Effective Date: October 9, 2018
1. Introduction and Overview.
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 you provide 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; make a purchase; 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). Some examples of information we collect include the following:
- Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.
- Credentials. We collect 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, 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 username, interests, likes, favorites, information that you choose to submit or post regarding your physical or mental condition, and other profile data.
- Contacts. We collect data about your contacts in order to fulfill a request by you, such as finding your contacts on the Service or inviting your contacts to join the Service. Such functionality is only intended for United States (“U.S.”) residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.
- Content. We collect the content of messages you send to us, your feedback, your forum posts, and questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the services you use.
You may choose to voluntarily submit other information to us through the Service, including sensitive health or wellness information, or information regarding mental illness and related symptoms, and, in such instances, you are solely responsible for such information, including where you choose to post such information in a public forum.
B) Information Collected Automatically.
We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers 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 products you purchase, 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 use various current – and later – developed technologies to collect this information (“Tracking Technologies”), 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.
- 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.
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.
- Data brokers from which we purchase demographic or other data to supplement the data we collect.
- Social networks when you reference our Service or grant permission to Made of Millions to access your data on one or more of these services.
- Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Publicly-available sources such as open government databases or other data in the public domain.
For further information on Third Party Services, see the section entitled “Third Parties” below.
4. Use of Information.
We use information about you for our legitimate interests, including to:
- Manage our Service, including your registration and account.
- Perform services requested by you, such as facilitating your ability to access your dashboard, upload resources, add notes, and engage in forums; respond to your comments, questions, and requests; and provide customer service. Our administrators review your notes, videos, and resources before they are published to our Service. Once published, you will receive a transactional email with a link to the note, video, or resource.
- 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 trends, usage, and activities.
- Conduct research, including focus groups and surveys.
- Improve the Service or other Made of Millions websites, apps, marketing efforts, products 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 about you as follows:
- 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 share your information with our related entities. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.
- Business Partners. We share your information with our business partners in connection with offering you co-branded services or engaging in joint marketing activities.
- 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 and blogs, 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.
B) Third Party Features.
- Liking, Sharing, and Logging-In. We embed pixels or SDKs on our Service that allow you to “like” or “share” content on, or log-in to your Made of Millions account through, Third Party Services, including Google and social networks such as Facebook and Twitter. 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 user ID, billing information, 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.
C) Analytics and Interest-Based Advertising.
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third 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”).
We serve ads on and through Third Party Services, such as Facebook and Google, that are targeted to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the Third Party Service or incorporating a pixel from the Third Party Service on our Service, and the Third Party Service matching common factors between our data and their data. To opt-out of receiving Matched Ads, please contact the applicable Third Party Service. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such Facebook ads and find out how to opt-out. We are not responsible for such Third Party Service’s failure to comply with your opt-out instructions.
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.
- Location-Identifying Technologies. You can exercise choice over the location data collected by us as follows: (i) for GPS data, disabling location in your device settings; (ii) for Bluetooth data, disabling Bluetooth and any Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning option in 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, 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 Opt-out Browser Add-on.
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. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, http://www.aboutads.info/choices; and (ii) for mobile app opt-out, http://www.aboutads.info/appchoices. In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, please visit 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 members should no longer deliver certain Interest-based Advertising 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).
- E-mails. 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, servicing, or Made of Millions’ ongoing business relations.
Please note that your opt-out is limited to the e-mail address, device, and phone number used and will not affect subsequent subscriptions.
E) Unlinking Your Accounts.
F) 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.
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.
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.
13. Contact Us.
Made of Millions 636 Broadway, Suite 1200 New York, NY 10012
For EU-specific requests, you can reach our Data Protection Officer (“DPO”) at DPO@madeofmillions.com