Mili - Privacy Policy

PRIVACY POLICY

Last Updated: 16 July, 2024

WE WILL POST ANY CHANGES TO THIS PRIVACY POLICY IN A NOTICE OF THE CHANGE AT THE BOTTOM OF OUR WEB PAGE WITH A HYPERLINK THERETO. PLEASE REGULARLY REVIEW THIS PRIVACY POLICY. NOTWITHSTANDING IF YOU CONTINUE TO USE OUR SERVICES, YOU ARE BOUND BY ANY CHANGES THAT WE MAKE TO THIS PRIVACY POLICY.

1. INTRODUCTION

Mili Software, Inc. (“Mili,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Mili Platform (the “Platform”) through Mili’s website at https://www.getmili.ai/ (the “Website”) or Mili’s mobile application (the “App”). Mili is a platform that provides AI-driven personal assistant services designed to help users manage their daily tasks, schedules, and communications more efficiently. It integrates with various applications and devices to streamline workflows, automate routine tasks, and provide personalized recommendations based on user preferences and behavior. By leveraging advanced AI technology, Mili aims to enhance productivity and simplify the management of personal and professional responsibilities.

Mili is committed to protecting the privacy of its Users whose information is collected and stored while using Mili’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.

The capitalized terms have the same meaning as ascribed in our Terms of Use, unless otherwise noted here.

By using the Mili Platform, you acknowledge and agree that you are responsible for obtaining all necessary consent from individuals whose personal information you may access, collect, or share through the use of the Platform. You must ensure that such individuals are aware of and agree to the practices described in this Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@GETMILI.AI.

WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO.

The capitalized terms have the same meaning as ascribed in our Terms of Use, unless otherwise noted here.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@GETMILI.AI.

WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO.

2. WHAT INFORMATION DO WE COLLECT?

When you register to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact

information such as your email address or username, phone number, and other personal information. The information so collected will be stored on our servers. This personal information is not referring to the personal information of your clients or concerned parties whose information your may store via the services provided by Mili. You are able to change your personal information via email by contacting us at privacy@getmili.ai or through your profile or account settings on our Website, App, or Platform.

a. Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details.

b. Financial Information. We currently do not collect or store any credit cards or bank information, as we are using a third-party payment processor. However, we will update this Privacy Policy when we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.

3. HOW DO WE COLLECT INFORMATION?

We collect personal information from you in the following ways:

a. At registration on our Website, App, or Platform;

b. In email, text, and other electronic messages between you and our Website, App, or Platform;

c. Through mobile and desktop applications, your downloads from our Website, App, or Platform, which provides dedicated non-browser-based interaction between you and our Website, App, or Platform;

d. When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;

e. From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform;

f. When you subscribe to a newsletter;

g. From your responses to a survey;

h. From forms filled out by you;

i. From records or copies of correspondences (including email addresses) if you contact us;

j. From search queries on our Website, App, or Platform; and

k. When you post information to be published or displayed on our Website, App, or Platform.

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

a. Usage details;

b. IP addresses;

c. Information obtained through browser cookies;

d. Information obtained through flash cookies;

e. Web beacons on our Website;

f. Web beacons on emails sent by us; and

g. Other tracking technologies.

User Responsibility for Obtaining Consent

It is the responsibility of the User to ensure that any collection, use, and sharing of personal information through the Mili Platform complies with applicable privacy laws and regulations. Users must obtain explicit consent from individuals before collecting or sharing their personal information through the Platform. Mili is not responsible for any misuse of personal information by Users.

We collect personal information from you in the following ways:

a. At registration on our Website, App, or Platform;

b. In email, text, and other electronic messages between you and our Website, App, or Platform;

c. Through mobile and desktop applications, your downloads from our Website, App, or Platform, which provides dedicated non-browser-based interaction between you and our Website, App, or Platform;

d. When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;

e. From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform;

f. When you subscribe to a newsletter;

g. From your responses to a survey;

h. From forms filled out by you;

i. From records or copies of correspondences (including email addresses) if you contact us;

j. From search queries on our Website, App, or Platform; and

k. When you post information to be published or displayed on our Website, App, or Platform.

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

a. Usage details;

b. IP addresses;

c. Information obtained through browser cookies;

d. Information obtained through flash cookies;

e. Web beacons on our Website;

f. Web beacons on emails sent by us; and

g. Other tracking technologies.

