Welcome to [MILIMILI] (“Company,” “we,” “us,” or “our”). We are committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (“Website”) and use our ad tech services (“Services”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

We receive and store any information you knowingly provide to us when you create an account, as well as when you fill any online forms on the Website. When required, this information may include your email address, name, phone number, or other personal information. You can choose not to provide us with certain information, but certain features of the Website may not be accessible. Users who are uncertain about what information is mandatory are welcome to contact us.

When you are using our Services (including but not limited to the use of a mobile application that utilizes our mobile SDK), we also automatically collect information about your device such as the advertising ID, the model of your device, and your screen size.

When you visit the Website, our servers automatically record information that your browser sends. This data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences, the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, links clicked, information you search for on our Website, access times and dates, and other statistics.

Cookies and Tracking Technologies

We may use cookies, web beacons, and other tracking technologies to collect and store information about your interactions with our website.

You are able to access, add to, update and delete certain personal information about you. The information you can view, update, and delete may change as the Website or Services change. When you update information, however, we may maintain a copy of the original unrevised information in our records. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may use any aggregated data derived from or incorporating your personal information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

We use the information we collect in various ways, including to:

i. Provide, operate, and maintain our website and services;
ii. Improve, personalize, and expand our website and services;
iii. Understand and analyze how you use our website and services;
iv. Develop new products, services, features, and functionality;
v. Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes;
vi. process your transactions and manage your orders;
vii. Send you text messages and push notifications;
viii. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

We may process personal information related to you if one of the following applies:

i. You have given consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of personal information is subject to EU General Data Protection Regulation (GDPR) under the European Data Protection Law;
ii. Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
iii. Processing is necessary for compliance with a legal obligation to which you are subject;
iv. Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
v. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

We may share your information with third parties in the following circumstances:
i.With service providers and vendors to perform functions on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. In such cases, these third parties must abide by our data privacy and security requirements and shall not be allowed to use any information they receive from us for any other purpose.
ii. In connection with a merger, sale, acquisition, or other transfer of all or part of our business
iii. With our affiliates and business partners for the purposes described in this Privacy Policy
We may also share your information with business partners and other third parties in order to allow them to provide you with offers, promotions, or ads that we think you may enjoy. If you do not want us to share your information with these companies, please contact us using the information provided in the contact section.
iv. To comply with legal obligations, respond to legal requests, or protect our rights.

If you are visiting our Website from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to various locations and processing globally. By providing your information, you consent to any transfer and processing in accordance with the Privacy Policy.

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by inquiring with us using the information provided in the contact section.

Depending on your location, you may have the following rights regarding your personal information:

The right to withdraw consent – You have the right to withdraw consent where you have previously given your consent to the processing of your information.

The right to access – You have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions, in which case, we will not process your information for any purpose other than storing it.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions. However, where your personal data is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. Should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.

The right to data portability – You have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.

This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

To exercise these rights, please contact us at [email protected].

Our Website and Services, including our mobile SDK, are not directed to children under the age of 13, and we do not knowingly collect any personal information from children under the age of 13. Please do not submit any personal information through our Website or Services if you are under the age of 13. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Privacy Policy by instructing their children never to provide personal information through our Website or Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Website or Services, please contact us, and we will delete that information immediately.

If you are a developer using our SDK in a child-directed mobile application or you have actual knowledge that a user is under the age of 13, please notify us using the mechanisms provided through our platform or tools, or contact us using the information below.

Mobile users can opt out of having their Mobile IDs used for certain types of interest- based mobile advertising, including those performed by us, by accessing the settings on Apple or Android mobile device, as follows:

Apple Devices: If you have an Apple device, you can opt out of most interest-based advertising by updating to iOS 6.0 or higher and enabling "Limit Ad Tracking."

iOS 7 and Higher: Go to Settings → Privacy → Advertising, and toggle "Limit Ad Tracking" to 'ON.'

iOS 6: Go to Settings → General → About → Advertising, and toggle "Limit Ad Tracking" to 'ON.'

Android Devices: If you have an Android device, you can opt out of most cross-app advertising by going to Google Settings → Ads, and selecting the option to opt out of interest-based ads.

Users also have the right to clean the personal data concerning them that we hold as a data controller. The above opt-out process satisfies this right. When an End User opts-out through device settings, and we receive this signal from our Clients, the personal data we use to provide our Services will be deleted within 30 days (if you have an Android device) or permanently rendered disconnected to your device (if you have an iOS device). Our service team will also manually delete users' personal data, please contact us at [email protected] for further instructions on exercising this right manually.

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transaction-related emails.

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you wish to delete browser cookies, you can go to browser settings and find relevant options.To learn more about cookies and how to manage them, visit internetcookies.com.

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
i. Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http:// optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices).
ii. European Interactive Digital Advertising Alliiance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu).
iii. Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http:// www.networkadvertising.org/mobile-choices.

Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

If you no longer wish to see cookie-based personalized ads from MILIMILI, you can choose to Opt Out.

Note: An “opt-out cookie” will be placed in your current browser. If you use multiple browsers and devices, you must opt out on each browser or device. If the “opt-out cookie” is deleted, you must opt out again.

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

In the event we become aware that the security of the Website has been compromised or users personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. You acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite all best efforts.

In the event we become aware that the security of the Website has been compromised or users personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website and/or send you an email.

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.

Our website may contain links to third-party websites that are not owned or controlled by us. This Privacy Policy does not apply to the practices of other websites, and we are not responsible for the actions and privacy policies of third parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect your information.

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. We will notify you of any changes by posting the new Privacy Policy on our website and updating the "Last Updated" date at the top of this page. We encourage you to periodically review this page for the latest information on our privacy practices. The changes will be made within 7 days after the notification was provided. Continued use of the Website or our Services after any such changes shall constitute your consent to such changes.

You acknowledge that you have read this Privacy Policy and agree to all its terms and conditions. By using our Website or Services you agree to be bound by this Privacy Policy. If you do not agree to abide by the terms of this Privacy Policy, you are not authorized to use or access our Website and Services.

If you have any questions or concerns about this Privacy Policy or our practices regarding your information, please contact us at: [email protected].