PRIVACY NOTICE
Last updated December 27, 2022
This privacy notice for Milli Estates LLC ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
- Visit our website at milliestates.thinkific.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Milli Estates LLC and the Services, the choices you make, and the products and features you use. Click here to learn more.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Click here to learn more.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what Milli Estates LLC does with any information we collect? Click here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe and Paypal. You may find their privacy notice link(s) here: Privacy Policy We’re updating Stripe’s Privacy Policy effective January 24, 2023. Learn more. Last updated: February 3, 2022 This Privacy Policy includes important information about your personal data and we encourage you to read it carefully. Welcome We provide economic infrastructure for the internet. Businesses of all sizes use our software and services to accept payments and manage their businesses online. Stripe cares about the security and privacy of the personal data that is entrusted to us. This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us. Please visit the Stripe Privacy Center for more information about our privacy practices. “Stripe”, “we”, “our” or “us” means the Stripe entity responsible for the collection and use of personal data under this Privacy Policy. It differs depending on your country. Learn more. “Personal Data” means any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP address). “Services” means the products and services that Stripe indicates are covered by this Policy, which may include Stripe-provided devices and apps. Our “Business Services” are Services provided by Stripe to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Services which Stripe directs to individuals (rather than entities) so that those individuals do business directly with Stripe. “Sites” means Stripe.com and the other websites that Stripe indicates are covered by this Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”. Depending on the context, “you” means End Customer, End User, Representative or Visitor: When you directly use an End User Service (such as when you sign up for Link, or make a payment to Stripe Climate in your personal capacity), for your personal use, we refer to you as an “End User.” When you do business with, or otherwise transact with, a Business User (typically a merchant using Stripe Checkout, e.g. when you buy a pair of shoes from a merchant that uses Stripe for payment processing) but are not directly doing business with Stripe, we refer to you as an “End Customer.” When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.” When you visit a Site without being logged into a Stripe account or otherwise communicate with Stripe, we refer to you as a “Visitor.” (e.g. you send Stripe a message asking for more information because you are considering being a user of our products). Depending on the activity, Stripe acts as a “data controller” or “data processor” and for more information about this and on the Stripe entity that is responsible under this Policy, see here. 1. Personal data that we collect and how we use and share it 2. More ways we collect, use and share personal data 3. Legal bases for processing data 4. Your rights and choices 5. Security and retention 6. International data transfers 7. Updates and notifications 8. Jurisdiction-specific provisions 9. Contact us 1. Personal data that we collect and how we use and share it 1.1 End Users We provide End User Services where we do not act as a service provider to Businesses but instead provide the Services directly to you for your personal use (e.g. Link user). See here for further information on the legal bases which we rely on for using (processing) your Personal Data. Personal data that we collect about End Users Using Link or Connecting your Bank Account. Stripe offers you the opportunity to store your payment methods with Stripe so that you can conveniently use it across merchants who are our Business Users – we call this “Link” (formerly known as “Remember Me”). When you opt in to Link, you agree to let us store your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services (e.g. name, card number, cvc, and expiration date). When you choose to pay with Link, we will also collect your Transaction Data. Learn More. If you choose to share bank account information (including for use in Link) with us, Stripe will periodically collect and process your bank account information (e.g. account owner information, account balances, account number and details, account transactions and in some cases, credentials) until you ask us to disconnect your bank account. Learn More. Paying Stripe. If you are buying goods or services directly from Stripe, we receive Transaction Data. For example, when you make a payment to Stripe Climate, we will collect contact information, payment method information, information about that transaction and in some cases, shipping information. Other Services. We may offer other End User Services directly to you from time to time, including certain financial Services. Learn More for information about our collection and use of Personal Data. More. Please see below for information about additional types of Personal Data that we may collect, including about online activity. How we use and share personal data of End Users Services. We use your Personal Data to provide the End User Service to you, including security, delivery, support, personalization and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). We also use your Personal Data for our fraud detection and mitigation Business Services and may share certain Personal Data as part of those Business Services with Business Users that you may seek to do business with. The use of this Personal Data is subject to the Business Users’ privacy policies. Our Business Users. When you choose to connect your bank account with Stripe, you may also choose to share account information with certain Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information. Transactions. For payment transactions with Link, End User Personal Data is shared with others to enable the transaction. For example, when you choose to use a payment method for the transaction with Stripe or with Link (e.g. credit card, debit card, buy now pay later, or direct debit), that payment method will receive