Milabro, Inc. (“Milabro,” “we,” “us”) has adopted this privacy policy (the “Privacy Policy”), which describes how we collect, use and share personally identifiable information (such as your full name, email address or mobile number) (“PII”) we obtain online and offline from and about individuals located in the United States.
The Milabro.com web site (www.milabro.com)(the “Site”) is a general audience web site, and we do not knowingly collect PII from children under 13 years of age.
Our Privacy Policy applies to “Visitors,” which means that you simply browse or use the Site, “Subscribers,” which means that you have subscribed to receive one or more Milabro newsletter, email alerts or partner emails, and “Members,” which means that you have registered with Milabro. The term “User” refers to a Visitor, Subscriber or a Member. By using the Site, you signify your agreement with all the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site. Our Privacy Policy does not apply to those web sites that do not display or link to this Privacy Policy or that have their own privacy statements.
Milabro may modify this Privacy Policy at any time. Each such modification will be effective upon posting on the Site and the effective date will be noted at the beginning of such revised Privacy Policy. Your continued use of the Site after Milabro posts a revised Privacy Policy on the Site signifies your acceptance of the revised Privacy Policy. Therefore, you should review the Privacy Policy periodically so that you are up to date on our most current policies and practices. If Milabro materially changes its practices regarding collection or use of your PII, your PII will continue to be governed by the Privacy Policy under which it was collected unless you have been provided notice of, and have not objected to, such change. In the event the last e-mail address you provided to us is not valid or is not capable of delivering the notice to you, Milabro’s dispatch of an e-mail containing the notice to that e-mail address shall nonetheless constitute effective notice.
Because the Milabro services are hosted in the United States, if you are a User located outside the United States, you understand and consent to having any PII and non-PII you provide transferred to and processed in the United States. The data protection and other laws of other countries, such as the United States, may not be the same as those in your jurisdiction. As a result, please read this Privacy Policy with care.
A. COLLECTION: COLLECTION OF PII AND NON-PII BY Milabro (“What Data Do We Collect”)
1. General. When Milabro collects PII from you it is because you are voluntarily submitting PII to us in order to register as a Member or a Subscriber. Milabro may also collect PII from you so that you can participate in activities like creating a personal profile (“Your Profile”), sweepstakes, contests, surveys, forums, in connection with questions you submit to us, or because you want us or a third party to furnish you with products, services or information. You are responsible for ensuring that the PII you provide is accurate and up-to-date. We may also obtain PII from reputable third parties or supplement PII that we have collected directly from our Users with additional PII or non-PII from reputable third parties.
In addition, Milabro collects non-PII including, without limitation, IP address, aggregate User data, and browser type. This non-PII data is used to manage and improve the Milabro services, enhance your experience on the Site, track usage, and for security purposes. Our primary service provider for collecting and processing site data and behavior is Google. You can find more information on Google’s processing activities, by clicking on the following link (https://www.google.com/policies/technologies/partner-sites/). We have also entered into Data Processing Amendments with third-party data and advertising partners, where necessary, to ensure compliance with all relevant local, national, and international regulations.
You may also choose to voluntarily provide or store non-PII in Your Profile (as described in Section A (1) (a) below) or on message boards or other public forums, including but not limited to, text, files, images, photos, video, musical works, works of authorship, personal statements, comments or any other materials (collectively “Content”) that you choose to post to the Site (Content posted by any User is “User Content”). If you choose to store your Profile Information (as defined below in Section A (1) (a)), User Content or any PII on Your Profile, or provide any Profile Information, PII or User Content on message boards or other public forums provided on the Site, this information and content will be made public and you do so at your sole discretion and risk.
As noted above with regards to Google’s Data Activities on our site(s) as well as others across the web, the following resources may be helpful for you in understanding, changing, updating, and maintaining your profile data with Google. These pages provide you with detailed information and give you control over your data with Google:
Myaccount.google.com
Myactivity.google.com
Privacy.google.com
Important Information about Changing and Updating your Registration Data and Your Profile Information. Members can change, correct, edit or remove their Registration Data (as defined below in Section A (1) (a)) and Your Profile information at any time and can control how Users and Milabro communicate with them by controlling their profile settings and privacy settings, available within the “Edit Profile” portion of the Profile section located in the Community section of the Site.
