Copy of Privacy Policy 2

Last Updated Nov 2019

Thank you for accessing Milly.com, which is owned and operated by MMJ Apparel LLC. The terms of this Privacy Policy apply to information collected from you online, on the MILLY^® website at www.milly.com, related websites and our mobile sites (like our blog), on any of our mobile applications or social networking services, and in boutiques operated by MILLY (collectively the "Sites").

We respect your privacy and want to protect your personal information. This Privacy policy lets you know what information we collect from you, what information we disclose, 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 Privacy Policy explains your options regarding the collection, use and disclosure of your personal information.

By visiting the Site, directly or through another site, you accept the practices described in this Policy. This Policy forms a part of our Site Terms of Use at https://www.milly.com/pages/terms-of-use.

In addition, any information you submit in connection with your participation in a contest, giveaway or other promotion sponsored by MILLY or any of its affiliates or partners will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for those contests, giveaways or promotions.

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, address, telephone number, e-mail address, credit card number, information that would permit us to contact a customer physically or online, a customer's account 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 information, such as a person’s Internet IP address, geolocation data and biometric information.

Personal information does not include "aggregate" 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.

We collect certain personally identifiable information defined 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; participate in a contest, promotion or survey; or request other services that require information, registration or subscription. 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, MILLY cookie information and the page you requested).

How We Collect Information

MILLY collects the information that you voluntarily provide, online or in-stores, such as when you:

make a purchase;
register with a Site;
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 mail, online, or by telephone through customer service.

In addition, we and our third-party providers may automatically collect some 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 may 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. For example, we use Shopify, Paypal and Afterpay to administer payment processing. These and other third parties identified in this privacy 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 it.”

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, you have certain additional rights that are set forth below in the California Residents section.

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 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 privacy statement and Google’s privacy policy. 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.
Other Cookies. Some of the cookies are set on social media Sites that are operated by third parties, such as Twitter, Pinterest, Facebook or TurnTo. Third parties, such as advertising networks and providers of external services like web traffic analysis services, may also use cookies and other tracking technologies while you are using the Sites to collect information. We do not control these third parties or their use of cookies, and the information collected by such third parties is not covered by this privacy statement. Please check the websites of those third parties for details on how they use cookies and what your rights are.

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 privacy policy in accordance with applicable law 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.

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.

We may use your information according to the Privacy Notice and Terms of Use in effect at the time of use. The provisions contained herein supersede all previous notices or statements regarding our privacy practices with respect to the Website. We may use aggregated data (independent of any personal identifiers) for research and commercial purposes. This information includes what areas our users visit most frequently and what services they access most often. This information helps us develop a better site that is more useful and accessible to you. We may use your personally identifiable information:

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 which 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 Information

MILLY does not sell, rent, share, or disclose personal information to third parties without your prior consent, except in the limited circumstances described in this privacy policy. It is necessary, however, in order to complete a transaction, for us to provide your personal information to service providers performing services on our behalf. We may share your personal information with selected third parties 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 currently use Shopify for our online sales platform to receive and process all orders and credit card payments. We do not receive or store your credit card information. Shopify’s privacy policy is located at https://www.shopify.com/legal/privacy.

We also use Klaviyo for marketing technology services . Klaviyo’s privacy policy is located at https://www.klaviyo.com/privacy/policy.

We may also access and disclose your personal information in the event that MILLY were to sell or buy any business or assets, in which case we may disclose your personal information to the prospective 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.

Selling Information

We do not sell your personal information that is collected under this Privacy Notice. To the extent we sell any personal information that falls outside the scope of this Privacy Notice, we will disclose our selling practices in the applicable privacy notices linked below.

Access to Personal Information

Use of Personal Information by MILLY

MILLY has implemented physical, electronic and procedural safeguards to store and maintain your personal information in a secure environment. Further, 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. We cannot guarantee that the safeguards we and our providers employ today can protect your Information from the threats of tomorrow. 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 that we believe 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.

Choice/Opt-Out

If you sign up with MILLY to receive electronic newsletters or promotional emails, including new ideas, 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 customercare@milly.com. There is no charge to unsubscribe.

Information about opting-out from targeted advertising and disabling cookies is provided above in the Disabling Cookies and Tracking Technology paragraph.

California Residents: Your Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third-parties for direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third-parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a request by email to the address as provided below in “Contact Us” and specify, in your request, that you want a “California Privacy Rights Notice.” Please allow 30 days for a response.

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 privacy policy or the information that we may have collected about you, please contact us by sending an e-mail to customercare@milly.com.

Other Disclosures

Use of the Milly.com Web Site by Children

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

MILLY operates the Sites from the United States and the Sites are primarily directed at US persons. As a courtesy, we work with a third party, International to fulfill orders placed by customers that require shipment outside of the United States. Information provided to International Checkout is subject to the privacy policy of International Checkout, which is available here (http://www.internationalcheckout.com/privacy-policy.php) as well as the terms of this privacy statement.

All online sales made through our Sites are processed by Shopify, including secure credit card payments. If you are a resident of the European Economic Area (EEA), please review Shopify’s privacy policy relating to EEA residents and their rights under EEA law, specifically the EU General Data Protection Regulation (GDPR) and Shopify’s compliance with the EU-U.S. Privacy Shield Framework, at https://www.shopify.com/legal/privacy.

Links to Other Sites

The Sites may contain links that allow users to access the websites of third parties that provide useful information, or who have agreed to offer goods and services to MILLY members. Any personal information you provide on the linked pages is provided directly to such third-party and is subject to that third party's privacy policy. Except as described above, MILLY is not responsible for the content or privacy practices of websites or applications to which we link. Links from our Sites to third parties’ or other sites are provided for your convenience. We encourage you to learn about the privacy practices of each website before providing them with your personal information.

How We Respond to "Do Not Track" Signals

Our Sites do not respond to or alter the practices detailed herein based upon your selection of the "Do Not Track" setting or other "opt out" setting or feature that may be offered by your browser.

Changes to this Statement

MILLY reserves the right to change this privacy 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 the privacy statement the date it was last updated. We encourage you to review our privacy statement to make sure you understand how your information will be used. Your continued use of the Sites following the posting of changes to this privacy statement will be considered your consent to those changes.

Copy of Privacy Policy 2

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