MYTONOMY PRIVACY POLICY

LAST UPDATED: January 1, 2024

Mytonomy wants you to be familiar with how we collect, use and disclose, and otherwise process personal information in connection with our services.

PERSONAL INFORMATION

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or anonymized information that is maintained in a form that is not capable of being associated with or reasonably linked to you. That can include the following:

• Name
• Telephone/cell phone number
• Email address
• User ID
• Social media account ID
• Demographic information, such as your gender, race, ethnicity.

If you are an employee using the Services at the direction of your employer, we also collect employment-related information, including the name of your employer and your title.

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

Through the Services

• Contact Information. We collect Personal Information through the Services, for example, we may collect your name, email address, postal address, telephone number, account ID, user ID, and password when you register an account to access the Services and/or when you use the Services.
• Job Applicant Information. When you apply for a job with us, we may receive information such as current and past employer, job titles, and any other Personal Information you include in documents such as your resume. We use this information for hiring practices, in compliance with applicable laws and regulations.
• Demographic Information. We may collect information such as your gender, marital status, and employment status when you complete one of our surveys or update your account profile information. We use this information to measure our performance and improve our products, services and customer experience.

• From Other Sources

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.

We receive the same categories of Personal Information as described above from the following sources and third parties:

• Social Networks. When you interact with us through a social media site or third party service, such as when you like, follow or share Mytonomy content on LinkedIn, Facebook, Twitter, Instagram or other sites, we may receive information from the social network including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. The data we receive from these third party sites is dependent upon that third party’s policies and your privacy settings on that third party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Services. 

• Publicly Available Sources. We collect Personal Information about you that we do not otherwise have, including contact information, employment related information and product interest information, from publicly available sources. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials or to personalize our Service, to pre-populate online forms, and to better understand the demographics of our users.

• Personal Information Automatically Collected

As is true of most digital platforms, we collect certain personal information automatically when you visit our online services, including:

• Geolocation Information. We approximate your location by your IP Address. This data is collected, processed, and stored in order to provide personalized content and advertising, to assist us with analytics, and to improve the effectiveness of our websites, branches, mobile applications, merchandise, advertising, and customer service.
• Log Files. We record certain information in a log file every time your browser or user-agent requests any information from our server, such as your device's operating system, application software, Internet Protocol (IP) address, access times, crash reports, browser type and language, peripherals, user log data, Active Directory information, and the websites you visited before and after our online Services. We use this information to operate, maintain, test, enhance, update, monitor, diagnose, fix and improve our services and products.
• Analytics Data. We collect information about how you use our Services, including the electronic path taken to our services, through our services and when exiting our services, as well as usage and activity on our services, such as the links and content individuals view or engage with.

For information about our and our third-party providers’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please visit our Cookie Notice [link].

Use of Personal Information

We and our service providers use Personal Information for business purposes including:

• Providing the functionality of the Services and fulfilling your requests.
  • To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
  • To respond to your inquiries and fulfill your requests when you send us questions, suggestions, compliments or complaints.
  • To send administrative information to you, such as changes to our terms, conditions and policies.
  • To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials.
  • For marketing and advertising purposes, including sending you marketing related emails, with information about our services, new products, and other news about Mytonomy.
• Analysis of Personal Information for business reporting and providing personalized services.
  • To better understand you, so that we can provide you with personalized content.
  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
• Accomplishing our business purposes.
  • For data analysis, for example, to improve our Services.
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • For developing new products and services.
  • For enhancing, improving, or modifying our current products and services.
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Disclosure of Personal Information

We disclose Personal Information in the following ways:

• Service providers. We share Personal Information with third-party vendors, and other service providers who perform functions or services on our behalf and under our instructions to make our Services available to you. These can include providers of services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• Ad Networks and Advertising Partners. We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see our Cookie Notice [link] for more information.
• Business Transaction or Reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership. You will be notified by email and/or a prominent notice on any affected online service of any change in ownership, as well as any choices you may have regarding your personal information as a result of the transaction.
• Legal Obligations and Rights.  We may disclose personal information to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us;
  • to protect the safety and that of our customers, or any person; or
  • as otherwise required by applicable law.
• Consent.  We may disclose personal information about you to certain other third parties with your consent.

