services to you. We work closely with third parties, including business partners, promoters, affiliates, and sub-contractors in technical, payment and delivery services, advertising networks, marketing analytics providers, promotions, and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies

Our Site uses cookies to personalize your experience and target advertising, and we recommend you review our Cookies policy.

3. How Does the Company Use Personal Information?

Information You Give Us

We will use this information:

• to provide you with the Services that you request from us;
• to carry out our obligations arising from any contracts entered into between you and us, or between you and our promoters, affiliates, or distributors;
• to contact you in the future to provide you with information about other products and services we offer, or that are offered by our affiliates or third party vendors;
• to notify you about changes to our Services;
• to comply with applicable laws and regulations;
• to assess your suitability for participation in our live events, and to determine additional Mullins & McGinn Publishing LLC materials, services, or events to recommend and market to you;
• for training purposes, quality assurance, and to record details about the products and services you order from us;
• to make inquiries about you for credit reference purposes;
• to perform data analyses (including anonymization and aggregation of Personal Information);
• for prospective employees, to respond to and process your job application and CV.

Information We Collect About You

We will use this information:

• to provide targeted advertising and marketing services;
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our site safe and secure.

Information We Receive from Other Sources

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. Do We Share Your Personal Information with Any Third Parties?

Mullins & McGinn Publishing LLC does not sell your Personal Information to any third parties. To provide the Services, we sometimes disclose Personal Information to service providers for business purposes. Our service providers are contractually obligated to comply with all applicable laws (e.g., the CCPA), and all such third parties use your Personal Information only on behalf of Mullins & McGinn Publishing LLC and under the instructions of Mullins & McGinn Publishing LLC on how your information may be used and processed. By enjoying our Services and sharing your Personal Information, you agree that we have the right to share the categories of Personal Information we collect with our service providers for the following business purposes:

• Sales — for the purpose of fulfilling requests from you to purchase goods and services from our Site or at our events;
• Targeted advertising — to provide advertising of Mullins & McGinn Publishing LLC programs and services on other sites and platforms;
• Marketing — for the purpose of direct marketing of goods and services offered by Mullins & McGinn Publishing LLC and our affiliates that you may be interested in;
• Self-Assessment testing — for administering and providing self-assessment testing services, including any assessment tests;
• Cloud services — for provision of cloud storage services;
• Contractual performance — for the performance of any contract we enter into with you, or they enter with you on behalf of Mullins & McGinn Publishing LLC;
• Web analytics — analytics and search engine service providers that assist us in the improvement and optimization of our site.

We may also disclose your personal information to third parties in the following circumstances:

• In the event that we sell or buy any business or assets, in which case we will disclose your Personal Information to the prospective seller or buyer of such business or assets;
• If we sell all or substantially all of our assets to a third party, personal information about our customers will be one of the transferred assets;
• If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or any lawful request by public authorities, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.

5. Our Storage of Your Personal Information

Mullins & McGinn Publishing LLC uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect. We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim. You may unsubscribe from any of our online e-mail updates and marketing by following the unsubscribe instructions in the body of any e-mail message we have sent to you. We will take commercially reasonable steps to implement your unsubscribe requests promptly, but you may still receive promotional information from us by mail for up to 60 days, and up to 10 days for e-mail. You may also continue to receive information from those third parties to whom we have previously disclosed your Personal Information. Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

6. Access to Other Websites

Our Site may include links to and from other websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites are not covered by this Privacy Policy. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how Mullins & McGinn Publishing LLC deals with your Personal Information.

7. Protecting Children’s Privacy

We are strongly committed to protecting the safety and privacy of children who visit our Site. Our Site is not designed nor is it intended to be used by children under 13, and we do not knowingly collect personal information online from children under 13. Our Site includes content that we believe to be unsuitable for children under 13, and we encourage all parents to talk to their children about online safety and to monitor their children’s use of the Internet.

8. Additional Policies in Compliance with the CCPA

The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section.

