Privacy Policy

This privacy policy (the “Privacy Policy”) explains the collection, use, and disclosure practices of the websites, mobile applications, and other online and offline products and services (collectively, the “Services”) owned and operated by Milestones Labs, Inc. (“Milestones,” “we,” “us,” or “our”). This Privacy Policy also describes how we collect and use information when you access and use our websites (the “Site”). Please be advised that the practices described in this Privacy Policy also apply to information that you submit to us offline and to Personal Information (as described below) that we may collect from third parties. By using our Site or submitting information to us, you acknowledge and understand the terms of our Privacy Policy. Furthermore, if you provide us with your telephone number, including on our Site or over the telephone, you agree to be contacted by us to explore options relating to our Services. You agree to be contacted by telephone call or text message at the telephone number you provided using automatic telephone dialing systems, even if you previously registered on a Do Not Call registry.

COLLECTION & USE OF YOUR PERSONAL INFORMATION
As used in this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, reasonably can be linked, directly or indirectly, with an individual or household, or as otherwise defined under applicable law.
We collect Personal Information from various sources including directly from you, automatically from the use of our Services, from affiliated and unaffiliated third parties, and by using the information we collect to derive new Personal Information. The types of Personal Information we collect about you depend on your interactions with us and are described in more detail below.

Information We Collect Directly from You. We collect information directly from you in a variety of ways. Any information you provide to us is voluntary, but please note that some information may be necessary for us to provide you with our Services. The categories of Personal Information we collect directly from you include:

Identifiers, such as your property address and property-related information, first name, last name, phone number, email address, and mailing address;
Information you provide on our Site to request Services, for example, your username, password, location, zip/postal code, mailing address, fax number, and email address;
Any financial information;
Feedback you provide to us about our Services, including in response to surveys or through our customer service centers.

Information Automatically Collected from Your Use of the Site. We may automatically collect information about you from your use of our Services, including by using website analytics tools or other technologies, like cookies and web beacons (which are described in more detail below).

The categories and types of information we collect automatically from your use of the Services include:
Identifiers, such as your IP address and unique device identifiers;
Internet or other electronic network activity information, such as the type of browser you use, app version, access dates and times, pages viewed, and the page you visited before navigating to our Site;
Geolocation data;
Other information that relates to or is capable of being associated with you, such as information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, and mobile network information.

Cookies are small text files that are stored on your computer when you visit certain online pages that record your preferences. We use cookies to track use of our Site and other Services. We may also use cookies to monitor traffic, improve the Site, make the Site easier and/or relevant for your use, and improve the performance of our advertising on other websites. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. However, certain features of our Site or other Services may not work if you delete or disable cookies.

INFORMATION WE COLLECT FROM OTHER SOURCES
We may collect information about you from other sources. For example, we may collect information about you from:

Third-party social media services, such as Facebook, Twitter, and Instagram, that you use to interact with our Services (e.g., to provide feedback on our Services) or that allow you to share information (e.g., via plugins, widgets, or other tools);
Unaffiliated parties, such as our service providers, analytics companies, advertising networks, affiliates, and other third parties that provide us with information, so we can better understand you and provide you with information that may be of interest to you.

INFORMATION SHARED WITH COLLABORATORS
We provide online workspaces, or “hubs”, for you to access and share information, interact with resources and tools, and communicate with industry professionals. Each hub is private and secure, accessible via login and password. Individuals with access to each hub are collectively referred to as “hub members”. By joining a hub, you acknowledge that information contained therein may be accessible to other hub members – including files, property information, transaction history, written communication, professional services, and other personal information. By inviting others to join a hub, you acknowledge that you are opting to share information within the hub with them.

USE OF YOUR INFORMATION
For each category of Personal Information we collect about you, we use such category of Personal Information for the business and commercial purposes set forth below:

To provide you the Services and otherwise complete the transactions you request, perform our contractual obligations, and as otherwise anticipated within the context of our ongoing business relationship;
Create and manage your online accounts;
Communicate with you, including by telephone, text, email, and chat, regarding your use of the Services;
Respond to your requests and any other communications from you, including providing customer service;
Send advertising or marketing communications about products, services, offers, promotions, rewards, and events offered by us and provide news and information that we believe may be of interest to you;
Offer and administer surveys, contests, prize draws, sweepstakes, and other promotions;
Conduct internal research and development;
Analyze your engagement with us and your use of our Services to better understand your interests and behaviors and customize your experience;
Detect security incidents and protect against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, and breach of contract, and to protect against harm to the rights, property, or safety of us and our users, customers, employees, or the public;
Debug, identify, and repair errors that impair the functionality of our Services;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our business;
Comply with our legal obligations, including our tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law or any regulatory requirements or provisions; and
With our legal, financial, insurance, and other advisors in connection with the kinds of transactions described above or in connection with the management of all or part of our business or operations.

