PRIVACY POLICY

Millicast (“Millicast,” "we," "us," or "our") respects your privacy and is committed to protecting the Personal Data it collects. The purpose of this Privacy Policy is to inform you of how we protect your privacy when accessing or using Millicast's Services.

This Privacy Policy applies to Millicast's Services that link to, or reference, this Privacy Policy, and describes the ways Millicast collects and uses your personal information and the choices you have regarding collection, use, maintenance, access and transmission of your personal information. Capitalized terms not expressly defined in this Privacy Policy shall have the meaning found in the Terms of Service. By utilizing the Millicast Service, including, without limitation, the website or otherwise providing your Personal Data to Millicast via any other means, you or the entity you represent ("you" or "your") accept and consent to the rights, obligations and practices described in this Privacy Policy.

1. Who does the Privacy Policy apply to?

This Privacy Policy applies to all Clients of the Millicast Service, and Visitors to the Millicast website. In the case of Clients, Client shall be responsible for (a) informing their customers (“End Users”), if any, of the existence of this Privacy Policy and (b) agreeing to this Privacy Policy, as amended, updated or modified from time to time, on behalf of his, her or its End Users.

In the case of End Users, (a person who uses a Client’s application or website that incorporates the Millicast Service) Millicast has no direct relationship with such End User and Millicast will not collect their Personal Data directly from them. In the event an End User seeks to access, correct, amend or delete data, the End User should contact the Client directly.

If you are a person who has directly signed up with Millicast for the use of Millicast’ Services and you seek to access, correct, amend, or delete data, you should contact Millicast directly. If requested to remove data under either scenario, Millicast will respond within a reasonable timeframe.

2. What Personal Data is Collected by Millicast?

Millicast considers any information that can be used to directly or indirectly identify you to be Personal Data, including without limitation, Personal Data that is accessed, collected, maintained, transmitted and/or used by Millicast in the normal course of our business, and is subject to the provisions of this Privacy Policy and applicable law.

The Personal Data we collect may include, but is not limited to, your full name, email address, phone number, account log-in credentials, billing address, credit card information, IP address and any information you choose to include in your correspondence to Millicast.

In the case of an End User, if End User utilizes a Client’s website or application that incorporates Millicast’ Service, we may receive and store such End User’s IP address from Client. Depending on how the Client has implemented our Service, Client may also collect further Personal Data from such End User and we may also receive such Personal Data to transmit across our Service on behalf of the Client. In this case, the End User should direct all requests regarding the Personal Data collected directly to the Client. It is the Client’s responsibility to obtain express consent of End Users to transfer their Personal Data to Millicast. Millicast may store the aforementioned Personal Data upon the request of Client and applies the same security measures as described in Section 7 to End User’s Personal Data received from Client.

3. How is Personal Data Collected by Millicast?

Millicast collects and logs your IP address, the time and duration of your visit, the time and duration of the pages on Millicast's website that you view (where applicable) and information about your computer system, such as your browser type and operating system, whenever the Millicast Service is accessed or used by you. In the case of Clients, we collect, maintain, transmit and/or use Personal Data provided by you in your account, including without limitation, your full name, Millicast identification number, billing data and contact information.

Millicast utilizes third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please email privacy@Millicast.com.

Millicast also collects anonymous usage information on Visitors to its website through use of Google Analytics. Google Analytics may employ third party tracking cookies to gather anonymous browser, operating system, geographic, and website navigation information.

Millicast also uses AdRoll who may place cookies on Visitor’s browsers for targeted advertising purposes. If you would like to opt out of having your information collected by or submitted to AdRoll, please email privacy@Millicast.com.

Use of the Millicast Dashboard interface requires the acceptance of cookies for login session management purposes. Millicast will likely place a cookie on your hard drive during the web visit. A cookie is a unique alphanumeric identifier that Millicast uses to determine the number of unique Visitors that view its website, whether or not those Visitors are repeat Visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus. Other servers cannot read cookies and personal information cannot be gathered from cookies. Cookies are simply an identifier shared between you and Millicast to allow Millicast to improve the services Millicast offers to you through its website. If you do not wish cookies to be placed on your computer, then they can be disabled in your web browser. The option to do so is normally found in your browser's "security settings" section. However, please note, permanently disabling cookies in your browser may hinder your use of Millicast's website as well as other website and interactive services.

A web beacon, also known as a web bug, is a small graphic (usually 1 pixel x 1 pixel), that is embedded in a web advertisement, email, or page on Millicast's website, which is invisible to you. When you view a page on Millicast's website, an e-mail or an advertisement, your web browser will request the web beacon from a web server, which in turn will set a cookie in your web browser containing a unique identifier. This unique identifier will be linked to log information that is used to track your usage of Millicast's website in order to determine the effectiveness of content and advertising campaigns.

Millicast does not collect personal information about you as part of a web visit, but web visit information may be tied to other information (including personal information) that Millicast collects from you via chat, web forms, and the other means Millicast describes in this Privacy Policy.

