Thank you for visiting the Mandel website (the “Website”), which is owned and maintained by Mandel Communications, Inc. (“Mandel”). Our clients’ and partners' information is important to us, and we are committed to maintaining the confidentiality of the information we receive. This statement governs the information you provide to Mandel or that we learn from your use of this website and any services provided from this Website. Our privacy policy below discusses the types of information we collect, how we use it, and under what circumstances, if any, that we might disclose it. By accepting the Privacy Policy and Terms and Conditions in using the Website, you expressly consent to Mandel's use and disclosure of your personal information as described in this Privacy Policy.

This privacy policy, and Mandel's use of information collected on this Website, are based on the US-EU Directive on Data Protection Safe Harbor principles.

Note: One of the primary Safe Harbor principles is “Notice”. This principle provides that an organization must inform individuals about the purposes for which it collects and uses information about them, how to contact the organization with any inquiries or complaints, the types of third parties to which it discloses the information, and the choices and means the organization offers individuals for limiting its use and disclosure. This privacy policy describes how Mandel adheres to these principles.
We collect no personally identifiable information about you when you visit our site unless you choose to provide that information to us. Mandel collects only the information needed to administer our business and to provide our clients and partners (each, a “Client” or a “Partner” and collectively, “Clients” or “Partners”, respectively) with our products and services. We will not give, sell, share or rent this information to others, except as disclosed in this Privacy Policy.
Note: Under the “Data Integrity” Safe Harbor principle, information that we collect must be relevant for the purposes for which it is to be used, and no more information will be collected than is required to satisfy the purpose for which it is collected. Also, in compliance with the “Sensitive Information” Safe Harbor principle, so-called "sensitive" data, such as that pertaining to racial or ethnic origins, political or religious beliefs, or health or sex life, will not be requested.

While using our Website, you have the option to provide personal profile information in a form, which may include your name, title, company, mailing address, phone number, and email address.

The personal information that we collect is used to manage, administer and develop our relationship with you and as you request including:

• Rendering our services to you;
• Receiving requests for white papers;
• Sending emails to workshop participants, with pre- and post-workshop surveys;
• Collecting pre-work information;
• Transmitting evaluation forms;
• Issuing workshop participant lists for trainers
• Receiving reinforcement suggestions;
• Verifying the accuracy of personal information we receive;
• Measuring the number of visitors to our Website;
• Helping us to make our Website more useful to visitors; and
• Protecting our rights or interests or the rights or interests of others including you and other Mandel Clients or Partners as described elsewhere in this policy.

While Mandel does not generally share personal information with others for their marketing purposes unless or except as described here, we may share aggregate information derived from personal information. The shared aggregated information is not personally identifiable.
Because of the way that World Wide Web communication standards work, when you arrive at or leave the Mandel Website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Website you visit while, the type of browser you use and the times you access our Website. We use this information only to try to understand our Clients' and Partners' preferences better and to manage the speed and response time of our own Website pages (i.e. load on our servers), so as to improve our service and your experience with Mandel. We do not track the Websites that you visit before or after you leave the Mandel site.
We only use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use. Any such data will be stored for a limited period of time (generally no more than 3 years from the date collected).
“Cookies” are small files of data that reside on your computer and allow us to recognize you if you return to the Website using the same computer and browser. We send a “session cookie” to your computer if and when you log in to your Mandel account by entering your e-mail address and password. These cookies allow us to recognize if you visit multiple pages during the same session, reducing the need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display some of the information that you may need to complete various forms on the Mandel website to reduce the need to retype the information each time you log in to your Mandel account.
If you send us correspondence, including e-mails and faxes, we may retain such information in the records of your account. We may also retain Client service correspondence and other correspondence from Mandel to you. We retain these records in order to measure and improve our Client service, and to investigate potential fraud and violations of our Terms and Conditions and to otherwise protect Mandel' legal interests and the interests of others. We may, over time, delete these records if permitted by law.
Note: The following provisions describe how Mandel adheres to the “Onward Transfer” Safe Harbor principle, which is intended to assure that there is as little leakage of data from Safe Harbor protections as possible.

