Privacy Policy

1) Introduction and Overview.

This Privacy Policy describes how Made of Millions, Inc., 501c3 non-profit organizations (collectively, “Made of Millions,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of any online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.

2) Data Controller.

EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Made of Millions, located at the address in the section entitled “Contact Us” below, is the controller with respect to information collected through the Service.

3) Information Collection.

A. Information You Provide.

We collect information you provide directly via the Service, such as when you: register an account; update your profile; access our content; upload a resource, picture or video; add a note or comment; sign up for our newsletter, make a purchase or donation; participate in a survey, exclusive offer, or other promotion (“Promotion”); or contact customer support. We may use Service Providers (defined below) to collect this information.

The information we collect includes information that identifies you personally (whether alone or in combination). We collect the following information:

• Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.
• Account Credentials. We collect username, passwords, password hints, and other information for authentication and account access.
• Demographic Data. In some situations, we collect demographic information including your age, gender, and country.
• Payment Data. We collect data necessary to process your payment if you make a purchase or donation, including your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
• Profile Data. We collect your interests such as hosts and episodes you add to your favorites and share on other platforms, episodes and content you view or watch, your preferences regarding the type of content you would like to see, and other profile data.
• Content. We collect content you send to us or submit through our Service, such as your feedback, comments or forum posts, responses to questionnaires, articles about your personal story, opinions or professional perspective you would like to publish on the Service, resources you submit to our global mental health directory, the video and audio content of mental health live series you host on our channels and questions and other information you provide to us. Our administrators review the content you submit to us before it is published on our Service. Once published, you will receive a transactional email with a link to the note, video, or resource.

You may choose to voluntarily submit other information to us through the Service, including sensitive health or wellness information, or information regarding your mental illness and related symptoms, and, in such instances, you are solely responsible for such information, including where you choose to post or publish such written or audio visual content in a public forum or live stream video.

B. Information Collected Automatically.

In addition, we automatically collect information when you use the Service. We may use Service Providers (defined below) to collect this information. Some examples of information we collect include the following:

• Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the time of day you browse, your referring and exiting pages, and other similar information.
• Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.
• Location Data. We collect data about your device’s location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).

We and our Service Providers use tracking technologies to automatically collect this information, including the following:

• Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.
• Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
• Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
• Location-Identifying Technologies. GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
• App Technologies. Technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.  

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using tracking technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.

For further information on tracking technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.

C. Information from Other Sources.

We also obtain information about you from other third party sources. To the extent we combine such third party sourced information with information we have collected about you through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included:

• Social networks such as Facebook or Google when you log-in using their services, reference our Service or grant permission to Made of Millions to access your data on one or more of these services.
• Partners such as programming partners with which we jointly offer services or content such as episodic series about certain health issues and streaming of other live videos.
• Publicly-available sources such as open government databases or other data in the public domain.
  

4) Use of Information.

We collect and use information about you for our legitimate interests described in this Privacy Policy, including to:

• Manage and provide our Service, including your registration and account.
• Perform services requested by you, such as facilitating your ability to access your favorites and dashboard, upload resources, add notes, videos and resources and engage in forums; respond to your comments, questions and requests; and provide customer service. 
• Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
• Prevent and address fraud, breach of policies or terms, and threats or harm.
• Monitor and analyse data, trends, usage, and activities.
• Conduct research, including focus groups and surveys.
• Improve the Service or other Made of Millions websites, apps, marketing efforts and services.
• Develop and send you direct marketing, including advertisements and communications about our and third party products, offers, news, promotions, rewards, events, and services.

We also use information about you with your consent, including to:

• Verify your eligibility and deliver prizes in connection with Promotions you have entered.
• Serve advertising tailored to your interests on our Service and Third Party Services.
• Fulfill any other purpose disclosed to you and with your consent.

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

5) Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy, including with the following:

• Service Providers. We share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as payment processing, account administration, content review, processing donations, fulfilling orders, data analytics, marketing and promotional services, Promotions, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
• Affiliates. We may share information with our related entities. For example, we may share information with our affiliates for customer support, marketing, and technical operations.
• Partners. We share your information with our programming or other partners with which we jointly offer services or content such as episodic series about certain health issues and streaming of other live videos.
• Insurance Carriers. We share aggregate or deidentified information with insurance carriers to help reduce the cost of care and support production of our content. 
• Promotions. Our Promotions may be jointly sponsored or offered by third parties. If you voluntarily choose to enter a Promotion, we may share your information with third parties as set forth in the official rules that govern the Promotion as well as for administrative purposes and as required by law. By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
• Third Parties. We share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
• Merger or Acquisition. We reserve the right to share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We share your information to comply with the law or other legal process and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also reserve the right to share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
• Consent. We share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we share aggregated information that does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

6) Public Information.

