MYTONOMY PRIVACY POLICY

Last Update: October 14, 2019

Mytonomy wants you to be familiar with how we collect, use and disclose, and otherwise process personal 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.

• Employment 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

• 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 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 collect information about your location with varying degrees of accuracy through GPS/GNSS, WiFi, Bluetooth Low Energy, wireless network triangulation or other methods in order to obtain your location for the purposes of providing our services. We may also approximate your location by your IP Address. This data is collected, processed, and stored in order to provide personalized content and advertising, to enhance your shopping experience, to assist us with analytics such as foot traffic measurement, 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.

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.

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.
  • To send you marketing related emails, with information about our services, new products and other news about Mytonomy.

We will engage in this activity with your consent or where we have a legitimate interest.

• 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.

We will provide personalized services either with your consent or because we have a legitimate interest.

• 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.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

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.
• 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 our safety and that of our customers, or any person; or
  • as otherwise required by applicable law.
• We may disclose personal information about you to certain other third parties with your consent.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

If you no longer want to receive text messages from us, you can reply to the message with “STOP” or “UNSUBSCRIBE.”

We will try to comply with your request(s) as soon as reasonably practicable.

How you can access, change or delete your Personal Information

If you would like to request to review, correct, update, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by emailing us at privacy@mytonomy.com or mailing us at 4550 Montgomery Ave, Suite 200N, Bethesda, MD 20814. You may also updated or correct your Personal Information by visiting your Account profile page. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed 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 obligations to the Mytonomy Customer.

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. 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 info@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.