Milabro collects information from you at several different points on the Site in the manner set forth below:
(a). Member Registration and Your Profile: In order to access certain information and services on the Site, you must first register to become a Member by completing the Milabro registration credentials. During the Member registration process you will be required to provide registration data, which may include PII such as your full name and e-mail address (such PII is the “Registration PII”) and non-PII such as a password (“Registration Non-PII,” collectively with Registration PII, the “Registration Data”). You may also choose to voluntarily provide or store PII (such as your first and last name), non-PII and User Content in Your Profile (such information is your “Profile Information”). During the registration process you will also be required to create a “User Name.” The User Name you provide will automatically be incorporated into Your Profile and will be made public. Please choose your User Name carefully; if you do not want your full name to be public, do not use it as your User Name. The Profile Information you include in Your Profile will automatically be made public and you provide it at your own discretion and risk.
(b). Newsletters; Email Alerts: During the subscription process you will be required to provide subscriber data, which may include PII such as your full name and e-mail address (such information is the “Subscriber PII”) and zip code (such information is the “Subscriber Non-PII,” collectively with Subscriber PII the “Subscriber Data”). If you would like to unsubscribe from any Milabro newsletter or email alert, please use the unsubscribe link on the bottom of such newsletter or email.
(c) Sweepstakes, Contests and Promotions: On the Site, you may have the opportunity to participate in sweepstakes, contests and other promotions that may require you to provide PII or other information about yourself. If and when we sponsor sweepstakes, contests or other promotions, or third parties sponsor such sweepstakes, contests or promotions with us, either we or the third party will post relevant privacy information in the official rules and/or registration area for the sweepstakes, contest or promotion. That privacy information, to the extent it conflicts with this Privacy Policy, will govern that particular sweepstakes, contest or promotion—please remember to read it carefully.
2. Cookies. Cookies are small bits of information that the Site places on the hard drive of your computer. Milabro uses cookies to identify your Internet browser, store your Milabro username for easy logon, store Users’ preferences, keep you logged in, and identify parts of the Site you have visited, applications you are using, advertisements you have seen and/or products you have purchased. Information about your activities on the Site and other non-PII about you may also be used to customize the online ads you encounter to those we believe are consistent with your interests.
Milabro, or data providers we have engaged, use cookies to enable you to receive customized ads (either on our site(s) or in our outbound marketing efforts on other sites and platforms), content or services, and to provide Milabro with certain information that enhances and enriches the user experience and our ability to understand our audience and inform our content strategy.. No PII is placed into these cookies. The cookies may reflect demographic or other data linked to data you voluntarily have submitted to us, e.g., your e-mail address in hashed, non-human readable form. To opt-out of these cookies, please go to http://www.privacychoice.org/companies and http://www.aboutads.info/choices.
You can opt out of our in-app behavioral targeted advertising by changing the settings on your mobile device. On Apple devices, the setting may be under Settings-Privacy-Advertising-Limit Ad Tracking. On Android devices, the setting may be under Settings-Account & Sync-Google-Ads-Opt Out of Interest-Based Ads. For further information, please go to the following links with device-specific opt-out instructions.
iOS – https://support.apple.com/en-us/HT202074
Android – https://support.google.com/ads/answer/2662922?hl=en
Third party advertisements displayed on the Site may also contain cookies set by Internet advertising companies or advertisers. Milabro does not control these cookies and Users of the Site should check the privacy policy of the Internet advertising company or advertiser to see whether and how it uses cookies. (See Section C (Notice)
below for more information on third party advertisements).
For personal, browser-specific information on how you can adjust your cookie and privacy settings and configurations on your devices, we’ve compiled the following list of resources:
Internet Explorerhttps://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Firefoxhttps://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Chromehttps://support.google.com/chrome/answer/95647?co=GENIE.Platform=Desktop&hl=en
Safarihttps://support.apple.com/kb/ph21411?locale=en_US
Milabro may use cookies and similar technology to relate your use of the Site to PII obtained from you or a reputable third party. For example, if you have asked us to provide you information about our upcoming products or promotions, cookie and/or click stream data about your activities on the Site may allow us to limit the materials we provide you to items we think you will find interesting, based on your prior online activities and preferences.
You can program your computer to warn you each time a cookie is being set or to refuse cookies completely. However, without cookies you may not have access to certain features on the Site.
A pixel tag or web beacon is a tiny image inserted in a webpage and used to record the number and types of views for that page. Milabro may allow third party pixel tags or similar technology to be present on the Site for purposes of advertising, providing services or data and statistics collection. We also may use this type of technology in order to recognize Users and assess traffic patterns, and we may include pixel tags/web beacons in our e-mail messages, including newsletters, in order to understand the time and date of when a User has opened an e-email and when he/she has utilized a link within the e-mail to visit a website. These pixel tags/web beacons do not contain PII. Users wishing to disable our pixel tags/web beacons should do so by turning images “off” in their email client (e.g., Outlook, Outlook Express). Please see your e-mail client for more information.