Mandel will not sell or rent your personal information to others for their marketing purposes. Mandel may validate personal information you provide, or request additional information from credit bureaus or other third parties, to assist us in establishing and authenticating your account, and verifying the accuracy of the information that you provide. Information obtained from third parties and linked with your personal information is safeguarded by confidentiality agreements and to the extent required by law.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Website

When we partner with another party to provide specific services, and a Client signs up for those services, we share only the contact information that is necessary for the third party to provide such services. Third parties are not authorized to use personal information except for the purpose of providing those services. Otherwise, Mandel will not share or give your personal information to others unless in the rare case that Mandel believes it is necessary to cooperate with regulators or law enforcement authorities or similar legal request including the protection of our rights or the rights of others. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register on or use this Website.
Our Website may contain links to other sites. Mandel is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they are leaving our site and to read the privacy policies of each website that collects personally identifiable information. This Privacy Policy applies solely to information collected by Mandel through the Website.
Note: Under the “Security” Safe Harbor principle, we are required to take "appropriate technical and organizational measures to protect data" against destruction, loss, alteration, or unauthorized disclosure or access. The following provisions describe the measures that Mandel takes in compliance with this principle.

All data access is based on a need-to-know basis. Any secure protected area(s) of the Website may allow our Clients, using a unique username and password, to access account information, depending on their entitlements and account setup.

Our employees are regularly notified and/or reminded about the importance we place on privacy, and the steps they should take to protect our Clients' information.

Mandel uses industry-standard security measures to protect the integrity and confidentiality of information it processes on behalf of Clients and Partners, including, in appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions. Mandel limits access to personal information to those persons in Mandel's organization who have a business need to process such information.

While we make reasonable efforts to ensure security on our systems, no company, including Mandel, can guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of administrative, managerial and technical safeguards. For additional details on how we secure your personal information, please write to policy@Mandelcom.com.

If Mandel learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By submitting your personal information to Mandel, you agree that Mandel may communicate with you electronically. Mandel may post a notice on this Website if a security breach occurs. If this happens, you will need a web browser enabling you to view the Mandel Website. Mandel may also send you an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us at policy@Mandelcom.com.
Please note that your personal information will be stored and processed in the United States and that by providing your personal information to Mandel, you expressly consent to the transfer and processing of your personal information in the United States and elsewhere as Mandel deems necessary fulfill the purposes described in this Privacy Policy. The laws on holding personal information in the United States may be less stringent than the laws of your country but, Mandel strives to maintain the confidentiality and security of personal information of individuals who may be outside the United States. If Mandel should ever file for bankruptcy or have its assets sold to or merged with another entity, information Mandel receives through your use of the Website is a Mandel asset and may be transferred except to the extent the law may prohibit such transfers. We may occasionally update this Privacy Policy. When we do, we will also revise the “effective date” on the Privacy Policy. For changes to this policy that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will attempt to obtain your consent before implementing the change. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of this Website constitutes your agreement to this Privacy Policy and any updates. Note: Under the “Choice” Safe Harbor principle, your consent is required before we process any of the data that you provide to us. In addition, under the “Access” Safe Harbor principle, you will always have a right to review your data that we process, to correct any information that is inaccurate, or to know who will receive the data.

If you have a privacy concern regarding Mandel or this policy and if you cannot satisfactorily resolve it through the use of this Website you should then write to: policy@Mandelcom.com, or 820 Bay Avenue, Suite 113, Capitola, CA 95010 USA, or phone us at 831-475-8200. You should also use these means to “opt out” of receiving communications from us or from having your information used for certain purposes. Mandel is committed to cooperating to achieve a proper resolution of your privacy concerns. Permission to use documents (such as service information, press releases, fact sheets and FAQs) from this server is granted, provided that the Mandel copyright notice appears in all copies, (2) use of such documents from this server is for informational and noncommercial or personal use only and will not be copied or posted on any network computer or broadcast in any media, and (3) no modifications of any documents are made.

Use for any other purpose is expressly prohibited by law, and may result in severe civil and criminal penalties. Violators will be prosecuted to the maximum extent possible.

All information on this server is provided on an as-is basis. Mandel makes no warranties, express or implied, as to the accuracy and correctness of the information. In no event shall Mandel be liable for any damages whatsoever resulting from the use of this information. Mandel is a registered trademark of Mandel Communications, Inc. All other products are trademarks and registered trademarks of their respective companies.

The practices described in this privacy policy statement and terms of use are current personal data protection policies and related terms. Mandel reserves the right to modify this privacy policy and these terms of use at any time. We will promptly reflect any such modifications on the Website.

Effective Date: August 22, 2007