Privacy Policy

Effective Date: September 12, 2016

This Privacy Policy governs the manner in which Modern Guild, Inc (“ModernGuild”) collects, uses, maintains, and discloses information collected from users (each, a “User”) of its www.modernguild.com website and any derivative or affiliated websites on which this Privacy Policy is posted (collectively, the “Website”). ModernGuild reserves the right, at its discretion, to change, modify, add, or remove portions of this Privacy Policy at any time by posting such changes to this page. You understand that you have the affirmative obligation to check this Privacy Policy periodically for changes, and you hereby agree to periodically review this Privacy Policy for such changes. The continued use of the Website following the posting of changes to this Privacy Policy constitutes an acceptance of those changes going forward from the date of the revision.

IF YOU ENTER INTO OUR STUDENT PARTICIPATION AGREEMENT, MODERNGUILD’S COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION THAT YOU PROVIDE TO MODERNGUILD UNDER THE STU- DENT PARTICIPATION AGREEMENT WILL BE GOVERNED BY THE TERMS OF THE STUDENT PARTICIPATION AGREEMENT AND NOT BY THIS PRIVACY POLICY.

1. Privacy

ModernGuild believes that every User should know how it utilizes the information collected from Users. The Website is not designed for or directed to children under 13 years of age, and ModernGuild does not knowingly collect per- sonally identifiable information from children under 13. Please note that the Website may contain links to other web- sites. These linked sites may not be operated or controlled by ModernGuild. ModernGuild is not responsible for the privacy practices of these or any other websites, and you access these websites entirely at your own risk. Modern- Guild recommends that you review the privacy practices of any other websites that you choose to visit. ModernGuild is based, and the Website is hosted, in the United States of America. If User is from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law and User is registering an account on the Website, visiting the Website or otherwise using the Website, please note that any personally iden- tifiable information that User provides to ModernGuild will be transferred to the United States. Any such personally identifiable information provided will be processed and stored in the United States by ModernGuild or a service provider acting on its behalf. By providing your personally identifiable information, User hereby specifically and ex- pressly consents to such transfer and processing and the uses and disclosures set forth herein.

2. The Information ModernGuild Collects

Users browsing the Website without registering an account or affirmatively providing personally identifiable informa- tion to ModernGuild do so anonymously. Otherwise, ModernGuild may collect personally identifiable information from Users in a variety of ways. Personally identifiable information may include, without limitation, (i) contact data (such as first name, last name, phone-number, and e-mail address); (ii) demographic data (such as time zone); and (iii) billing data (such as credit card number and expiration date). If User communicates with ModernGuild by e-mail or other- wise or interacts with or uses the features on the Website, any information provided in such communications may be collected by ModernGuild. ModernGuild may also collect information about how Users use the Website, for example, by tracking the number of unique views received by the pages of the Website, the domains and IP addresses from which Users originate and other information made available via website traffic-analytics services. While not all of the information that ModernGuild collects from Users is personally identifiable, it may be associated with personally iden- tifiable information that Users provide ModernGuild through the Website or otherwise. ModernGuild may use “cook- ies” or “web beacons” to track how Users use the Website. A cookie is a piece of software that a web server can store on Users’ PCs and use to identify Users should they visit the Website again. Users may adjust their web browser software if they do not wish to accept cookies.

3. How ModernGuild Uses Information

ModernGuild may use personally identifiable information collected through the Website (i) for the specific purposes for which the information was collected; (ii) to contact Users with e-newsletters and special announcements; (iii) to contact Users regarding information and services offered by ModernGuild and other related companies and its trusted affiliates, independent contractors, and business partners; (iv) to contact Users regarding their experiences on the Website; and (v) to otherwise enhance Users’ experience with ModernGuild and such affiliates, independent contrac- tors, and business partners. All data submitted by visitors to the ModernGuild website may be stored and used at will by ModernGuild to better serve its clients. This includes, but is not limited to, sharing data (such as ethnicity, race,

gender, graduation year, school attended, employment preferences) with partner companies for more transparent recruitment, screening and interviewing. In cases where sensitive data is being shared, individual identifying informa- tion (mainly the User’s full name) will be hidden. ModernGuild may also use information collected through the Web- site for research regarding the effectiveness of the Website and the business planning, marketing, advertising, and services efforts of ModernGuild, its trusted affiliates, independent contractors, and business partners. ModernGuild may also use the aggregate data, with any information that could be used to identify an individual or individual firm removed, collected through the Website to perform statistical analysis of the aggregate data. ModernGuild may pub- lish statistical analysis of the aggregate data.

4. Disclosure of Information

ModernGuild may disclose personally identifiable information collected from Users to its employees and related com- panies, if any, and trusted affiliates, independent contractors, and business partners who will use the information for the purposes outlined above, as necessary to provide the services offered by ModernGuild and to provide the Web- site itself, and for the specific purposes for which the information was collected. ModernGuild may disclose personally identifiable information if required to do so by law enforcement or governmental agencies or in response to subpoe- nas, court orders, or other legal processes, to establish, protect, or exercise ModernGuild’s legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. ModernGuild may disclose personally identi- fiable information in order to protect the rights, property, or safety of User or any other person. ModernGuild may dis- close personally identifiable information to investigate or prevent a violation by User of any contractual or other rela- tionship with ModernGuild or the perpetration of any illegal or harmful activity. ModernGuild may also disclose aggre- gate, anonymous data based on information collected from Users to sponsors, investors, and/or potential partners. Finally, ModernGuild may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation, or other reorganization of its business.

5. Security of Information

Information about Users that is maintained on ModernGuild’s systems is protected using commercially reasonable security measures. However, no security measures are perfect or impenetrable, and ModernGuild cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. Modern- Guild is not responsible for the circumvention of any privacy settings or security measures relating to the Website by any Users or third parties.

If User’s personally identifiable information changes (such as e-mail address or zip code), or if User no longer desires to receive non-account specific information from ModernGuild, ModernGuild will endeavor to provide a way to correct, update, and/or remove that User’s previously-provided personal data. This can be done by emailing a request to ModernGuild at info@modernguild.com. Additionally, Users may request access to the personally identifiable informa- tion as collected by ModernGuild by sending a request to ModernGuild accordingly. Please note that in certain cir- cumstances, ModernGuild may not be able to completely remove User’s information from its systems. For example, ModernGuild may retain User’s personal information for legitimate business purposes, if it may be necessary to pre- vent fraud or future abuse, for account recovery purposes, if required by law, or as retained in ModernGuild’s data backup systems or cached or archived pages. All retained personally identifiable information will continue to be sub- ject to the terms of the Privacy Policy to which User has previously agreed.

7. Contacting ModernGuild

If you have any comments or questions, please do not hesitate to contact ModernGuild at Phone: 917-860-7059 E-mail: info@modernguild.com