Notwithstanding anything else in this policy, we or a data provider we have engaged may place or recognize a unique cookie on your browser to enable customized ads or content. No personally identifiable information is placed into these cookies. The cookies may reflect de-identified demographic or other data linked to data you have submitted to us, e.g., your email address, in hashed, non-human readable form. To opt-out of these cookies, please go tohttp://www.aboutads.info/choices.
Uses of cookies, web beacons, and similar technologies:
Our uses of such technologies fall into the following general categories:
- Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
- Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
- Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement. This information enables us to tailor our advertisements on third-party platforms like Facebook, Google, and other buying platforms and ensures that we can serve and target relevant ads to users on behalf of us and our advertising partners.
3. Message Boards and Public Forums: The message boards and public forums and similar features offered on the Site are for public and not private communications, and you have no expectation of privacy with regard to any PII, User Content or other information posted, submitted or distributed on or through a message board or public forum. Milabro cannot guarantee the security of any information you disclose through any of the message boards or public forums available on the Site, and you make such disclosures at your own discretion and risk.
4. Third Party Ad and Service Provider Disclosures and Resources
Certain of our Third-party Advertisement and Data Service Providers have provided resources and disclosures to help you understand their positions in our site, data, and privacy framework. Below are those disclosures and resources:
Exponential
Subject to your consent, Exponential Interactive, Inc collect and profile personal data in the form of IP address and cookie ID from users on our website in order to provide targeted online advertising and ad measurement. You may change your consent decision at any time via <insert details of your consent mechanism or Consent Management Platform here>. For more details including access requests and complaints, review their privacy policy or contact their data protection officer via [email protected].
Criteo
The purpose of Criteo Email is to find visitors of Criteo advertising clients’ properties (websites, apps and newsletters) and send them personalized emails. Criteo uses cookies to single out users and then personalize ads based on their browsing experience. To learn more or opt out of Criteo Email click here
(link to Criteo privacy policy at http://privacy.criteoemail.com/us/privacy-policy.html)
B. Collection of Personal Financial Information on the Site by an independent Third Party company
Milabro may use an independent third party company to process purchases and financial transactions on the Site. When an independent third party company selected by Milabro collects, transmits and/or processes your PII and your personal financial information, such as your credit card information or other payment information (collectively, “Personal Financial Information”), on the Site it is because you are submitting such Personal Financial Information in order to purchase any products or services offered from time to time on the Site. At the time of your purchase, Milabro will notify you of the identity of any third party that is collecting, transmitting and/or processing your Personal Financial Information. You must be 18 years of age or older to submit Personal Financial Information on the Site, including to place an order on the Site.
You acknowledge and agree that this Privacy Policy will not apply to any Personal Financial Information that you provide to any independent third party company on the Site and that all payment obligations related to such purchase shall be governed solely by the applicable independent third party company’s privacy policy. You further acknowledge and agree that Milabro will have no liability for or control over such independent third party company’s use or protection of your Personal Financial Information. You should check the privacy policy of the independent third party company‘s website to determine how it will handle any Personal Financial Information it collects from you and/or processes.
You acknowledge and agree that in the event that such independent third party company experiences a data breach that compromises or otherwise affects your Personal Financial Information, Milabro shall in no way be responsible or liable to you for such breach. You should contact the applicable independent third party company regarding any such data breach.
C. NOTICE:MILABRO WILL PROVIDE YOU WITH NOTICE ABOUT ITS PII AND NON-PII COLLECTION PRACTICES
When you voluntarily provide PII to Milabro, we will make sure you are informed about who is collecting the information, how and why the information is being collected and the types of uses Milabro will make of the information.
At the time you provide your PII, Milabro will notify you of your options regarding our use of your PII, including whether we will share it with outside companies (See Section D (Choice) below). This Privacy Policy describes the types of other companies that may want to send you information about their products and services and therefore may want to share your PII, provided you have given Milabro permission to do so (See Section E (Use) below).
Sometimes we collect PII from consumers in an off-line or manual format, such as by mobile phone. Providing detailed notice in those situations often proves impractical, so consumers will instead be provided with a short notice that describes how to obtain the full text of this Privacy Policy and other relevant information from us.
The Site may be linked to Internet web sites operated by other companies. Some of these third party web sites may be co-branded with a Milabro logo, even though they are not operated or maintained by Milabro (for example, the co-sponsored chat pages, advertising sponsor pages or product purchase pages). The Site also carries advertisements from other companies. Milabro is not responsible for the privacy practices of web sites operated by third parties that are linked to the Site, for the privacy practices of third party or national Internet advertising companies or for third party payment processing companies selected by Milabro. Once you leave a Milabro Site via such a link or by clicking on an advertisement, Milabro Privacy Policy no longer applies and you should check the applicable privacy policy of the third party or advertiser web site to determine how they will handle any PII they collect from you.
