COMPLIANCE STATEMENT:

MCL Sustainable Solutions is committed to protecting the privacy of individuals’ Protected Personal Data (PPD). MCL Sustainable Solutions employees are responsible for safeguarding PPD. Questions or concerns regarding a privacy violation or data incidents should be emailed directly to: info@mclgreen.com

I. Privacy Compliance Council:

  1. MCL Sustainable Solutions has designated Privacy Compliance Council, who will have the responsibility of leading the training of employees in the area of privacy compliance, and will implement this policy.

II. Key Privacy Policy Areas:

  1. Record Retention: It is the policy of MCL Sustainable Solutions to:
    1. (1) protect the security, integrity and the availability of records created or maintained in the course of business operations;
    2. (2) retain records in accordance with applicable laws and regulations, and
    3. (3) endeavor to ensure that records that are no longer needed or of no value are discarded at the appropriate time.
    4. Limit the use of personal information to the purposes identified in the notice and for which the individual has provided implicit or explicit consent. Retains personal information for only as long as necessary to fulfill the stated purposes or as required by law or regulations and thereafter appropriately disposes of such information.
  2. Data Breach Notification: MCL Sustainable Solutions will investigate and provide notice of information security incidents to affected individuals and/or Federal and State agencies in accordance with applicable Federal and State requirements.
  3. Marketing Information (Websites): MCL Sustainable Solutions collects the IP (Internet protocol) addresses of all visitors to our Sites and other related information such as page requests, browser type, operating system and average time spent on our Sites. We use this information to monitor and improve our Sites. This information will not be shared with third parties without permission. We may share business information about MCL Sustainable Solutions business customers with MCL Sustainable Solutions Service Providers (if a special service is not provided directly by MCL Sustainable Solutions) to provide business customers with tailored information about products and services and special offers.
  4. Consumer Accounts: MCL Sustainable Solutions will not share the personal Data of its customers. MCL Sustainable Solutions will maintain confidentiality all personal information of its customers, and will work to prevent any data incident resulting in the loss of customer information.
  5. Consumer Accounts: MCL Sustainable Solutions will not share the personal Data of its customers. MCL Sustainable Solutions will maintain confidentiality all personal information of its customers, and will work to prevent any data incident resulting in the loss of customer information.

III. Response to Privacy Violations:

MCL Sustainable Solutions has established disciplinary procedures to handle violations of the privacy policy.

  1. Privacy Violation Procedure:
    1. In the event of a potential privacy violation, Privacy Council will initiate an investigation and determine if there has been a violation of the policy.
    2. If Privacy Council finds a privacy policy violation, Privacy Council will meet with the employee who caused the violation and will review the privacy policy with the employee, if Privacy Council determines that the incident is minor. If the Privacy Council determines that the incident is a major violation of the Privacy Policy or is an incident that is in violation of the law, or an incident that could result in possible litigation the violating employee may be subject to discipline, including but not limited to termination.
  2. Remedy of a Privacy Violation
    1. In the event of a Privacy Violation, Privacy Council will take all action necessary to mitigate and limit the harm caused by the violation.
    2. If a privacy violation is likely to lead to litigation Privacy Council shall immediately inform the General Counsel, as well as MCL Sustainable Solutions Executive Management.

IV. Changes to Privacy Policy:

  1. Any changes to either the MCL Sustainable Solutions Privacy Policy or MCL Sustainable Solutions Privacy Compliance Policy must be approved by Privacy Council.
  2. Any changes to either the MCL Sustainable Solutions Privacy Policy or MCL Sustainable Solutions Privacy Compliance Policy must be approved by Privacy Council.

V. Privacy Compliance Monitoring:

  1. Documentation:
    1. MCL Sustainable Solutions will maintain all documentation related to the Privacy Compliance Program for at least Six Years after the information was created or last in effect.
    2. All administrative actions taken by Privacy Council will be documented, and maintained in written and electronic form.
  2. Annual Privacy Compliance Auditing: MCL Sustainable Solutions establishes an annual auditing plan to ensure the effectiveness of the Privacy Compliance Program and Privacy Policy. The Privacy Compliance Audit will identify areas of risk in which MCL Sustainable Solutions needs to improve its Privacy Compliance Program, Make necessary changes to Comply with any new laws and regulations, and review all incidents pertaining to the company’s privacy policy in order to mitigate future potential damages from occurring.