DISCLOSURE OF PERSONAL INFORMATION
We will share your Personal Information as follows:

To Our Service Providers. We may share Personal Information with one or more service providers with which we have contracted to provide services to us or to offer the Services you have requested from us.
To Affiliated Companies. We may share your Personal Information with other companies under common control with us.
For Our Internal Analyses and Operations. We may share Personal Information with third-party vendors for our own internal statistical, design, or operational purposes, such as estimating our audience size, measuring aggregate traffic patterns, and understanding demographic trends among our users. The use and disclosure of your Personal Information by these other parties is restricted to the performance of such tasks and is subject to confidentiality.
For Legal and Other Compliance. We may share Personal Information when we believe it is appropriate for the following purposes (a) to comply with legal process or applicable law; (b) to enforce or apply this Privacy Policy or our other policies or agreements; (c) protect the rights, property, or safety of ourselves, our users, and the public; (d) to protect our users from fraudulent, abusive, or unlawful use of our Site; (e) to enable us to detect or prevent fraud, material misrepresentation, or criminal activity; (f) to law enforcement or authorities in conjunction with an investigation, or in response to a subpoena or court order; or (g) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
As Part of Business Transfers. We may share Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction.
As Aggregated, Anonymized Information. We may share aggregated, anonymous, or de-identified information to our advertisers, business partners, and other third parties that cannot reasonably be used by those third parties to identify you.
To Third Parties With Your Authorization. We may disclose your information to third parties for whom you have given us authorization or consent to make such disclosure.

LINKS TO THIRD PARTIES
We may provide links to third-party websites from our Site as a service to our users. We have no ability to control nor are we responsible for the privacy and data collection, use, and disclosure practices of any third-party websites, including those we may link to from our Site. When you click on links that take you to external websites, you will be subject to their privacy policies and practices and not ours. We strongly encourage you to review and understand the privacy policies and terms of use of any website that you visit.

SECURITY
We maintain security measures to protect your Personal Information while it is in our possession. Please note, however, that no transmission of data over the Internet is 100% secure.

RECORDED TELEPHONE COMMUNICATIONS
Telephone communications between us may be recorded or monitored for quality control purposes. By providing information to us, you expressly consent to the recording of these telephone communications.

CHILDREN
Our Services are designed for adults, not children under the age of 16. As such, we do not intend to collect Personal Information from children under the age of 16, and our Services are not designed for such information.

CONTROLLING YOUR PERSONAL INFORMATION
You have the right to submit a complaint or to object to the collection and use of your information by us at any time or to require us to review, transmit, change, or delete your information that we have collected and retained. We will respond to your request to exercise any of these rights after receiving a complete request, with the exception of information that is needed to complete the transaction for which the Personal Information was collected, to provide the information you have requested from us, as allowed or authorized by law, or that is reasonably anticipated within the context of our ongoing business relationship with you. You can exercise these rights by contacting us at:

Email: privacy@milestones.ai

Mailing Address: Milestones Labs, Inc. 925 Capital of Tx Hwy, Bldg. A, Suite 100, Austin, TX 78746

PRIVACY NOTICE FOR CALIFORNIA CONSUMERS
This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. This California Privacy Notice is part of the Privacy Policy, and it may be updated on the same terms and in the same manner as the Privacy Policy. If you have any questions about the California Privacy Notice, please contact us using the contact information set forth in the Privacy Policy.

Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Personal information does not include:

1. Publicly available information from government records.
2. Deidentified or aggregated consumer information.
3. Information excluded from the CCPA’s scope, like:
   1. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
   2. Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

1. 1. 1. Directly from you. For example, from forms you complete, or products and services you purchase.
      2. Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:

1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
2. To provide, support, personalize, and develop our Website, products, and services.
3. To create, maintain, customize, and secure your account with us.
4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
5. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
6. To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
7. To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
8. For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
9. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
10. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
11. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties from selling personal information we hold unless you have received explicit notice and an opportunity to opt out.

We share your personal information with the following categories of third parties:

1. Service providers.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have not disclosed personal information for a business purpose.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights, below), we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting.
4. The categories of third parties with whom we share that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
   1. 1. Sales, identifying the personal information categories that each category of recipient purchased; and
      2. Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    

   Exercising Access, Data Portability, and Deletion Rights
   To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

1. Emailing us at privacy@milestones.ai
2. Calling us at (512) 399-9230

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights, below.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Rights
We do not sell personal information. If you feel your information has been compromised, please contact us at privacy@milestones.ai.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

When you receive a newsletter or other promotional communications from us, you may indicate a preference to stop receiving further newsletters and other promotional communications by following the opt-out instructions included in the communications.

WEB CONTENT ACCESSIBILITY COMPLIANCE STATEMENT
Milestones Labs, Inc. and its subsidiaries are committed to facilitating the accessibility and usability of all of its websites for all our customers, including people with disabilities. We strive to meet the standards of the World Wide Web Consortium’s Web Content Accessibility Guidelines 2.1 Level AA (WCAG 2.1 AA). Our efforts are ongoing as technology advances.

If at any time you have specific questions or concerns about the accessibility of any particular web page, please contact us at support@milestones.ai. Please be sure to specify the issue, the web site and the web page in your email, and we will make all reasonable efforts to make that page accessible for you.

CHANGES IN THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

GOVERNING LAW
We attempt to comply with local data protection, privacy, and consumer rights laws to the extent they may apply to our services. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your Personal Information to the Site.

QUESTIONS AND CONCERNS
If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@milestones.ai

CCPA Requests? Follow This Link.