transaction information that includes your Personal Data. Please review your payment method’s privacy policy to learn more. When you use Link, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and with your permission, your bank account information. The merchant may share that Personal Data with others (see below regarding End Customers). Please review your merchant’s privacy policy for further information. Fraud Detection Services. We use your Personal Data collected across our Services (e.g. Stripe Radar) to detect and prevent fraud against us, our Business Users and financial partners, including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction here. Advertising. We may use your Personal Data to assess your eligibility for and offer you other End User Services. With your permission or where allowed by law, we use and share End User Personal Data with others so that we may market our products and services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. See our Cookie Policy. We do not share End User Personal Data with third parties for their marketing or advertising unless you give us or the third party permission to do so. We do not sell the data of End Users. More. Please see below for information about additional ways in which we may use and share your Personal Data. 1.2 End Customers Stripe offers Business Services to our Business Users (e.g. in-person checkout or online checkout). When we are acting as a Business User’s service provider (or data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. For example, we process payment transactions for a Business User because you bought a product from them. Business Users are responsible for making sure that their End Customer’s privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer (e.g., a purchaser of a product at an online Business User site), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly. See here for further information on the legal bases which we rely on for using (processing) your Personal Data. a. Personal data that we collect about End Customers Transaction Data. If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation or otherwise transact with a Business User that uses us to provide payment processing Business Services, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data, and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased and your phone number. We may also receive your transaction history with the Business User. Learn More. We may collect information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User. Learn More. Identity/Verification Information. Stripe provides a verification and fraud Service that allows a Business User to verify Personal Data about you, such as your age (when purchasing age restricted goods) or your authorization to use a payment method. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input or that is apparent from the physical payment method (e.g. credit card image). We may compare this information with information about you we collect from Business Users, financial partners, business partners, identity verification services, publicly available sources, and third party service providers. Learn More. More. Please see below for information about additional types of Personal Data that we may collect, including about online activity. b. How we use and share personal data of End Customers We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Stripe’s own purposes to secure, improve and provide our Business Services, as described below. Payments. We use your Transaction Data to provide our Payments related Business Services to Business Users, including to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to calculate their revenue. Learn More. We may also use Personal Data to provide and improve our Business Services. For payment transactions, your Personal Data is shared with a number of parties in connection with your transaction. Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example, when you choose to use a payment method for the transaction (e.g. credit card, debit card, buy now pay later, or direct debit), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information. The merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and the merchant may share that Personal Data with others. Please review your merchant’s privacy policy to learn more. Other Financial Services. Some of our Business Users use our Services in order to offer financial services to you, through Stripe or its financial partners. For example, they may provide a card product that enables you to purchase goods and services. These cards may carry the Stripe brand, bank partner brand and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our bank partner, if applicable, associated with the financial service (whose brands may be shown on the card). Identity/Verification Services. We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Stripe or for the Business Users that you are doing business with and to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified. Learn More. Fraud Detection Services. We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users and financial partners (e.g. Stripe Radar), including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction and what information we may share with Business Users about such risks here and here. Our Business Users (their Authorized Third Parties). We share Personal Data of End Customers with their respective Business Users and with parties directly authorized by those Business Users to receive Personal Data. This includes sharing Personal Data of End Customers with Business Users when a Business User authorizes a third party application provider to access its Stripe account using Stripe Connect. For example, when the Business User uses Identity Services to verify an End Customer’s identity, Stripe shares with the Business User the information, documents or photos provided by the End Customer to verify their identity. The Business Users you choose to do business with may further share your Personal Data to third parties they authorize. Please review your merchant’s privacy policy to learn more. Advertising by Business Users. If you have begun a purchase, we share Personal Data with that Business User in connection with our provision of Services and that Business User may use your Personal Data to market and advertise their products or services. Please review your merchant’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. We