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Privacy Policy

Milvian Group Privacy Policy

Last Updated: July 8, 2024 

This Privacy Policy sets forth the terms on which Milvian Group, Ltd. (“Milvian Group”) collects, uses, and otherwise processes personal information of users of, or visitors to, products, services, and resources provided by Milvian Group, including our website at https://milvian.group/ (the “Site”), our software products and services, and any updates and changes to the foregoing (collectively, the “Services”). This Privacy Policy is incorporated into and forms a part of the Terms of Service (“Terms”), together with all other terms and policies linked or otherwise referenced within the Terms or our Privacy Policy. Capitalized terms used and not otherwise defined herein shall have the meanings provided in the Terms. 

The European Union and the United Kingdom require additional information regarding our privacy practices and your privacy rights under the data privacy laws of those jurisdictions. If you are a resident of the European Union and or United Kingdom, please see the section titled “Your Rights and Choices Regarding Your Information” below.  

By visiting or using the Site or Services, you are accepting and consenting to the practices described in this Privacy Policy. If you have any objections to the Privacy Policy, you should immediately discontinue use of the Site and Services. We may revise and update this Privacy Policy at any time in accordance with the Terms. We encourage you to review our Privacy Policy whenever you visit the Services to make sure that you understand how your Personal Information is being processed. 

DEFINITION OF PERSONAL INFORMATION 

As used in this Privacy Policy, "Personal Information" means information that can be used to identify you, the processing of which is subject to applicable data privacy laws. The term “Personal Information” can include information such as your name and e-mail address, but can also include indirect identifiers such as your IP address or device identifier. The term “Personal Information” does not include aggregate information, which is data we collect about the use of the Services or categories of such users unless it is linked with your other Personal Information.  

DATA THAT WE COLLECT 

To access certain features of our Services, you may need to submit, or we may collect, certain Personal Information about you. Our purposes for using or otherwise processing your Personal Information are described in the section titled “Our Uses of Personal Information” below. By providing Personal Information to Milvian Group for processing, you affirm that you have provided all notices and obtained all consents necessary under applicable data protection laws to permit Milvian Group to process such Personal Information for the purposes described in this Privacy Policy. 

Generally, you may provide us with two categories of data: User Data and Services Usage Data. The types of information that you may provide in each category, along with the technologies that we use to collect such information, are generally described in the sub-sections below.  

User Data 

“User Data” is the Personal Information that you provide when you sign up to receive e-mails from us, send us messages, or submit Personal Information for processing by the Services. Any User Data that we receive about you is provided directly by you, or on your behalf, on a voluntary basis. We describe the most common types of User Data that you may expect to provide below: 

  • Use of the Services. You will be required to provide your Personal Information to use or access certain tools and features of the Services. If you sign up to receive our newsletters, or if you register for an account for our Services, you may be required to provide us with Personal Information such as your contact information, including your full name and e-mail address. If you’d like to opt out of receiving newsletters or other communications from us, you can unsubscribe at any time by using the “unsubscribe” link provided at the bottom of any promotional e-mail, or contacting us directly at privacy@milvian.group. 
  • Use of Services. We may also collect and process analytical and statistical data regarding your use of our Services, such as bug/crash reports, to enable us to maintain, develop, and improve the features and performance of our Services, and otherwise for the purposes described in this policy. 
  • Communications with Milvian Group. When you send e-mail messages to Milvian Group, we may receive Personal Information about you, and may use the information that you provide to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are permitted by law to do so.  
  • Automatically Collected Information: When you visit, use, and interact with the Services, we automatically collect data about those visits, uses, or interactions. We may use analytics service providers, including Google Analytics, to collect information regarding visitors to our Services, such as their behavior on our Services or information about their demographics. For more information about Google Analytics, see https://www.google.com/policies/privacy/partners/. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout. Information collected may depend on the type of device you use and its settings; however, the types of information that we collect include the following: 
  • Usage and Engagement Data: Metadata about your activities on and use of the Sites and Services, such as the types of content that you view or engage with, the features you use, and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, your IP address. 
  • Log Data: Information that your browser automatically sends whenever you visit our Site(s), such as your IP address, browser type and settings, the date and time of your request, and how you interacted with our Site(s). 
  • Device Information: Name and model of your device, the operating system used, and (if you access the Services via a web browser) the browser that you are using. 

You are responsible for verifying the accuracy of the Personal Information you submit (or that is submitted on your behalf) to the Services and ensuring that any Personal Information that you provide (directly or indirectly) is kept up to date for the purposes for which you provide it. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you.  

Some Personal Information that you submit can be removed at any time upon your request. Note, however, that some Personal Information is necessary to use our Services. As such, even if you remove all of your Personal Information from your account, we may retain some of your Personal Information to comply with our legal obligations or as necessary to provide the Services to you. 

Services Usage Data 

We, as well as our Service Providers (defined below), automatically track and collect certain types of information about visits to our Site (“Services Usage Data”), such as your IP address, geolocation data, device identification, browser type, and operating system, as well as the referring or exit pages, the page(s) requested, and cookie information. We do not treat Services Usage Data as Personal Information if it does not identify you and is not directly linked to your Personal Information. 