Certain areas of the Service, such as user profiles, live stream videos, articles, and resources in our global mental health directory are designed to help you share information with the world. If you make information public through our Service, including information regarding health or mental condition or disease, other people will have access to it. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information; however, California residents and data subjects in Europe have additional rights as set forth in “Your Rights and Choices” below.

7) Third Parties.

A. Third Party Services.

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use tracking technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature (defined below), or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

B. Third Party Features.

We allow you to connect our Service to a Third Party Service or offer our Service through a Third Party Service (“Third Party Features”). If you use a Third Party Feature, both we and the applicable third party have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party’s privacy policy and terms of use. Some examples of Third Party Features include the following:

• Sharing, and Logging-In. We embed pixels on our Service that allow you to “share” content on, or log-in to your Made of Millions account through, Third Party Services, including Google and Facebook. If you choose to engage with such a Third Party Service through our Service, we collect any information you have authorized the Third Party Service to share with us (such as your username, public profile information, e-mail address, birthday, friends list, and other account and profile data). Likewise, if you choose to engage with such a Third Party Service through our Service or visit our Service while logged in to that Third Party Service on your device, the Third Party Service receives information about your activities on our Service and may be able to associate that information with information the Third Party Service already has about you.
• Brand Pages and Chatbots. We offer our content on social networks such as a Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot, Pax the OCD Bot) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with Made of Millions, Intrusive Thoughts or Dear Manager in a tweet or post), we reserve the right to use your reference on or in connection with our Service.

C. Analytics and Interest-Based Advertising.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, ad networks, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These parties may use tracking technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).

For further information on tracking technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

8) Your Rights and Choices.

A. Review and Update of Account Information.

You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents and data subjects in Europe have additional rights as set forth in the sections entitled “Your California Privacy Rights” and “Your European Privacy Rights” below.

B. Tracking Technology Choices.

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
•  App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

C. Analytics and Interest-Based Advertising.

You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.  

Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website targeted ads from DAA participants, http://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from Network Advertising Initiative (“NAI”) participants, http://www.networkadvertising.org/choices/. You can learn more about your EU online choices by visiting http://www.youronlinechoices.eu/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, donations, servicing, or Made of Millions’ ongoing business relations.

Please note that your opt-out is limited to the e-mail address and device used and will not affect subsequent subscriptions.

You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, donations, servicing, or Made of Millions’ ongoing business relations.

Please note that your opt-out is limited to the e-mail address and device used and will not affect subsequent subscriptions.

D. Email Communications.

You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, donations, servicing, or Made of Millions’ ongoing business relations.

Please note that your opt-out is limited to the e-mail address and device used and will not affect subsequent subscriptions.

E. Your California Privacy Rights.

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

Made of Millions shares personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Made of Millions is not required to respond to requests made by means other than through the provided e-mail address or mail address.

Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

F. Your Canadian Privacy Rights.

If you are a resident of Canada, you may be entitled to additional rights regarding your personal information, including: (i) the right to withdraw consent to processing of your personal information where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to challenge improper processing of your personal information, under certain conditions; (iv) the right to demand that we restrict the use or disclosure of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for such use or disclosure, use or disclosure is no longer necessary, or believe your personal information is inaccurate; and (v) the right to lodge a complaint with applicable Canadian data protection authorities. If you want to learn more about your rights under Canadian law or our privacy practices you may contact us as set forth in the section entitled “Contact Us” below.

G. Your European Privacy Rights.

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.

9) Children.

The Service is intended for a general audience and not directed to children under sixteen (16) years of age. Made of Millions does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Made of Millions has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.

10) Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.

11) International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If your data is collected in Europe, we will transfer your personal data subject to appropriate safeguards, such as Standard Contractual Clauses.

12) Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your acceptance to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your e-mail address.

13) Contact Us.

If you have any questions or comments about this Privacy Policy or our data practices, please contact us:

By e-mail: [email protected] 

By mail:

Made of Millions 

636 Broadway, Suite 1200 

New York, NY 10012

EU Requests:

For EU-specific requests, you can reach our Data Protection Officer (“DPO”) at [email protected].