do not use or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact. We do not sell the data of End Customers. More. Please see below for information about additional ways in which we may use your Personal Data. 1.3 Representatives To provide Business Services, we collect, use and share Personal Information from Representatives of our Business Users (e.g. a business owner). If the Representative is the only employee of a Business User, please see the End User and End Customer sections to understand additional ways in which we can collect and use your Personal Data when you use our Services. See here for further information on the legal bases which we rely on for using (processing) your Personal Data. a. Personal data that we collect about Representatives Registration and Contact Information. If you register for a Stripe account for a Business User (including incorporation of a Business), we collect your name and account log-in credentials. If you register for an event that Stripe organizes or attends or if you sign up for Stripe communications, we collect your registration and profile information. If you are a Representative of a potential Business User, we receive your Personal Data from third parties (including data providers) in order to advertise to, market and communicate with you as described further below and in Section 2. Identification Information. If you are an owner of a Business User or you are expected to be a shareholder, officer or director of a Business User, we require that you provide your contact details, such as name, postal address, telephone number, and email address to fulfill our financial partner and regulatory requirements. We may also collect financial and personal information about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your Business User (such as your social security number, tax number, or Employer Identification Number). You may also choose to provide bank account information. More. Please see below for information about additional types of Personal Data that we may collect, including about online activity. b. How we use and share personal data of Representatives We generally use Personal Data of Representatives to provide the Business Services to the associated Business Users, as well as for the purposes described below. Business Services. We use and share Personal Data of Representatives with Business Users to provide the Services. For users of our tax Business Services, we may use your Personal Data to file taxes on behalf of your associated Business User. If your Business User uses Atlas, we may use your Personal Data to submit forms to the IRS on your behalf and to file documents with other governmental authorities (e.g. articles of incorporation in your state of incorporation). We share data with parties directly authorized by a Business User to receive Personal Data (e.g. financial partners servicing the financial product). The use of Personal Data by a Business User’s authorized third party is subject to the third party’s privacy policy. In some cases our Business Service will require us to submit your Personal Data to a government entity (e.g. incorporating a business, or paying applicable sales tax). Advertising. With your permission or where allowed by applicable law, we use and share Representative Personal Data with others so that we may advertise and market our products and services to you, including through interest-based advertising subject to any consent requirements under applicable law. See our Cookie Policy. We do not sell Representative Personal Data. More. Please see below for information about additional ways in which we may use and share your Personal Data. 1.4 Visitors (e.g. visitors to Stripe sites who are not an End User, End Customer or Representative) See here for further information on the legal bases which we rely on for using (processing) your Personal Data. a. Visitor personal data that we collect When you visit our Sites, we generally receive your Personal Data either from you providing it to us or through our use of cookies and similar technologies. See our Cookie Policy. Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form, usually your contact information and other information about your question related to our Services. More. Please see below for information about additional types of Personal Data that we may collect, including about online activity. b. How we use and share visitor personal data Personalization. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience and to tailor content about Stripe and our Services to you. Advertising. With your permission or where allowed by law, we use and share Visitor Personal Data with others so that we may advertise and market our products and services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. See our Cookie Policy. More. Please see below for information about additional ways in which we may use your Personal Data. 2. More ways we collect, use and share personal data In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows. a. Personal Data Collection Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about: Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”), Usage data associated with those devices and browsers, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, and the pages that led or referred you to Sites and Third-Party Sites. For example, activity indicators, like mouse activity indicators, help us detect fraud. Learn More. Please also see our Cookie Policy. Communication and Engagement Information. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Stripe emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Stripe, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Stripe events and other interaction with Stripe personnel. Forums and Discussion Groups. Where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post. b. Personal Data Usage. In addition to the ways described above in which we use Personal Data, we use Personal Data in the following ways: Improving and Developing our Services. We use analytics on our Sites to help us analyze your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy. We also collect and process Personal Data through our different Services, whether you are an End User, End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you. Communications. We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you. Learn More. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns. Social Media and Promotions. If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. Based on your permission or opt-out, we will also use that Personal Data and Personal Data you make available on social media to market to you. Fraud Prevention and Security. We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Stripe and its Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised. Learn More. This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner. Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas, and other legal obligations. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Stripe, our End Users and their End Customers. Minors. The Services are not directed to minors, including children under the age of 13, and we request that they do not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of End Customers, Representatives, Visitors or End Users, including those aged between 13 to 16. c. Personal Data Sharing. In addition to the ways described above, we share Personal Data in the following ways: Stripe Affiliates. We share Personal Data with other Stripe affiliated entities. When we share with these entities, it is for purposes identified in this Policy. Service Providers or Processors. In order to provide Services to our Business Users and End Users and to communicate, market and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers (provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorize such service providers to use or disclose the Personal Data of our Users that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union, the United States of America and India. Learn More. Financial Partners. “Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data of our Users with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners. For example, we share certain Personal Data of Representatives (e.g. loan repayment data and contact information) with institutional investors who purchase the Capital loans that we have made to the associated Business Users. Others with Consent. In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services (e.g. professional services firms that we partner with to deliver Atlas). In these cases, we will disclose the identity of the third party and the information that will be shared with them, and seek your consent to share the information. Corporate Transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy. Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Stripe, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. 3. Legal bases for processing data For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data. For more information see here. a. Contractual and Pre-Contractual Business Relationships. We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations that we have with these Users. Activities include: Creation and management of Stripe accounts and Stripe account credentials, including the evaluation of applications to commence or expand the use of our Services; Creation and management of Stripe Checkout accounts; Accounting, auditing, and billing activities; and Processing of payments, including fraud detection and prevention, optimizing valid transactions, communications regarding such payments, and related customer service. b. Legal Compliance. We process Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as "Anti-Money Laundering ("AML") and Know-Your-Customer ("KYC")" obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits. c. Legitimate Business Interests. Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data: Detect, monitor and prevent fraud and unauthorized payment transactions; Mitigate financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and Stripe; Determine eligibility for and offer new Stripe products and services Learn More; Respond to enquiries, send Service notices and provide customer support; Promote, analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services; Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets; Analyze and advertise our Services; Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business; Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business Learn More; Enable network and information security throughout Stripe and our Services; and Share Personal Data among our affiliates. d. Consent. We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services like Link, Atlas and Identity. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. 4. Your rights and choices You may have choices regarding our collection, use and disclosure of your Personal Data: a. Opting out of receiving electronic communications from us If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or as described here. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf. b. Your data protection rights Depending on your location and subject to applicable law, you may have the following rights described here with regard to the Personal Data we control about you: The right to request confirmation of whether Stripe processes Personal Data relating to you, and if so, to request a copy of that Personal Data; The right to request that Stripe rectifies or updates your Personal Data that is inaccurate, incomplete or outdated; The right to request that Stripe erase your Personal Data in certain circumstances provided by law. Learn more; The right to request that Stripe restrict the use of your Personal Data in certain circumstances, such as while Stripe considers another request that you have submitted (including a request that Stripe make an update to your Personal Data); The right to request that we export your Personal Data that we hold to another company, where technically feasible; Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or Where we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object. c. Process for exercising your data protection rights To exercise your data protection rights please also see the Stripe Privacy Center or contact us as described below. 5. Security and retention We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately. Learn More. We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Stripe account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Learn More. 6. International data transfers We are a global business. Personal Data may be stored and processed in any country where we do business, where our service providers do business or if you use an international payment method or financial partner service, the countries in which that payment method or financial partner operates. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities). If you are located in the European Economic Area (“EEA”), the "United Kingdom ("UK")" or Switzerland, please see Stripe Privacy Center for more information. Where applicable law requires a data transfer mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA, Switzerland or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal methods available to us under applicable law. For transfers to third countries we have entered into Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Data to those entities outside the EEA. You can obtain a copy of the relevant Standard Contractual Clauses. Learn More. While Stripe Inc. remains self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks for the transfer of personal data to the U.S. For more information, please see Stripe Privacy Center. 7. Updates and notifications We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services. We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Business User, by contacting you through your Stripe Dashboard, email address and/or the physical address listed in your Stripe account. If applicable law requires that we provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice. 8. Jurisdiction-specific provisions Australia. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Policy, you may wish to contact the Office of the Australian Information Commissioner. EEA and UK. To exercise your rights, you may contact our DPO. If you are a resident of the EEA or we have identified Stripe Payments Europe Limited as your data controller, and believe we process your information within the scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated financial activities in Europe, Stripe Payments Europe Limited and Stripe local regulated entities (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) are considered joint controllers. Learn More. Indonesia. As used in this Policy, “applicable law” includes Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions, Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions, and Minister of Communication and Informatics Regulation No. 20 of 2016 on Personal Data Protection in Electronic Systems and “Personal Data” includes “personal data” as defined under such laws. Malaysia. If you have any questions or complaints about this Policy, please contact our DPO. Thailand. Thailand residents may have additional rights under applicable laws. If we process your Personal Data due to a legal obligation or contractual right, and you do not provide us with personal Information, we may not be able to lawfully provide you services. United States - California. If you are a consumer located in California, we process your personal information in accordance with the California Consumer Privacy Act ("CCPA"). You have a right to receive notice of our practices at or before collection of personal information. This section provides additional details about the personal information we collect and use for purposes of CCPA. How We Collect, Use, and Disclose your Personal Information. The Personal Data We Collect section further describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the How We Use Personal Data section. We share this information as described in the How We Disclose Personal Data section. For specific details, please see here. Stripe uses cookies, including advertising cookies, as described in our Cookie Policy. Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information (learn more): Exercising the right to know: you may request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about categories of their personal information collected, sold, or disclosed; purposes for which this personal information was collected or sold; categories of sources of personal information; and categories of third parties with whom we disclosed this personal information. Exercising the right to delete: you may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law. Exercising the right to opt-out from a sale: We do not sell Personal Data as defined by the CCPA and have not done so in the past 12 months. Non-discrimination: The CCPA provides that you may not be discriminated against for exercising these rights. To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us. Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account. An authorized agent may submit a request on your behalf by contacting us using the methods described in the Contact Us section below. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request. 9. Contact us If you have any questions or complaints about this Policy, please contact us. If you are an End Customer (i.e. an individual doing business or transacting with a Business User), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly. and Last updated on November 6, 2022 Overview This privacy statement explains how and why PayPal collects, stores, uses, and shares personal information when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices. By using the Site or Service, you agree to the collection and use of information in accordance with this privacy statement and the applicable user agreement (PayPal, Braintree, Hyperwallet, and Xoom). “Personal information” in this statement means information about you, including your identity, finances, and online behavior. “PayPal” in this statement means PayPal, Inc. This privacy statement applies to the PayPal, Braintree, Xoom, and Hyperwallet services offered by PayPal. To learn about our privacy practices for Venmo, Honey, Happy Returns, Chargehound, or Simility, visit the website and review the privacy statement for those services. Your privacy rights and choices When it comes to how your personal information is collected, stored, used, and shared, you have rights and choices. Understanding your rights You have the right to request a copy of the personal information we’ve collected about you in the past 12 months. You also have the right to ask us to delete your personal information we have collected about you. If you or an authorized agent want to see or delete your personal information, contact us or submit your request from your account settings. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights. If you are a California resident, learn more about how we have handled your Privacy Rights. If you or an authorized agent request to see or delete your personal information, we’ll first need to verify who you are before we can respond to your request. If we can’t verify your identity, we will not be able to fulfill your request. If you want to delete your personal information, you have choices: Log in to your account and delete information you previously added. For example, you can delete your profile picture and non-primary addresses in your settings Call us or contact us and request that we delete specific information Close your account If you close your account or request that we delete personal information, we still need to keep some personal information so we can: Complete a transaction, provide goods or services you requested, or comply with our promises to you in the user agreement or other contract you have with us Detect and prevent malicious, fraudulent, or illegal activity Protect your (or another person’s) legal rights, including the right to free speech Manage our internal business processes that are reasonably related to your expectations when using our services Comply with laws Depending on where you live and what type of account you use, you may have different rights and choices for managing your personal information. For example, certain State privacy laws do not apply to personal information collected, processed, or disclosed by a financial institution according to federal laws, such as the Gramm-Leach-Bliley Act. Consumers may read our Consumer Privacy Notice for more information about their rights under US federal law. Understanding your choices You can control how personal information is collected or shared, as well as how we communicate with you. Here are some of the ways you can customize your choices. Choose how we collect personal information You may choose to limit the personal information you provide when our apps or services request it. To help make choices that are right for you, it’s important to understand that personal information helps us provide a richer, more personalized experience for you. Also, some personal information is required for our services to function at all. For example, sharing your contacts helps make it easier for you to find the people you want to send money to. If you choose not to share your contacts with us, you can still use our mobile apps, but some actions may not be as fast or easy as it would be if shared your contacts. Another example is creating an account with us. If you choose not to provide information that is required for an account to function, like your name and email address, we will not be able to create an account for you. Choose how connected accounts collect and use personal information If you connect your account to a third-party service, you may be able to manage how your personal information is collected, used, and shared by them. Read the third parties’ privacy policies to see the choices they offer you. You can control which third-party services you connect to your account and what personal information they can collect about you. For example, to manage the permissions, go to the Security settings in your PayPal account. Choose how we communicate with you Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional, and some are necessary for you to manage your accounts with us. We use email, text messages, push notifications on your mobile device, and even phone or paper mail depending on the situation and your preferences. You can click the unsubscribe link in a marketing email, opt out of a text message by replying “STOP,” or turn off notifications on your device. You can also change your account’s notification settings or the notification preferences on your device. You won’t be able to opt out of messages that are considered necessary for you to manage your account, such as receipts and emails that alert you to changes in your account’s status that require your attention. You may be able to decide how we send those messages, such as by email, phone, text message, or a notification on your mobile device. Notice to Non-Account Holders If you use our services without creating or logging into an account, we’ll still collect personal information, which may include your payment information, device information, and location. When you use our services without creating or logging into an account, we will use this information to provide and improve the service, including to process transactions, prevent fraud, and comply with the law. We may connect this information with your account, if you have one at the time you use the service without logging in, or if you create an account at a later date. When you shop on merchant or partner sites, upon your consent, merchant may share data with PayPal that will be used in accordance with this privacy statement. The personal information we collect We may collect your personal information when you register for or use our services, such as when you create an account, make a payment, send a payout, or make a purchase on a merchant’s website. Here are the kinds of personal information that we may collect when you create an account or use our services: 1. Information that identifies you, for example: First and last name Address Phone number Email IP address Device Information Information collected from cookies or other tracking technologies 2. Records and financial information, for example: Social Security Number Government-issued identification Bank account and routing numbers Credit and debit card information Financial information 3. Personal characteristics, for example: Age or Date of Birth National origin Disability Citizenship Military status 4. Commercial information, for example: Online shopping cart information Purchase history Order and product information 5. Internet or network activity, for example: Interactions with our services or sites Shopping history 6. Geolocation data, for example: Global Positioning System (GPS) information when you give us permission through your device settings IP-based geolocation 7. Audio, electronic, visual, biometric, or similar information, for example: Call recordings when you talk to customer service Voice identification, when you consent to this biometric method of authentication Profile pictures you provide Photo IDs you voluntarily provide to authenticate your account, which we delete immediately upon authentication. 