PERSONAL INFORMATION – PRIvACY POLICY

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MENA Counseling Services understands the importance of maintaining the privacy of your personal information. For the purposes of the GDPR, MENA Counseling Services is both the “data controller” and a “data processor” of personal information. Our Privacy Policy below is intended to describe to you how and what data we collect, and how and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process.

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What information do we collect?

We collect and hold your personal information which may include your name, email address, phone number, mailing address, date of birth, type of animal(s), number of animals, historical information that you provide, questionnaire responses, other data collected that could directly or indirectly identify you, and any other information you have submitted to supply our products and services to you. We may also collect your bank or credit card details and details about payments you have made.

Information you provide to us about yourself (through the questionnaire on our website or otherwise) may be accessed by our employees, principals, agents, independent contractors and the licensed healthcare professionals we work with. Such access may be for the purpose of connecting you with a licensed healthcare professional, evaluating your eligibility for an emotional support animal and performing other actions related to fulfilling your order or request with us.

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We may also collect non-personally identifiable information about you (such as anonymous usage data, IP addresses and location, browser or platform type, etc).

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any products or services purchased or required for our legitimate business purposes or legal or contractual recordkeeping requirements.

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Sharing with trusted third parties

We may share your personal data with affiliated companies within our corporate family, with third parties we have partnered with to allow us to integrate their services into our own services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:

Processing credit card payments

Evaluating your questionnaire

Assessing your submitted information for any services

Conducting contests or surveys

Performing analysis of our services and customers demographics

Communicating with you, such as by way of email or survey delivery

Client relationship management

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for.

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Communicating with you

We may contact you directly or through a third party service provider regarding services you have signed up for or purchased from us. We may also contact you with offers for additional services we think you may find valuable if you give us consent, or where allowed based upon legitimate interests. These contacts may include:

Email

Text (SMS) messages

Telephone calls

Automated phone calls or text messages.

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Transfer of personal data abroad

If you are located outside the United States of America, and your location has laws governing data collection and use that differ from U.S. law, note that you are transferring your personal information to the U.S., and in such context, you are consenting to such transfer by providing your personal information.

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Website analytics

We use multiple web analytics tools provided by service partners such as Google Analytics, MixPanel and Singular to collect information about how you interact with our Website, including what pages you visit, what site you visited prior to visiting our Website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our products and services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our Website. Each cookie cannot be used by anyone other than the service provider (ex: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies.

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Third-party websites

Our website and our mobile applications contain links to third-party websites. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit.

How we secure, store and retain your data

We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.

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We retain personal data only for as long as necessary to provide the products or services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:

mandated by law, contract or similar obligations applicable to our business operations;

for preserving, resolving, defending or enforcing our legal/contractual rights;

needed to maintain adequate and accurate business and financial records; or

for auto-renewal billing.

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If you have any questions about the security or retention of your personal data, you can contact us at *protected email*.

California Residents Privacy Notice

Effective January 1, 2020, the California law known as the California Consumer Privacy Act (“CCPA”) allows, with some exceptions, California residents to request that a business that collects consumers’ personal information to give consumers access to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with the CCPA, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information.

Notice to Business-to-Business Consumers: Many of the obligations imposed by the CCPA currently do not apply to personal information reflecting communications or transactions between the business and a California resident where the resident is acting on behalf of another business, e.g., a business-to-business transaction. If your personal information is being processed within this context, your rights under the CCPA are limited.

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Your Rights Under California Law

The following are your rights under California law:

To request that the business disclose what personal information (about you) it collects, uses, discloses, and sells.

To request deletion of your personal information collected or maintained by the business. This right is limited, and we may not always honor your request, particularly when it is necessary to maintain your information for legal purposes or to complete the business we have with you.

To opt-out of the sale of your personal information by the business. A “sale” occurs when your personal information is exchanged with a, non-service provider, third party in exchange for valuable consideration. It is not a sale when you intentionally authorize us to disclose your personal information or interact with a third party. To exercise your right to opt-out, please contact us at *protected email*.

To not receive discriminatory treatment by the business for exercising any of the privacy rights conferred under the CCPA.

Exercising Your Rights Under the CCPA

How to make a disclosure request: You may request these disclosures by contacting us at *protected email*. You have the right to make a free request two times in any 12-month period. We will make the disclosure within 45 days of receiving your request, unless we request an extension. In the event that we reasonably need a 45-day extension, we will notify you of the extension within the initial 45-day period.

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Right of deletion: You have the right to request that we delete your personal information, subject to certain exceptions. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information, unless an exception applies. Contact us at *protected email* to delete your data.

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The CCPA permits using a designate an authorized agent to make a request on a consumer’s behalf. You may designate an agent by filling an agent-designation form. Both the designated agent and the consumer are subject to verification before accepting a consumer rights request.

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All consumer rights requests are subject to verification by us. We verify requests by matching the information provided by the consumer to the personal information of the consumer already maintained by the business. In some instances, we may use your contact information to contact you in order to verify your identity.

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Residents of the state of California have the right to request certain information from us with respect to the types of personal information we share with third parties for their direct marketing purposes, as well as the identities of the third parties we have shared such information with during the immediately preceding calendar year. To exercise your choices, please contact us at *protected email*.