4. Why Does Millicast Collect Personal Data?

For Clients
Millicast may use your Personal Data to handle orders, process your service requests, deliver products and services, process payments, communicate with you about orders, provide access to secure areas of Millicast’ website, and to enable Millicast to review, develop and continually improve the products and services that it provides. Millicast also uses this information to prevent or detect fraud or abuses of Millicast’ website and to enable third parties to carry out technical, logistical or other functions on its behalf.

For Visitors
Millicast uses Personal Data to send information about Millicast to Visitors and to contact them when necessary. Visitors have discretion as to whether to grant information to Millicast upon Millicast’ request for information.

For Financial Information
Millicast may ask Clients to enter credit card or account information in order to process orders for services placed with Millicast. Financial information provided via its website is transferred over a secure connection via Stripe, Inc., a payment processing company. Millicast does not collect this information and will not authorize the release of the information to anyone not directly involved in processing the transaction. This information may be encrypted and stored for logging purposes by Stripe, Inc.
Credit card numbers are used by Stripe, Inc. only for processing payments and are not used for any other purposes. Millicast will ensure that appropriate security and confidentiality measures are in place in safeguarding your personal data.

For Use Information
Millicast uses website use information to measure interest in and develop its web pages and marketing plans, customize the content you view on your web visits based on your activity during past visits, and administer Millicast's website. In addition:
• Millicast uses a Visitor's IP address to help diagnose problems with its servers, and to administer its website.
• Millicast uses cookies to help it recognize Visitors as unique Visitors when they return to Millicast's website. Millicast also uses cookies to tailor content or advertisements to match your preferred interest; avoid showing Visitors the same advertisements repeatedly; compile anonymous, aggregated statistics that allow Millicast to understand how users use its site and to help it improve the structure of its website (Millicast cannot identify Visitors personally in this way); and count the number of anonymous users of its websites.
• Millicast uses web beacons to count the number of times that its advertisements and web-based e-mail content are viewed. Millicast combines web beacon information with cookies to track activity on its website originating from advertisements and web-based e-mail content.

For Support Information
Millicast uses information that you provide to it via telephone calls, chat, e-mail, web forms and other communications to correspond with you about services you may be interested in purchasing. If you elect to purchase a service online using a web form, Millicast will use the information to establish your account. Information you submit in writing, such as chat, e-mail, and web form information is archived and may be tied to information that Millicast collects about your web visits.

5. Millicast's Disclosure of Personal Data to Regulatory Agencies

Millicast transfers Personal Data to third parties, including without limitation, law enforcement agencies and consumer reporting agencies, under the following normal business procedures:
• Millicast uses a Visitor's IP address to help diagnose problems with its servers, and to administer its website.
• Millicast uses cookies to help it recognize Visitors as unique Visitors when they return to Millicast's website. Millicast also uses cookies to tailor content or advertisements to match your preferred interest; avoid showing Visitors the same advertisements repeatedly; compile anonymous, aggregated statistics that allow Millicast to understand how users use its site and to help it improve the structure of its website (Millicast cannot identify Visitors personally in this way); and count the number of anonymous users of its websites.
• Millicast uses web beacons to count the number of times that its advertisements and web-based e-mail content are viewed. Millicast combines web beacon information with cookies to track activity on its website originating from advertisements and web-based e-mail content.
• If you breach the Terms of Service or other applicable Service Level Agreement, or if Millicast is under a duty to disclose or share your personal data in order to comply with any legal obligation, Millicast may disclose your information to a relevant authority. Disclosure may include, but is not limited to, exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. In particular, Millicast may release the information it collects to third parties when Millicast believes that it is appropriate to comply with the law, to enforce its' legal rights, to protect the rights and safety of others, or to assist with industry efforts to control fraud, spam or other undesirable conduct.
• Millicast may release the information it collects to third parties, where the information is provided to enable such third party to provide services to Millicast, provided that the third party has agreed to use at least the same level of privacy protections described in this Privacy Policy, and is permitted to use the information only for the purpose of providing services to Millicast.

6. User Choice

Subject to applicable law, you have the choice to and right to limit, restrict or deny Millicast's ability to share your Personal Data with third parties or use of your Personal Data for a purpose that is materially different from the purpose for which it was originally collected or authorized by you. In order to exercise your right to choose, please contact us at privacy@Millicast.com, or via postal mail or facsimile using contact information found on Millicast's Contact page. Please note, in the absence of any notice to the contrary, you expressly grant Millicast permission to share your Personal Data at Millicast's discretion.