8. Professional or employment information, for example: Business information, contact emails and phone numbers Tax IDs 9. Information we infer based on your personal information, for example: Fraud and risk assessments Personalization preferences Personal information How we collect personal information about you We may collect personal information about you from various sources, for example from: You, when you use PayPal or another PayPal service, such as Xoom, Hyperwallet, or Venmo Merchants Our payment partners, such as card networks and payment processors Financial institutions, such as banks Credit bureaus Service providers, such as companies that help us manage risk and fraud, deliver services to you, and market our services If you have an account with PayPal, we will associate information from all these sources with your account to improve your experience and for compliance and analytics purposes. We do not knowingly collect personal information from people who are not allowed to use our sites and services, such as children under the age of 13 or pursuant to the applicable user agreements. Contact us if you believe that we’ve mistakenly collected personal information from someone not allowed to use our services. We’ll delete it immediately, unless we’re legally required to keep it. How we use tracking technologies like cookies We or our authorized service providers may use cookies and similar tracking technologies to collect personal information whenever you use our services, visit our sites, or visit websites that offer our services. The information collected with these technologies helps us personalize your experience, measure the effect of our ads, prevent fraud, and enhance the security of our sites and service. You can disable or decline some cookies for our sites and services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use. Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings. If you want to know more about how we use cookies, read our Cookie Statement. To learn how to opt-out of this kind of tracking technology, visit About Ads. Why we collect personal information We collect personal information for many reasons, including to improve your experience, and to run our business. Specific reasons why we collect your personal information include: Run our sites and provide better services, for example to help you send or request money, send payouts, make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date. Manage and improve our business. For example, we do user research to improve our products’ performance and abilities. We also monitor and analyze our sites to help ensure they work as expected. Protect our business and our customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and merchants. Send you marketing information about our products and services. We may use personal information to market about our partners, such as merchants. We use personal information to better understand and cater to your interests. Personalize your experience when you use our sites and services, as well as other third-party sites and services. In this case, we might use tracking technologies like cookies. See our Cookie Statement for more details. Send you locally relevant options, but only if you agree to let us track your location. If you do, this can help us enhance the security of our sites and services, and customize our services by using the right language and personalizing content such as ads and search results. Make it easy for you to find and connect with others. For instance, if you let us access your contacts, we can suggest connections with people you may know. Contact you when you need us, such as answering a question you sent to our customer service team. Comply with laws and enforce our agreements with you and other people who use our services. If you choose to receive a digital receipt via email or text when completing a payment in-store, we’ll remember your choice the next time you check-out with the same payment card. How and why we share personal information about you We do not sell your personal information. However, we may share personal information across our services and with other members of the PayPal corporate family, including with Honey to manage our Rewards program. Sometimes we share the personal information we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations. You can review the personal information that we may share by reviewing The personal information we collect section. We may share personal information with: Other members of the PayPal corporate family, including our brands such as Venmo, Honey, Happy Returns, Chargehound, and Hyperwallet. For example, we share data with Honey to manage our Rewards program. Service providers that help us with processing payments, marketing, research, compliance, audits, corporate governance, communications, and security Card networks and payment processors Financial institutions, such as banks we partner with to offer joint products, like Synchrony Bank in connection with PayPal Credit, PayPal Savings, the PayPal Cashback Mastercard, and the PayPal Extras Mastercard Credit reporting and collections agencies Courts, governments, regulators, and law enforcement when accompanied by a subpoena or other legal documentation that requires PayPal or members of our corporate family to respond People involved in a transaction, such as other users or merchants and their service providers. Third parties that you asked us to connect with, such as other financial or social media apps. If you want us to stop sharing information with a third party, disconnect your account from that third party. Third-party tools used to help fight spam and abuse. For instance, we use ReCaptcha to help determine whether you’re a person or a computer. When you use ReCaptcha, your personal information is subject to Google’s Privacy Policy and Terms of Use. Other third parties to: Comply with laws Investigate or enforce violations of our user agreement Facilitate a merger, purchase, or sale of part or all of our business Comply with card association rules To prevent physical harm or illegal activity How we protect your personal information Helping to keep your personal information safe against loss, misuse, unauthorized access, disclosure, and alteration is our top priority. To protect your personal information, we use technical, physical, and administrative security measures that include: Firewalls Data encryption Physical access controls at our data centers While we protect our systems and services, you’re responsible for keeping your password(s) and account information private. You are also responsible for making sure your personal information is accurate and up to date. If your account is closed, we