The Site may also be linked to web sites operated by companies affiliated with Milabro. Visitors to those affiliated web sites should still refer to their separate privacy policies and practices, which may differ in some respects from this Privacy Policy.
Some of the advertisements that appear on Milabro’s Site are delivered to you by national Internet advertising companies. These companies utilize certain technologies to deliver advertisements and marketing messages and to collect non-PII information about your visit to the Site, including information about the advertisements they display, any cookie they place on your computer and your IP address. To opt out of information collection by these companies, or to obtain information about the technologies they use or their own privacy policies, please visit:http://www.networkadvertising.org/managing/opt_out.asp.
D. CHOICE:Milabro WILL PROVIDE YOU WITH CHOICES ABOUT THE USE OF YOUR PII
Milabro will not use the PII you provide to us for purposes different from the purpose for which it was submitted unless otherwise provided in this Privacy Policy (See Section E (Use) below). Milabro will not share your PII with third parties that are not affiliated with Milabro, unless we obtain your permission or as otherwise provided in this Privacy Policy (See Section E (Use) below).
E. USE: Milabro’s USE OF PII
Milabro will use your PII provided under this Privacy Policy in a manner that is consistent with this Privacy Policy. If Milabro obtains PII from a third party, such as a business partner, our use of that PII is governed by this Privacy Policy.
Milabro may occasionally send Users information about special offers, Site updates, contests and other offerings via e-mail. We may also send information about products and offerings of our partners or other affiliated companies that we think may be of interest to our Users. To opt out of receiving these messages, click on the opt-out link at the bottom of our e-mails.
Milabro may also share your PII with affiliated companies. In addition, Milabro may share your PII with advertisers and business partners that are not affiliated with Milabro, but would like to send you information about their products and services. For example, Milabro may share your PII with the companies who supply prizes for Milabro’s contests and may have special offers or promotions that might be of interest to Milabro users.
Milabro employees, agents and contractors must have a legitimate business or legal reason to access your PII. Milabro may share your PII with outside contractors or agents who help us provide you with services or products or who help us manage our information activities, but they may only use your PII to provide Milabro with a specific service and not for any other purpose. For example, if you enter a sweepstakes on the Site, your PII may be shared with our sweepstakes administrators.
Milabro may also enter into agreements with outside companies that possess the technology that allows Milabro to customize the advertising and marketing messages you receive on the Site. Your Non-PII and click stream data about your activities on the Site may be shared with these companies so this customization may be accomplished. Anonymous click stream and demographic information may also be shared with Milabro’s advertisers and business partners.
There may be instances when Milabro may disclose PII without providing you with a choice in order to protect the legal rights of Milabro, other affiliated companies or any of their employees, agents and contractors; to protect the safety and security of any person, including, without limitation, Users of the Site, or the public; to protect against fraud or for risk management purposes; or to comply with the law or legal process. In addition, if Milabro sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Milabro may transfer your PII to a third party as part of that transaction.
F. SECURITY:Milabro PROTECTS THE SECURITY OF PII
Milabro uses reasonable administrative, technical, personnel and physical measures to safeguard PII in its possession against loss, theft and unauthorized use, disclosure or modification. However, no security system is impenetrable. Milabro cannot warrant or guarantee the security of its servers, nor can it guarantee that any information, including, without limitation any PII, that you supply will not be intercepted while being transmitted to Milabro over the Internet. Additionally, as outlined in our DPAs with third-party processors, Milabro will also be notified promptly by our third-party data processors of any breach of their systems so we can notify users immediately.
ACCESS: HOW TO ACCESS, CORRECT OR DELETE YOUR PII
Whenever possible, Members and Subscribers may review the PII we maintain about them in our records. We will take reasonable steps to correct any PII a Member or Subscriber informs us of in writing is incorrect.
If for any reason you want Milabro to stop using your PII, Milabro will honor that request; however, Milabro will retain any record of your PII that is necessary to comply with applicable federal, state or local law. Even after removal of PII and User Content by you or Milabro, PII and User Content may still be viewable in cached and archived pages or if another User has stored your User Content.
H. REMEDIES AND COMPLIANCE: HOW TO CONTACT Milabro’s ABOUT PRIVACY CONCERNS
If you have questions or concerns regarding privacy, your use of the Milabro’s Site, or the collection and use of PII, you may contact Milabro E-mail: [email protected]