8.1 Right to Know About Personal Information Collected, Used, Disclosed, or Sold

California consumers have the right to request that the Company disclose what personal information it has collected, used, disclosed, and sold over the 12-month period preceding the Company’s receipt of such a request. To exercise this right, a California consumer must submit to the Company a verifiable request to know such information. This request can be submitted by following the procedures set forth in the Contact Us section.

8.2 Right to Request Deletion of Personal Information

California consumers have the right to request the deletion of their personal information collected or maintained by the Company. To exercise this right, a California consumer must submit to the Company a verifiable request to delete such information. This request can be submitted by following the procedures set forth in the Contact Us section.

8.3 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that the company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA.

8.4 Notice of Financial Incentive

Mullins & McGinn Publishing LLC offers a financial incentive to its users and clients who refer friends and family to Mullins & McGinn Publishing LLC. If you refer four people then you get a free ticket to one of Mullins & McGinn Publishing LLC events at time offered valued at no more than $997.

8.5 Submitting a CCPA Data Request

To submit a request to know about the Personal Information we collect about you as described in Section 8.1 or a request for deletion of your Personal Information as described in Section 8.2, please contact us. Mullins & McGinn Publishing LLC is required to verify the identity of the individual requesting access to a consumer’s data or requesting deletion of a consumer’s data. To verify your identity, you must provide:

• userid and password for the Mullins & McGinn Publishing LLC Site; or
• if Mullins & McGinn Publishing LLC has previously received your email address, Mullins & McGinn Publishing LLC may verify that you have access to that email address by sending a verification code; or
• if Mullins & McGinn Publishing LLC has previously received your mobile number, Mullins & McGinn Publishing LLC may text you a verification code.

8.6 Authorized Agent

California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:

• Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
• Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465.

9. Additional Policies in Compliance with the EEA Privacy Laws

In addition to the other policies described in this Privacy Policy, residents of the European Union or the EEA are afforded the following additional rights and protections as required by the General Data Privacy Regulation (“GDPR”). The additional rights and protections set forth in this section of this Policy apply only to residents of the European Union or the EEA.

9.1 GDPR Definitions

“Controller” means the Company which is the organization that determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business. “Processor” means any Person Processing Personal Information. “Person” means a natural person, corporation, association, organization, partnership, or other legal entity. “Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.

9.2 The Legal Basis for Processing Your Personal Information

In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information. The legal basis for processing your Personal Information will typically be one of the following:

• our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors;
• the performance of a contract that we have in place with you;
• your consent where appropriate; or
• compliance with our legal obligations, including to meet national security or law enforcement requirements.

9.3 Where We Store Your Personal Information

The data that we collect from you is stored on our servers or on servers provided by cloud service providers, such as Amazon Web Services. If you are a resident of the EEA, your Personal Information may be transferred within or outside the EEA to areas where privacy laws may be less strict than in the EEA. By submitting your Personal Information, you agree to this transfer, storing, and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

9.4 Addendum to How Long We Store Your Personal Information

In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

9.5 Your Rights with Respect to Your Personal Information

Subject to certain exceptions, you have the following rights with respect to your Personal Information:

• To receive or access a copy of the Personal Information that we hold about you;
• To request that any inaccurate or incomplete Personal Information be corrected or supplemented;
• To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and
• To ask us not to process your Personal Information for a particular purpose, including for marketing.

All of these rights are subject to certain conditions and exemptions. To exercise any of these rights, please submit a written request to us using the contact information set forth below. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.

10. Conditions of Use and Changes to Our Privacy Policy

If you choose to visit our Site and attend our events, your visit and any dispute over privacy is subject to this Notice and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the State of Nevada. If you have any concern about our privacy practices, please contact us with a thorough description, and we will try to resolve it. As our business changes, our Privacy Policy and Terms of Use may change also. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

11. Contacting Us

This Site is owned and operated by Mullins & McGinn Publishing LLC. If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please contact us at:

Mullins & McGinn Publishing LLC
Attn: Legal

CCPA-Specific Requests: Please submit CCPA-specific data requests through the procedures set forth in Section 8.

Updated June 2026