may keep your personal information and other information as required by law and according to our data retention policy. If we do, we’ll continue to handle it as we describe in this statement. How this statement changes over time We’ll make changes to this privacy statement from time to time. This helps us stay up to date with changes to our business and the most current laws. After a new version is published, we’ll collect, store, use, and protect your personal information as we outline in that revised statement. If the new version reduces your rights or increases your responsibilities, we’ll post it on the Policy Updates or Privacy Statement page of our website at least 21 days before it becomes effective. We may notify you about these changes through email or other communications. Contact Us If you have questions about this privacy statement or your personal information, contact us so we can help. To talk about your PayPal account: Call PayPal Customer Service at 1-888-221-1161 or visit our Customer Service web portal To talk about your Xoom account: Call Xoom Customer Service at 1-877-815-1531 or visit our Help Center web portal To talk about your Hyperwallet account: Call Hyperwallet Customer Service at 1-877-546-8220 or send an email to [email protected] Consumer Privacy Notice Last update: March 21, 2022 FACTS WHAT DOES PAYPAL DO WITH YOUR PERSONAL INFORMATION? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and account balances Payment history or transaction history Credit history or credit scores When you are no longer our customer, we continue to share your information as described in this notice. How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons PayPal chooses to share; and whether you can limit this sharing. This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses PayPal sites or services for your own personal, family, or household purposes. This Consumer Privacy Notice does not apply to PayPal card processing products such as Braintree or Pro VT. Reasons we can share your personal information Does PayPal share? Can you limit this sharing? For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes – to offer our products and services to you Yes No For joint marketing with other financial companies Yes No For our affiliates’ everyday business purposes – information about your transactions and experiences Yes No For our affiliates’ everyday business purposes – information about your creditworthiness No We don’t share For our affiliates to market to you No We don’t share For nonaffiliates to market to you No We don’t share Questions? Call our customer service at 1-888-221-1161or visit us at https://www.paypal.com/us/smarthelp/contact-us?email=privacy. Who we are Who is providing this Privacy Statement? This privacy notice is provided by PayPal, Inc. and is applicable to your personal U.S. PayPal and/or Xoom accounts. What we do How does PayPal protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. How does PayPal collect my personal information? We collect your personal information, for example, when you open an account or provide account information use your credit or debit card or give us your contact information use your PayPal and/or Xoom account to send or receive funds We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. Why can’t I limit all sharing? Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes — information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law. Definitions Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Bill Me Later, Inc. Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf. Joint Marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial companies and banks, such as Synchrony Bank. Other important information We may transfer personal information to other countries, for example, for customer service or to process transactions. California: The California Consumer Act of 2018 (CCPA) permits consumers who are California residents to ask businesses covered under the act about personal information it has collected about the consumer, submit an access or deletion request, and opt-out of the sale of personal information, if applicable. These provisions do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law such as the Gramm-Leach-Bliley Act. Contact us if you have questions about our privacy statement, this consumer notice, or your personal information. If your PayPal account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law. To talk about your PayPal account, call PayPal Customer Service at 1-888-221-1161 or visit our Customer Service web portal. To talk about your Xoom account, call Xoom Customer Service at 1-877-815-1531 or visit our Help Center web portal. Vermont: If your PayPal account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization. Nevada: If your PayPal account has a Nevada mailing address, we are providing this notice pursuant to Nevada law. If you prefer not to receive marketing calls from PayPal, you may be placed on our internal Do Not Call List by calling 1-888-221-1161 or going to https://www.paypal.com/selfhelp/home. For more information, you can contact PayPal at 12312 Port Grace Blvd, La Vista, NE 68128 or you can contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: 1-702-486-3132; email: [email protected].
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Develop and display personalized and relevant advertising content for our users
- Analyze how our Services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights, you may email us at [email protected].
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | NO |
B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | NO |
C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
E. Biometric information | Fingerprints and voiceprints | NO |
F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
G. Geolocation data | Device location | NO |
H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
J. Education Information | Student records and directory information | NO |
K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
Milli Estates LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Milli Estates LLC will not sell personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at [email protected] or by post to:
Milli Estates LLC
202 government st
mobile, AL 36602
United States
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by clicking here.
This privacy policy was created using Termly's Privacy Policy Generator.