We may use information about you to create and use anonymous, statistical, or aggregated data. Such aggregated data does not allow any party to identify you or any other specific user, and is not Personal Information subject to this Privacy Policy.  

OUR USES OF PERSONAL INFORMATION 

We use Personal Information that we collect from you to process your requests, to facilitate your use and our administration and operation of the Services, to provide you with information or services you request, and to learn more about and improve the Services, including by: 

  • Establishing and managing your use of the Services; 
  • Sending you account-related e-mails; 
  • Responding to your e-mails, submissions, comments, requests for technical support or assistance, or complaints; 
  • Developing, customizing, and improving the Services, and the resources that Milvian Group provides (including without limitation diagnosing technical and service problems, administering our Services; managing our communications; and analyzing and enhancing our Services; protecting the security of our networks and information systems); 
  • Identifying and protecting against fraud, prohibited or illegal activities, as well as potential third-party claims and other liabilities;  
  • Providing, supporting, personalizing, and developing our Site and Services; 
  • Personalizing your experience with our Services and delivering product and service offerings relevant to your interests; 
  • Conducting testing, research, analysis, and product development; and 
  • Generally complying with applicable laws, rules, and regulations. 

Cookies; Do-Not-Track Signals 

We use a variety of online analytics products that automatically deploy cookies, pixel tags, local storage, and other technologies to collect information through our Services to help us with analyzing how users use our Site and other Services.  A “cookie” is a piece of data sent to your browser by a website you visit. Depending on the type of information collected, cookies may constitute Personal Information. Depending on your device specifications and settings, you may be able to configure your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. Note that refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website. 

Our use of cookies and other automatic technologies falls into the following categories: 

  • Strictly Necessary: Technologies that allow you to access our Services and use our features, and tools that help us identify irregular site behavior and prevent fraudulent activity or improve security. 
  • Functionality: Technologies that collect information about your use of our Services, including measuring, understanding, and reporting on your usage of the Services. We may use these cookies to measure the effectiveness of that content, including information about what content was shown, how often or how long it was shown, when and where it was shown, and what actions, if any, you took on the content. 
  • Performance: Technologies that store information or provide access to information that is already stored on your device, such whether you have logged into our site previously. 
  • Marketing/Advertising: Technologies that collect information about your use of our Services, including measuring, understanding, and reporting on your usage of the Services. We may use these cookies to personalize your experience with our Services, and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email (with your consent where required by law). 

Opt-Outs 

You may be able to opt out of providing certain categories of Personal Information to us by following the instructions below. You may stop or restrict the placement of cookies on your device or remove them as your browser or device permits. Note that some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. As of the date on which this Privacy Policy was last updated, however, there is no standardized DNT signal. As such, our Services do not currently respond to browser DNT signals.  If you do not wish to be tracked, you may be able to opt out by selecting certain options in the settings of the browser or device that you use to access the Services, or by using third-party applications and programs. 

If you have any questions about viewing or updating information we have on file about you, please contact us using the methods provided at the end of this page. 

SHARING OF PERSONAL INFORMATION 

Milvian Group does not process your Personal Information except as required to provide the Services to you, as specified below, with your consent, or as otherwise permitted by law. A non-exhaustive list of examples of our sharing of Personal Information are described below: 

  • From time to time, we may share Personal Information with consultants, vendors, and service providers (“Service Providers”) who assist us in providing the Services and related services. These Service Providers may include vendors and suppliers that provide us with technology, services, and/or other content related to the operation and maintenance of the Services. Our Service Providers may access the categories of Personal Information specified in the section “User Data” to the extent necessary to provide their products or services to us. These Service Providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. 
  • Milvian Group may share your Personal Information with government authorities in the scenarios described below. In such cases, we reserve the right to raise or waive any legal objection or right available to us at our discretion: 
  • If we are required to do so by law, regulation, or legal process (such as a court order or subpoena); 
  • In response to requests by government agencies, such as law enforcement authorities; and/or 
  • If we have a good faith belief that the disclosure is necessary or appropriate to comply with law or legal process. 
  • We also may share your Personal Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Milvian Group, the Services, our users, or others; to prevent and protect Milvian Group and its users from fraudulent, abusive, unlawful, or unauthorized use of the Services; to otherwise enforce our rights and agreements; and otherwise in connection with our Terms and other agreements with you, in each case as permitted by applicable laws. 
  • We reserve the right to disclose or transfer any information we have about you as part of, or during negotiations of, any merger, sale of company assets, or acquisition, or in any other situation where Personal Information may be transferred as one of Milvian Group’s assets. 

We will not collect additional categories of Personal Information or use the Personal Information that we collect for materially different, unrelated, or incompatible purposes without providing notice to you. 

