Last Updated Dec. 22, 2020
We respect your privacy and want to protect your personal information. This Policy lets you know what information we collect from you, what information we disclose and to whom, and how we and our service providers use your personal information. The Policy also explains the steps we have taken to secure your personal information. Finally, this Policy explains your options regarding the collection, use, disclosure and deletion of your personal information.
If you are a resident of the State of California or of the European Union, you have certain additional data privacy rights and options, which are explained below in this Policy.
- Collection of information
What constitutes “personal information”?
Personal information is information that can be directly or indirectly associated with a specific person such as a customer's name, mailing address, telephone number, mobile number, e-mail address, credit card number, social security number, information that would permit us to contact a customer physically or online, a customer's account name/number and related information (such as username and password), or information about activities directly linked to a person, such as his or her purchases.
Some state laws define personal information to include additional data, such as a person’s Internet IP address, geolocation data and biometric information. In addition to these categories, the California Consumer Privacy Act of 2018 (CCPA), which applies to California residents, also includes within its definition of “Personal information” an alias; unique personal identifier; online identifier; driver’s license number; passport number; other similar identifiers; records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; Internet or other electronic network activity information (including browser and search histories); and audio, electronic, visual, thermal, olfactory, or similar information.
Personal information does not include publicly available information that is lawfully made available from federal, state, or local government records.
Personal information does not include “aggregate” or “deidentified” information. Aggregate information is data we collect about a group or category of products, services or customers, from which individual customer identities have been removed and there exist technological safeguards that prohibit reidentification of the consumer to whom the information may pertain. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data.
Likewise, information about the products you purchase may be collected and combined with information about the products purchased by others. Aggregate data helps us understand trends and customer needs so that we can better consider new products and services, and tailor existing products and services to customer desires.
When Do We Collect Personal Information?
We collect certain personally identifiable information (defined under the CCPA as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household”) when you sign in to the Website; create an account for online shopping; register with MILLY.com; participate in a contest, promotion or survey; or request other services that require personal information for registration or subscription services. We also keep a record of your product interests and purchases online and automatically receive and record information on our server logs from your browser (including your IP address, data captured by cookies, and the web page(s) you requested).
How We Collect Information
MILLY collects personal information that you voluntarily provide to us, both online and in-stores, such as when you:
- make a purchase;
- register with our Sites;
- sign up for special offers or promotions;
- use a third-party connection or log-in to create a membership or profile on any of our Sites, access any content on our Sites or forward content from our Sites to another person (such as email, Facebook, Twitter, Pinterest, Instagram, Google Plus and YouTube); or
- contact us for any reason, reply to one of our inquiries by email, postal mail, online, or by telephone through customer service.
In addition, we and our third-party providers automatically collect certain information when you visit the Sites, such as your computer’s IP address, operating system, the site from which you linked to us, and the time and date of your visit and purchases.
From time to time, we work with third parties (such as e-commerce sales and payment providers, marketing firms, networks, analytics providers, search information providers, credit reference agencies) that provide us information about you, excluding your credit card information (which we do not receive or store). For example, we use Shopify, PayPal and Afterpay to administer payment processing. These and other third parties identified in this Policy may collect and store certain personal information about you, and you should carefully review those companies’ privacy policies to understand what information they obtain from you and how they use and secure it. We also use one or more fraud protection service providers that set cookies to protect both you as a consumer and us.
If you want to access, correct or object to the collection of your personal information, you can contact us using the details set forth below in the Choice/Opt-Out paragraph. If you are a resident of California or the European Union, you have certain additional rights that are set forth below in the California Residents and European Residents sections.
What Are Cookies And Tracking Technologies?
MILLY and its analytics and other service providers use technologies such as cookies, web beacons, tags, scripts and other similar technologies (collectively, “Cookies”) to collect certain information. These technologies are used to help us and our business partners analyze trends, administer the Sites, remember preferences, track users’ movements around the Sites and gather demographic information about our customer base as a whole. Some types of Cookies, like web beacons, allow us or third parties working on our behalf to gauge and enhance the effectiveness of our marketing by allowing us to understand whether users follow links in our e-mails or on our Sites, and by gathering information about other sites users visit before and after visiting our Sites. Certain other Cookies are used to store preferences on a user's computer or mobile device, or display content based upon what a user viewed on the Site to personalize their visit. Currently, MILLY employs cookies and tracking technologies on its Sites, including the following:
- Essential Cookies. These cookies enable you to move around the Sites and to use their features. Without these absolutely necessary cookies, certain aspects of the Sites would not work. No information about your browsing habits is gathered by these cookies.