User Responsibility for Obtaining Consent

4. HOW DO WE USE YOUR INFORMATION?

We use the information that you provide to:

a. Personalize your experience in using our Platform;

b. Provide you with information, products, or services requested from us;

c. Present our Website, App, and Platform and their contents to you;

d. Provide you with notices about account and/or subscription, including expiration and renewal notices;

e. Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;

f. Notify you about changes to our Website, App, and Platform and any products or services; g. Allow you to participate in interactive features on our Website, App, and Platform; h. Improve the Website, App, and Platform;

i. Improve our customer service;

j. Administer contests, promotions, and surveys or other Website, App, and Platform features; k. Process transactions;

l. Anonymize data and aggregate data for statistics;

m. Contact you for other purposes with your consent;

n. Contact you about our products and services that may be of interest;

o. Contact you about third parties’ goods and services;

p. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent; and

q. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 14, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.

We use the information that you provide to:

a. Personalize your experience in using our Platform;

b. Provide you with information, products, or services requested from us;

c. Present our Website, App, and Platform and their contents to you;

d. Provide you with notices about account and/or subscription, including expiration and renewal notices;

e. Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;

i. Improve our customer service;

j. Administer contests, promotions, and surveys or other Website, App, and Platform features; k. Process transactions;

l. Anonymize data and aggregate data for statistics;

m. Contact you for other purposes with your consent;

n. Contact you about our products and services that may be of interest;

o. Contact you about third parties’ goods and services;

p. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent; and

5. OUR COOKIE POLICY

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”

We use Cookies on our Website and App to (a) help remember and process items in the shopping cart, (b) understand and save your preferences for future visits, (c) keep track of advertisements, (d) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (e) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.

We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites. Please contact us at privacy@getmili.ai.

6. HOW DO WE PROTECT INFORMATION WE COLLECT?

Our Website and App are reasonably scanned to meet or exceed PCI Compliance. Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third party credit card processor on our behalf. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.

7. DATA SECURITY MEASURES

a. Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.

b. Fair Information Practice Principles. In the event of a personal data breach, we will notify you within fifteen (15) days via (i) email and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

c. Open-Source Software: We use the following open-source software in the provision of our Services, which can be found here.

d. User Responsibility for Security. While Mili implements reasonable security measures to protect personal information, Users are also responsible for maintaining the security of any personal information they collect and share through the Platform. Users must ensure that their use of the Platform complies with all applicable data protection and privacy laws, including obtaining necessary consents and providing appropriate notifications to individuals.

c. Open-Source Software: We use the following open-source software in the provision of our Services, which can be found here.

8. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us may be shared by Mili with others to enable us to provide you over Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Mili may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:

Disclosure of Personal Information.

a. We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
b. We may disclose personal information to our subsidiaries and affiliates.

c. We may disclose personal information to contractors, services providers, and other third parties.
d. We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.

e. We may disclose personal information in the event of a merger, sale of business, etc.
f. We may disclose to third parties to market their products and services to you if you have either consented or not opted out of these disclosures.

g. We may disclose personal information to third parties to market their products and services if you have either consented or not opted out of these disclosures.

h. We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.

i. We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.
j. We may disclose personal information for any other purpose for which you have provided it.
k. We may only disclose personal information as described in this Privacy Policy or your consent.

User Obligations for Third-Party Information

Users are solely responsible for ensuring that they have obtained necessary consents from any third parties whose personal information they may disclose to Mili or through the Platform. Users must provide such third parties with a copy of this Privacy Policy and inform them of their rights regarding their personal information.

Other Disclosure of Personal Information

a. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Mili, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Mili, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third Party Disclosure

a. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

b. We do not provide non-personally identifiable visitor information for marketing purposes.

Choices Users Have About How Mili Uses and Discloses Information

a. Tracking Technologies and Advertising. You can set their browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or function properly.

b. Disclosure of Users’ Information for Third-Party Advertising. Users can opt-out by (i) checking the relevant form when we collect the data; (ii) logging into the Website, App, or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at privacy@getmili.ai. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Mili for product purchases, warranty registration, or other transactions.

c. Disclosure of User’s Information for Targeted Advertising. Users can opt-out by (i) checking the relevant form when we collect the data, (ii) logging into the Website, App, or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at privacy@getmili.ai.

Disclosure of Personal Information.

g. We may disclose personal information to third parties to market their products and services if you have either consented or not opted out of these disclosures.