CHOICES AND CONTROL OVER PERSONAL INFORMATION

Your choices regarding SMS Text Communications

We may use personal data we collect to communicate with individuals via text message and telephone calls, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. Text messages may be sent using an automatic telephone dialing system or other technology. You can unsubscribe from marketing text messages at any time by replying STOP or UNSUBSCRIBE to the text message. For more information, please see our Terms of Service.

How you can change or delete your Personal Information

If you would like to request to change or delete Personal Information, object to the processing of Personal Information, you may contact us by emailing us at privacy@mytonomy.com. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to update, or whether you would like to have your Personal Information deleted from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to fulfill our legal obligations.

How You Can Opt Out of Emails

An individual can stop receiving promotional email communications from us at any time by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. Individuals may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the service, technical and security notices).

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

CHILDREN’S PERSONAL INFORMATION

Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If we discover that a child under the age of 13 has provided us with personally identifiable information and we do not have parental consent, we will promptly delete that child’s information from the Website and Service. If you believe that Mytonomy has been provided with Personal Information of a child under the age of 13 without parental consent, please notify us immediately at privacy@mytonomy.com.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominently posting on our services, or through other appropriate communication channels. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

Mytonomy Inc., located at 4550 Montgomery Ave, Suite 200N, Bethesda, MD 20814, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at privacy@mytonomy.com or:

4550 Montgomery Ave, Suite 200N, Bethesda, MD 20814

Because email communications are not always secure, please do not include sensitive information in your emails to us.

MYTONOMY COOKIE NOTICE

Last Updated]: November 1, 2023

Unless otherwise expressly stated, capitalized terms in this Notice have the same meaning as defined in the Privacy Policy. 

Scope of Notice

This Cookie Notice supplements the information contained in the Privacy Policy by explaining how we and our business partners and services providers use cookies and related technologies in the course of managing and providing our online services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Policy.

What Are Cookies and Related Technologies

Cookies are small data files that are stored on your computer that allow us and our third-party partners and providers to collect certain information about your interactions with our email communications, websites and other online services.  We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

Types of Cookies We Use

Strictly necessary cookies. These are cookies that are required for the essential operation of the Service such as to authenticate users and prevent fraudulent use.

Analytical/performance cookies. They allow us to recognize and count the number of users and to see how users move around the Service. This helps us to improve the way the Service works, for example, by ensuring that users are finding what they are looking for easily. The service providers that we use to help us do this may enable us to set cookies on your device in order to collect information about your use of the Service. For instance, we may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users.

Functionality cookies. These are used to recognize you when you return to the Service. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region). We use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps Privacy Policy to learn more).

Targeting cookies. These cookies record your visit to the Service, the pages you have visited and the links you have followed. We will use this information to make the Service and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on the Service. These third parties are responsible for setting out their own cookie and privacy policies.

What We Collect When Using Cookies

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, websites and other online services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services and better understand our customer base.

Third-party partners and providers may also collect personal information about your online activities over time and across different websites when you use our websites and online services.

How We Use That Information

All the information collected automatically through these tools allows us to improve your customer experience. We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online services; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d)provide and monitor the effectiveness of our websites and online services; (e) monitor online usage and activities of our websites and online services; (f) diagnose errors and problems with our websites and online services; (g) otherwise plan for and enhance our online services; and (f) facilitate the purposes identified in the Use of Personal Information section of our Privacy Policy.  Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Policy.

Your Choices About Cookies

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online services, as some features and services on our online services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

To understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookie settings in Safari web and iOS.

You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy here.  You can also view Google’s currently available opt-out options here.

To learn more about Facebook’s practices, visit their cookies policy here.