- Session Cookies. These cookies contain information that is stored in a temporary memory location on your computer. They are deleted after the online session is completed or your web browser is closed. These cookies store information that you input and track how you move within our Sites.
- Functional Cookies. These cookies remember how you like to use the Sites and help to personalize them accordingly. These cookies do not collect personally identifiable information or track your browsing habits, but they do help us serve you with ads.
- Analytics Cookies. These cookies collect information about your use of the Sites, and enable us to improve the way they work. For example, analytics cookies show us the most frequently visited pages on the Sites, help us record any difficulties you have with the Sites, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on the Sites, rather than the use of a single person. Some of the analytics cookies we use may be operated by third parties, such as Google Analytics. Google Analytics enables website operators like us and our third-party service providers, including Google, to match the interests of our Sites’ visitors with appropriate ads after they leave our website through remarketing strategies. As a result, a visitor to our Sites may see a customized advertisement on a Google search results page, or other webpage, after leaving the Sites. Data collected through the use of “DoubleClick cookies” will only be used in accordance with this Policy and Google’s privacy . You can set preferences for how Google advertises to you by visiting Google’s Ads Settings page here: http://www.google.com/settings/ads. You can also permanently opt-out of the Google Analytics Advertising Features by visiting the page: https://tools.google.com/dlpage/gaoptout/. Additional information about how Google Analytics collects and processes data is available here: http://www.google.com/policies/privacy/partners/. MILLY cannot identify you personally through the use of these cookies; we just use them for statistics.
Because technology is constantly changing, however, we may change the types of Cookies that are used with the Sites from time to time. We will update this Policy in accordance with applicable law and if we materially change the manner in which we collect information.
Disabling Cookies and Tracking Technology
Some, but not all, Cookies may be disabled or removed through cookie management tools provided by your browser. If you are concerned about cookies and tracking technologies, we encourage you to visit the websites www.allaboutcookies.org to better understand what Cookies are set on your computer or mobile device and how to manage, disable or delete them. In addition, some of our third-party advertisers or display networks (including Google Analytics) may participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising and allow consumers to opt-out of targeted advertising based on web activity tracking. Additional information about the foregoing is available at http://www.aboutads.info/choices/.
If you choose to disable or delete Cookies, you should know that you may not be able to take advantage of all the features of our Sites, including certain personalized features. Rejecting Cookies may also affect your ability to perform certain transactions on the Sites, and our ability to recognize your browser from one visit to the next. Accordingly, if you opt out, you will still see ads from us online, but we will not know it’s you, so we will not be able to apply any of your ad preferences. Note, also, that we will keep a cookie on your computer to remember that you have opted out. That opt-out cookie (like all Cookies) is associated with a particular computer and browser. So if you get a new computer, install a new browser, or clear your Cookies, you’ll need to opt-out again.
How We Respond to “Do Not Track” Settings
Our Sites do not respond to or alter the practices detailed herein based upon your selection of the “Do Not Track” setting or feature that may be offered by your browser.
2. Use of Personal Information
Use of Personal Information by MILLY
As you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.
- for the specific purpose for which it was voluntarily provided;
- to provide you with a personalized browsing experience when using the Sites;
- to fulfill any contractual agreements between you and us (for example when you place an order for products through the Sites);
- to send you details (including by mail, phone, e-mail or text) of other products that we think may interest you, where you have consented to this and share your information with third parties for this purpose, unless you inform us that you do not want to receive these details;
- to manage any account that you hold with us:
- to ensure that content from the Sites is presented in the most effective manner;
- to notify you about changes to the Sites or our services;
- to develop, market, sell or provide products and services of interest;
- to deliver communications or obtain feedback relevant to your use of the Sites;
- to evaluate the quality of the information, provide more relevant content, analyze Site usage, and improve the Sites and the services provided through them;
- for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
- to create anonymous data for market profiling purposes that may be used by us and shared with our group of companies or third party service providers; and
- as permitted by, and to comply with, any legal or regulatory requirements, process or provisions.
- To process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To create and secure your account with us.
- To process your requests, purchases, transactions, and payments, and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To send you newsletters, or to provide information on products or services to you. You can elect not to receive promotional emails from us either by “unsubscribing” to an email you receive or by contacting us as indicated below.
If you prefer not to receive promotional information from us, we make it easy for you to let us know. You can contact us at any time to decline promotional information (see the Choice/Opt-Out paragraph below).
