Legal

Ownership of Site; Agreement to Terms of Use

These Terms and Conditions of Use (the “Terms of Use”) apply to the Michael D. Brown web site located at www.themichaeldbrown.com.

The Site is the property of MICHAEL D. BROWN COMPANY, INC. (“MDB”) and its licensors. BY USING THE SITE, YOU AGREE TO THESE TERMS OF USE; IF YOU DO NOT AGREE, DO NOT USE THE SITE.

MDB reserves the right, at its sole discretion, to change, modify, add or remove portions of these Terms of Use, at any time. It is your responsibility to check these Terms of Use periodically for changes. Your continued use of the Site following the posting of changes will mean that you accept and agree to the changes. As long as you comply with these Terms of Use, MDB grants you a personal, non-exclusive, non-transferable, limited privilege to enter and use the Site.

All text, graphics, user interfaces, visual interfaces, photographs, trademarks, logos, sounds, music, artwork and computer code (collectively, “Content”), including but not limited to the design, structure, selection, coordination, expression, “look and feel” and arrangement of such Content, contained on the Site is owned, controlled or licensed by or to MDB, and is protected by trade dress, copyright, and trademark laws, and various other intellectual property right laws.

Except as expressly provided in these Terms of Use, no part of the Site and no Content may be copied, reproduced, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way (including “mirroring”) to any other computer, server, Web site or other medium for publication or distribution or for any commercial enterprise, without MDB’s express prior written consent.

Privacy Policy

Data Protection Policy

The Michael D. Brown Company, Inc.

1. Data protection principles

The Michael D. Brown Company, Inc. is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General provisions

1. This policy applies to all personal data processed by The Michael D. Brown Company, Inc.
2. The Responsible Person shall take responsibility for The Michael D. Brown Company, Inc. ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, The Michael D. Brown Company, Inc. shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to The Michael D. Brown Company, Inc. shall be dealt with in a timely manner.

4. Lawful purposes

1. All data processed by The Michael D. Brown Company, Inc. must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
2. The Michael D. Brown Company, Inc. shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in The Michael D. Brown Company, Inc.

5. Data minimisation

1. The Michael D. Brown Company, Inc. shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

1. The Michael D. Brown Company, Inc. shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, The Michael D. Brown Company, Inc. shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

1. The Michael D. Brown Company, Inc. shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, The Michael D. Brown Company, Inc. shall promptly assess the risk to people rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).