7. Security, Integrity and Retention of Personal Data

Millicast intends to protect and secure Personal Data, including End User Personal Data that you may transmit through our Service, in accordance to the terms of this Privacy Statement and the Terms of Service, and has implemented physical, administrative and technical measures designed to protect Personal Data from unauthorized access, use or disclosure. These industry-standard safeguards include without limitation encryption of password and/or cryptographic key-based authentication controls on servers which house personal information, browser-based secure sockets layer encryption, and other storage system access control mechanisms to protect the integrity of internal databases and prevent unauthorized access.
It is also your responsibility to ensure authorized access to Personal Data by selecting and protecting your password appropriately and limiting access to your Millicast account.
Millicast requires all Millicast business partners and vendors to provide the same or greater protections for any Personal Data that is disclosed by Millicast in furtherance of our provision of the Millicast Service to you. To learn more about Millicast's contractor requirements, please contact us at privacy@Millicast.com.
Millicast retains your Personal Data, including End User IP addresses we may receive, as long as we provide Service to you. We retain Personal Data after we cease providing Service to you, even if you close your Millicast account to the extent necessary to comply with our legal and regulatory obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

8. Access to your Personal Data

You control access to Personal Data maintained or stored by you via Millicast's web-based interface for account management. You may update your information at any time. You may cancel your account at any time and may request that your personal information be deleted from Millicast's databases, with the exception of: network access logs, which may be stored for any duration of time at Millicast's discretion, cases where financially fraudulent or otherwise illegal activity is deemed to have occurred (as determined by Millicast management or law enforcement officials), in which case personal information may be retained indefinitely for purposes of ongoing investigation and prevention of fraud recurrence, or cases where a violation of the Terms of Service and applicable Service Level Agreement has resulted in cancellation of your account (as defined by revocation of your permission to utilize Millicast's services), in which case personal information may be retained indefinitely for purposes of prevention of further use of Millicast's services in the future by the offending individual.
Upon request, Millicast will grant you reasonable access to Personal Data maintained by Millicast about you. In addition, we will take reasonable steps to correct, amend or delete information that is demonstrated by you to be inaccurate, incomplete or processed in violation of applicable law. Unless required by law, Millicast will not permit you to access the Personal Data of any data subject other than yourself.
If you have any concerns or suspect unauthorized activities associated with your account, please contact us at privacy@Millicast.com. Millicast will respond to all requests regarding Personal Data within a reasonable timeframe.

9. International Transfers of Personal Data

Millicast is headquartered in the United States of America (the "US") and provides its Service internationally. By utilizing the Millicast Service, you expressly consent to Millicast's access, maintenance, transmission and/or use of your Personal Data outside of your country of residence, regardless of location or jurisdiction.
In addition to its obligations under US law, Millicast supplements the protection of the international transfer of your Personal Data by observing numerous industry best practices of data encryption.

10. Sensitive Information

Millicast will not intentionally collect or maintain, and requests that you do not provide, any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive information. If you store any data or information that is sensitive and/or violates any other law or regulation, such information and compliance with applicable privacy laws remains solely your responsibility. Millicast is not responsible for any sensitive information stored by you on its system.

11. Children's Online Privacy Protection

Millicast's services are not designed for or directed to children under thirteen (13) years of age and Millicast will not intentionally collect or maintain information about anyone under thirteen (13) years of age.

12. Data Service

You are solely responsible for ensuring compliance with any and all applicable privacy guidelines and regulations for all jurisdictions in which you may operate with respect to appropriate practices for the collection, storage, and dissemination of personal information using the Millicast Service. In no event shall Millicast be held liable for your failure to adopt and/or practice appropriate measures for safeguarding personal information stored within or transmitted through the Millicast Service.

13. Dispute Resolution

Please direct any complaints regarding this Privacy Policy to us at privacy@Millicast.com, or via postal mail or facsimile using contact information found on Millicast's contact page. We will attempt to resolve any such complaints in a reasonably timely manner and in accordance with this policy.

14. Enforcement

If you believe your Personal Data has been used in a way that is not consistent with this Privacy Policy, or if you have further questions regarding this Privacy Policy, please contact our Custodian of Records via email or by writing us at the following address:
Custodian of Records
Millicast
25061 Avenue Stanford, Suite 10
Santa Clarita, CA 91355

15. Definitions

"Custodian of Records" means the Millicast employee described in Section 14 of this Privacy Policy.
"Terms of Service" means the Millicast data processing and Terms of Service published here, as amended at Millicast's sole and absolute discretion from time to time.
"IP" means any internet protocol address, including without limitation, unique and non-unique network addresses.
"Personal Data" means any information relating to a data subject that you directly or indirectly provide to us as part of the Millicast Services or any data subject's use of any Millicast Service.
"Privacy Policy" means this policy, as amended at Millicast's sole and absolute discretion from time to time.
"Visitor" or "Visitors" means any individual(s) or entity(ies) that accesses, maintains, transmits, develops, acquires, operates or otherwise uses any Millicast Service but is not a Client.

16. Changes

Amendments to this Privacy Policy may be made at any time and you should check back frequently for any changes. Millicast will also provide public notice of amendments to this Privacy Policy on the appropriate Millicast Service. Unless otherwise directed by you in writing to the Custodian of Records, you agree that Millicast shall have the right and ability to amend this Privacy Policy at Millicast's sole and absolute discretion, and that you waive any requirement for specific or expressed acknowledgement or agreement to any such amendments or modifications. This Privacy Policy was last updated on July 12, 2018.

17. Verification

Millicast utilizes the self-assessment approach to assure its compliance with its Privacy Policy. Millicast regularly verifies that the Privacy Policy is accurate and in conformity with applicable local and international law.

This policy was last modified July 12, 2018.