Sharing of Personal
MILLY does not sell, rent, share, or disclose your personal information to third parties without your prior consent, except in the limited circumstances described in this Policy. We do share personal information with third party marketing partners for commercial purposes in connection with our business. In order to complete a transaction it is necessary for us to provide your personal information to service providers performing services on our behalf pertaining to the Sites or your product orders. We do not authorize these service providers to use or disclose your personal information except as necessary to perform services on our behalf or comply with legal requirements.
We may share your personal information with selected third parties performing such services, including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
- analytics and search engine providers that assist us in the improvement and optimization of the Sites.
We may also disclose or transfer your personal information in the event that MILLY were to sell or buy any business or assets, including a sale of our own company and its assets to another company. In those cases, we may disclose and transfer your personal information to the seller or buyer of such business or assets, and if MILLY or substantially all of its assets were to be acquired by a third party, the personal information of our customers would likely be one of the transferred assets. Additionally, MILLY may disclose personal information as may be permitted or required by law, regulation, rule or court order; pursuant to requests from governmental, regulatory or administrative agencies or law enforcement authorities; or to prevent, investigate, identify persons or organizations potentially involved in, or take any action regarding suspected fraud, violations of our Terms of Service, or activity that appears to us to be illegal or may expose MILLY to legal liability; and in situations that we believe to be emergencies involving potential threats to the physical safety of MILLY or to protect the rights, property, or safety of MILLY, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
3. Selling Information
We do not sell any of your personal information that is collected by us through any of our Sites. Please see our CCPA disclosure for additional information.
4. Personal Information Security
MILLY has implemented physical, electronic and procedural safeguards to store and maintain your personal information in a secure environment. When you enter personal information or your credit card information online, that information is encrypted using security software called SSL (Secure Socket Layer). SSL encrypts all information entered on our site before it is sent over the Internet. We also use SSL to allow you to securely view your online account and registration information. While we and our service providers, including Shopify, have implemented safeguards, you should be aware that Internet security technology rapidly changes and is not perfect. We cannot guarantee that the safeguards we and our providers employ today can protect your personal information from the threats of tomorrow or every potential malicious cyber-attack. Despite MILLY’s reasonable efforts, factors beyond MILLY’s control may result in disclosure of personal information. Accordingly, MILLY is not in a position to guarantee that your information will be secure under all circumstances. In the unlikely event we believe or are advised that the security of your personal information that we possess or control may have been compromised, we will notify you of that development in accordance with applicable laws.
If you sign up with MILLY to receive electronic newsletters or promotional emails, including new products, special offers and event information, or to otherwise receive communications about our products and services, you will have the right at any time to opt-out of receiving marketing emails or to specify which, if any, communications you would like to receive from us. You may contact us at any time by emailing firstname.lastname@example.org. You may also opt-out of receiving email marketing communications from us by using the “unsubscribe” link in our emails. There is no charge to unsubscribe. To opt-out of physical mailings and telephone communications, or to add your name to our do-not-share list, you may email us at the above address or call us at ________________ . We will be sure your name is removed from our list (and the list we may share with third parties) as soon as possible after we receive your request. Please be aware, however, that even after your request is processed, we may, for a time, retain residual information about you in backup and/or archival copies of our database.
Information about opting-out from targeted advertising and disabling cookies is provided above in the Disabling Cookies and Tracking Technology paragraph.
- California Residents: Additional Privacy Rights Under the CCPA
If you are a California resident, you have additional rights under the CCPA, including with respect to the use of your Personal Information and your right to opt-out of the “sale” of your Personal Information, as set forth in this section of our Policy. For purposes of this additional CCPA disclosure, the CCPA’s above definition of “Personal Information” is used.
Access to Your Personal Information
You have the right to request a copy of the specific Personal Information we collect about you, the sources of that Personal Information, and to whom your Personal Information was disclosed. We will provide this to you in electronic form. To protect your privacy and security, we may require you to confirm and prove your identity before providing the requested information.
Disclosure of Types of Personal Information Collected
You have the right to request disclosure of the types of Personal Information we collect, the purposes for which we collect, sell or disclose that Personal Information, and the categories of third parties with whom we share any Personal Information. Please see the above sections of this Policy on Sharing of Personal Information and Selling Information.
