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.
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:
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.
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.
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:
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:
- 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:
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 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.
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
E. USE: Milabro’s USE OF PII
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]