PROTECTING PERSONAL INFORMATION 

Milvian Group uses commercially reasonable administrative, technical, and physical safeguards to protect Personal Information against accidental or unlawful destruction or loss, or unauthorized disclosure, access, or use. You should be aware, however, that "perfect security" does not exist on the Internet or in any method of storage. To protect the confidentiality of your Personal Information, you must keep the Personal Information associated with your account confidential and not disclose it to any other person. You are responsible for all uses of the Services by any person using your account. 

YOUR RESPONSIBILITIES; OPTING OUT OF COMMUNICATIONS 

You acknowledge and agree that you, not Milvian Group, are solely responsible for the accuracy, quality, integrity, legality, reliability, appropriateness, and intellectual property ownership or right to use of all Personal Information that you submit, and for ensuring that any Personal Information that you provide is kept up to date for the purposes for which you provide it. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you.  

We only send e-mails to persons who have provided their e-mail addresses directly to us and who have consented to receive communications from us. If you do not wish to receive e-mails from Milvian Group, you may opt out by contacting us at privacy@milvian.group, or by clicking the “unsubscribe” link at the bottom of each newsletter. Please note that even if you opt out of receiving e-mails from Milvian Group, you may still receive relationship e-mails from us, including responses to e-mails that you sent to us prior to opting out, notices of updates or changes to our policies and procedures, or other messages relating to your account or your use of the Services. 

INFORMATION RETENTION AND DELETION  

Personal Information that we collect will be processed in accordance with this Privacy Policy and our internal retention guidelines. We will retain the Personal Information that you provide for as long as necessary to fulfill the purpose(s) for which it was collected, such as to enable or improve your access to or use of the Services. You may submit a request to review or delete the Personal Information that you submit to our Services for processing by contacting us using the contact information provided in the “Contact Us” section below. Note, however, that we may retain and use certain Personal Information as necessary to comply with applicable laws and our legal obligations, resolve disputes with any parties, and otherwise as needed to provide the Services that you have requested. 

SPECIAL NOTICES 

The Services are not designed for use by children under the age of 13, nor do we knowingly collect any Personal Information from children under the age of 13. If you are a child under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us.  If you believe that a child under 13 has provided us with Personal Information, please contact us using the contact information at the bottom of the page. 

YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION  

For users who reside in the European Economic Area, Switzerland, or the United Kingdom, and who are subject to any one of (i) the General Data Protection Regulation, (ii) data protection laws implemented by member states of the EU in harmony with the General Data Protection Regulation,  or (iii) the UK Data Protection Act of 2018, as amended and incorporated into UK law (collectively, the “GDPR”), we have implemented the practices described below to provide you with control over any Personal Information that constitutes “Personal Data” under the GDPR. If you are not a data subject entitled to data processing rights under the GDPR, the provisions below do not apply to you. 

  • Personal Data: The categories of personal data that Milvian Group processes to provide its Services are set forth in the “User Data” section.
  • Lawful Grounds: We rely on the following lawful grounds under the GDPR to process your Personal Information: (a) it is necessary for the performance of a contract with you; (b) our or a third-party’s legitimate business interest; or (c) your consent. 
  • Data Transfer Notice: We are located in the United States and transfer your Personal Information for processing in the United States. We make the transfer to the United States in the absence of an adequacy decision because it is necessary for the performance of a contract with you, or with your consent. 
  • Individual Rights and Data Requests: You may also contact us at privacy@milvian.group to request access to, transfer of, and rectification or erasure of your Personal Information, or restriction of processing, or to object to processing of your Personal Information. Please specify the nature of your request and the information that is the subject of your request. We may require you to submit additional information necessary to verify your identity and status as a data subject. If we are processing your Personal Information based upon the lawful grounds of your consent, you have the right to withdraw your consent for such processing at any time without affecting the lawfulness of processing based on consent before it is withdrawn. 
  • Retention: At a minimum, we will retain your Personal Information for as long as necessary for the purpose in which it was collected such as to perform a contract, for our or a third-party’s legitimate interest, or your consent. 

To exercise the rights available to you as a data subject under applicable laws, as described above, submit a request to us by emailing us at  privacy@milvian.group. We will need to verify your identity (and, where applicable, your authorized agent’s authority to make the request on your behalf) as well as other information about you to process your request. You may only make a verifiable request twice within a twelve-month period. We will not discriminate against you for exercising any of your rights regarding your information. We will respond to all data subject requests directly within the time period required by applicable law.  

REGARDING OUR EXEMPTION FROM INTERNATIONAL AND STATE DATA PRIVACY LAWS 

As of the “Last Updated” date indicated on this page, Milvian Group is not subject to the state-level data privacy laws in the United States (including, without limitation, those effected in California, Connecticut, Colorado, Iowa, Virginia, and Utah).  

CONTACT US 

If you have any questions, concerns, or complaints regarding our Privacy Policy or data processing practices, please contact us using the information below. We will try to respond to your complaint, inquiry, or information request as we have the capacity to do so. 

Milvian Group, Ltd. 

500 108th Ave NE Suite 1100 

Bellevue, WA 98004 

privacy@milvian.group