Specifically, you may request disclosure of any or all of the following:
(1) Specific pieces of Personal Information we have collected about you as a consumer;
(2) Categories of Personal Information we have collected about you;
(3) Categories of sources from which the Personal Information is collected;
(4) Categories of Personal Information that we sold or disclosed for a business purpose about you;
(5) Categories of third parties to whom any Personal Information was sold or disclosed for a business purpose; and
(6) The business or commercial purpose for collecting or selling Personal Information.
Deletion of Personal Information
You have the right to request that we delete Personal Information that we process about you, except we are not obligated to do so under certain circumstances, including if we need to retain such data in order to comply with our legal obligations or to establish, exercise or defend legal claims.
Personal Information We Collect
In the prior 12 months, we have collected the following types of Personal Information from California residents or permitted third parties (including online analytics and marketing companies, and providers of data services) to use such Personal Information:
- Device and browsing history information (including the pages you visit on our website and the type of browser);
- Purchase or other commercial information, including credit card information for payment processing and product return data;
- Demographic information;
- Identifiers and contact information, including names, email addresses, phone numbers, shipping/billing addresses, signatures, and online identifiers Internet Protocol (“IP”) addresses;
- Cookie information;
- Geolocation data (where you have permitted such access);
- Customer feedback;
- Information shared with Customer Service;
- Account number;
- Size, fit, and product preferences; and
- Inferences drawn from other personal information (including buying trends, personal preferences, and online behavior and attitudes).
Opt-Out - “Do Not Sell”
Under the CCPA, the term “sell” or “sale” is broadly defined and means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by a business to another business or a third party for monetary or other valuable consideration. As noted above, we do not transfer or make available any Personal Information for money. Although we disclose Personal Information to third parties who provide us with marketing and other services, as disclosed in this Policy, such disclosures under the CCPA do not constitute “valuable consideration” when they are made to service providers and are necessary to perform a business purpose, provided our service providers do not further collect, sell, or use the Personal Information except as necessary to perform the business purpose. Our service providers are not permitted to further sell or use Personal Information we provide to them.
You have the right to opt out of Personal Information sharing activities that meet the CCPA definition of “sale” or “sell.” We provide a free means to opt-out of such sharing by following the process we have set up under Right to Opt-Out.
You may also “Request to opt-in” after opting-out of the sale of your Personal Information.
We do not knowingly “sell” any Personal Information of minors under 16 years of age.
To exercise your privacy rights under the CCPA, please submit a request using one of the methods described below, and provide the required information. Once we receive your request, we will validate the information that you provide and send a message to the email address you provide in the request, asking you to verify that it is your email address. Please follow the instructions in that email to verify your email address. We will begin processing your request once you verify your email address.
- Request Access to specific pieces of Personal Information about you that we have collected in the preceding 12 months.
- Request Deletion of Personal Information that we have collected from you. We may retain Personal Information as required or permitted by law, and will maintain a copy of your deletion request. We may use a two-step process for online requests to delete where you must, first, submit the request to delete and then, second, separately confirm that you want your personal information deleted.
- Request Disclosure of the categories or types of Personal Information we collect, the purposes for which we collect, sell or disclose that Personal Information, and the categories of third parties to whom we disclose Personal Information.
- Request to Opt-Out (“Do Not Sell My Information”) of “selling” your Personal Information.
We provide you with one or more free means to make the above requests or to opt-out of such Personal Information sharing. To make your above requests or opt out under the CCPA, please click on the above links for the required process and information you must provide to us. We provide both email contact information and a toll-free telephone number. California consumers will be required to submit their name, email address, and telephone number, and may also be asked to provide their address, and a recent order number so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request. A request to opt-out need not be a verifiable consumer request; however, if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent, we may deny the request under the CCPA, in which case we shall inform the requestor that we will not comply with the request and shall provide an explanation why we believe the request is fraudulent.
If you make a request to exercise your rights listed above, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Requests from Authorized Agents
Consumers may authorize agents to act on their behalf. An “agent” under the CCPA means a natural person or a business entity registered with the California Secretary of State to conduct business in California that a consumer has authorized to act on their behalf. If you would like an authorized agent to submit a request on your behalf, please send us an email at email@example.com for instructions and details on the verification required for use of an authorized agent. The above forms that are available for you to exercise your rights under the CCPA permit submission by an authorized agent. Under the CCPA, we may deny a request from an authorized agent if the agent cannot provide to us the consumer’s signed permission or other verifiable confirmation (such as a power of attorney) demonstrating that the agent has been authorized by the consumer to act on the consumer’s behalf.