User Obligations for Third-Party Information

Other Disclosure of Personal Information

Third Party Disclosure

b. We do not provide non-personally identifiable visitor information for marketing purposes.

Choices Users Have About How Mili Uses and Discloses Information

9. GOOGLE ADSENSE AND GOOGLE ANALYTICS

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google partners.

We have implemented advertising features on our Website, App, and Platform including: (a) remarketing with Google AdSense; (b) Google Display Network Impression Reporting; (c) Google Demographics and Interests Reporting; and (d) Google’s DoubleClick platform integration.

We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App.

10. FOR OUR EUROPEAN CUSTOMERS AND VISITORS

We are headquartered in the United States. Most of the operations are located in the United States. Your Personal Information, which you give to us during registration or use of our Website, App or Platform, may be accessed by or transferred to us in the United States. If you are visiting our Web site or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.

● If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).

● Please note that in some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.

● In such situations, however, we will still respond to let you know of our decision.

● As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.

a. EU Standard Contractual Clauses.

On June 4, 2021, the EU promulgated a new set of SCCs (the “New SCCs”), which replaced the old SCCs which had been in place for over a decade. We now comply with the New SCCs with respect to the transfer of Personal Data from the EU to the US and other countries for Processing, as defined in the GDPR. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the New SCCs, the terms and conditions in the new SCCs will govern.

b. The New SCCs.

● The New SCCs took effect on June 27, 2021.

● The Old SCCs may still be used for new data transfers in new contracts during a three-month transition period that ends on September 27, 2021.

● Existing data transfers contracts that rely on the Old SCCs can be used until December 27, 2022, by which time all data transfers relying on the Old SCCs must be transitioned to the New SCCs.

● As of now, we and our customers are using the New SCCs to transport Personal Data from the EU to other countries including the US for processing by us.

● You are the Controller, as defined in the GDPR, and the Exporter, as defined in the New SCCs, of the Personal Data and we are a processor, as defined in the GDPR, and the Importer of such Personal Data.

● You agree to comply with the GDPR rules that apply to Controllers and the New SCCs rules that apply to Data Exporters. We agree to comply with the GDPR rules that apply to Processors and the New SCCs rules that apply to Data Importers.

c. Our GDPR Compliance Commitment.

● We agree to fully comply with the letter and the spirit of the GDPR and the New SCCs with respect to the transfer or your Personal Data for Processing outside the EU.

● As a Data Importer, a User may contact us as set forth in Subsection 9(d) below with respect to the Personal Data we store and process on you.

● We hereby notify you that we will be processing, as defined in the GDPR, the Personal Data of your Authorized Users (i.e., those individuals whom you have authorized to access our Platform and to use our Services) in the US, Canada, and Turkey for us to be able to provide the Services to you that we have agreed to do in our definitive service agreement between you and us.

● Upon request, we will provide you with a list of your Personal Data that we will process and a copy of the New SCCs under which we will transport your Personal Data for processing.

● We hereby warrant that, at the time of agreeing to the SCCs for the transport of your Personal Data, we have no reason to believe that the laws and practices applicable to us as a data processor and a data importer, including those of the US, Canada, and Turkey are not in line with the requirements of the New SCCs.

● If we cannot satisfy any request or dispute to your satisfaction, we will agree to arbitrate or litigate the dispute in the EU jurisdiction in which your reside.

● We will only transfer your Personal Data to a third country in accordance with documented instructions from you.

● Your Personal Data will be transferred and stored in an encryption format.

● Only our employees, who have a need to access your Personal Data to enable us to meet our contractual and legal obligations to you, will be given access to your Personal Data.

● Such employees will be given a User Name and Password to access your Personal Data.

● We will keep an automated record of all persons who have accessed your Personal Data.

d. Rights of Data Subjects.

To make any of the following requests, with respect to this Privacy Policy, our Terms or Use, and/or Personal Data, please contact us (i) via email at privacy@getmili.ai, or (ii) by writing to us at Mili, 108 W. 13th Street, Suite 100, Wilmington, DE 19801.

i. Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.

ii. Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.

iii. Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.

iv. Erasure: You can request that we erase some or all of your Personal Information from our systems. v. Restriction of Processing: You can ask us to restrict further processing of your Personal Information.

vi. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible. vii. Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.

viii. Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection authorities/index_en.htm to locate your Data Protection Authority in the EU. You may contact the UK’s Information Commissioner at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

ix. We will respond to your inquiry within thirty (30) days of the receipt.