Requests to Opt-In After Opting-Out of the Sale of Personal Information
If you request to opt-in to the sale of Personal Information under the CCPA after previously opting out, you will need to, first, clearly request to opt-in and then, second, separately confirm your choice to opt-in.
We do not discriminate against you as a California resident for exercising any of your rights listed in this Policy.
“Shine the Light” Notice To California Residents
We do not share your Personal Information with third parties for their independent marketing purposes or other uses as contemplated by California's “Shine the Light” law (Cal. Civil Code Section § 1798.83). If our practices change, we will update this Policy and, to the extent it is reasonably practical, notify you of the change.
- Children Under 13
The Sites are intended for general audiences. MILLY does not intend to, and does not knowingly, collect personal information from children who are under 13 years of age. Children under the age of 13 are not permitted to make purchases on the Sites.
- International Users – Additional Disclosures Under the GDPR for European Union Residents
MILLY operates the Sites from the United States and the Sites are primarily directed at US persons. If you are located outside of the United States, please be advised that we process and store Personal Information in the United States. By using our Sites, you agree to the collection, use, transfer, and disclosure of your Personal Information, and that communications will be subject to the applicable laws in the United States.
If you are a resident of the European Economic Area (EEA), please review Shopify’s and International Checkout’s privacy policies relating to EEA residents and their rights under EEA law, specifically the EU General Data Protection Regulation (GDPR). We use our reasonable commercial efforts to insure that all our service providers for our Sites have in place GDPR-compliant privacy policies, which may include the use of European Commission-approved Standard Contractual Clauses.
MILLY is a subscriber to the EU-U.S. Privacy Shield Framework. We comply with laws governing the international transfer of Personal Data (as defined in the GDPR), typically through the execution of legally required service provider agreements incorporating, where applicable, standard contractual clauses approved for use by the European Union or other instructions that may be specified, updated, amended, replaced or superseded from time to time by the applicable regulatory authority.
We will retain your Personal Data for as long as needed to provide our services to you or as needed to fulfill our own business and legal obligations, including resolving disputes, improving our services, maintaining security, preventing fraud, and meeting applicable regulatory requirements, as consistent with applicable law. We may retain non-personal data that has been sufficiently aggregated or anonymized for a longer period.
You have certain rights and options to protect and/or manage your own Personal Data under the GDPR. These privacy rights are summarized below and explained in this Policy:
- The right to be informed. We are required to tell you what Personal Data we collect, how we use that Personal Data, how long we keep your Personal Data, and with whom we share your Personal Data, including third-parties.
- The right to access. You can ask for a copy of the Personal Data and/or Personal information that we hold about you.
- The right to verify and rectification. You have the right to verify the accuracy of your Personal Data and Personal Information and ask us to update any incomplete information or correct any inaccuracies.
- The right to erasure (also known as the “right to be forgotten”). Under certain circumstances, you are entitled to have your Personal Data deleted or removed.
- The right to withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
- The right to restrict and/or object to the processing of your Personal Data. Under certain circumstances, you have the right to restrict or limit the way in which we use or process your Personal Data and the way Personal Data is automatically processed. You also have the right to object to our use of your Persona Data, provided that we do not have a legal reason to continue to do so. When we do rely on our legitimate interest to use your Personal Data for direct marketing, we will comply with your right to object.
- The right to Personal Data portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another entity without hindrance. This provision applies provided that the data is processed by automated means and that the processing is based on your consent.
- The right to file a complaint. You have the right to bring a claim before your competent Personal Data protection authority.
If you choose not to exercise your GDPR rights as summarized above or described elsewhere in the Policy and you continue to provide us with Personal Data through the Sites, you consent to our use of the Personal Data that you provide and you accept the terms of this Policy.
- Links to Other Sites
- Changes to this Policy
We reserve the right to change this Policy at any time and will alert you in accordance with applicable laws when material changes have been made by indicating at the top of this e Policy the date it was last updated. We encourage you to review our Policy to make sure you understand how your information and data will be used. Your continued use of the Sites following the posting of changes to this Policy will be considered your consent to those changes.
Contact Us: Questions, Concerns About or Reviewing or Correcting Personal Information
If, for any reason, you have questions or concerns regarding any provisions of this Policy or the information that we have collected about you, please contact us by sending an e-mail to firstname.lastname@example.org.
Last Updated December 22, 2020. © 2020 MMJ Apparel LLC. MILLY® and its derivative trademarks and service marks are owned by MMJ Apparel IP LLC and licensed to its affiliate MMJ Apparel LLC.