Your privacy is important to us and we want you to feel comfortable using the Milla Cashback Program as described and outlined in the Program Terms. In view of this, we have created this addendum ('Addendum') to our global Privacy Policy which applies to anyone using the Program and should be read in conjunction with our Privacy Policy. In case of any conflict between the Privacy Policy and the terms of this Addendum, this Addendum shall prevail.
1. GENERAL
In order to provide you with the benefits of the Program, we need to collect information, which may also include your personal information or data, as defined under applicable law. Please be aware that your browsing of our website may also result in the collection of certain information due to technologies detailed in our Privacy Policy.
2. INFORMATION WE COLLECT THROUGH THE PROGRAM
We collect and use several types of information from and about you for the Program, including:
Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, email address, phone number, Internet protocol (IP) address used to connect your computer to the Internet, login/username or other similar identifier, and any other identifier we may use to contact you ('personal information').
We provide an opportunity for you to unsubscribe or opt-out of contact on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails or by emailing to [email protected].
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personalinformation to calculate the percentage of users accessing a specific feature of the Program.
Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access the Program, and usage details.
Non-personal details about your interactions with the Program, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Sites (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
Transaction Data. When you participate in the Program by enrolling an eligible card (e.g., Visa, Mastercard), you will be asked to give consent for transactions on that enrolled card to be monitored by the respective card network and for that card network to share certain details of the monitored transactions with us and Olive Group Ltd ('Program Vendor'). Each party will access this Transaction Data from your monitored transactions. This Transaction Data may include the date, time, amount, merchant category, and merchant name. You may revoke your consent and opt-out of transaction monitoring on your enrolled cards at any time by going to your settings and disabling or removing the card from the Program.
When your card is enrolled with the network, it is done so securely and directly with the Payment Network. A unique identifier, a token, representing your enrolled card is used by our technology partner, Program Vendor, Milla, and our Partners, never see your credit card number or related details. After enrollment, your Transaction Data and the unique identifier will be shared between Milla, Program Vendor, and the card network associated with your enrolled card. No additional Personal Information is shared with these third-parties about your Milla account.
3. HOW WE USE YOUR INFORMATION
We use the information that we collect about you or that you provide to us, including any personal information:
- to present our Program and its contents to you;
- to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
- to provide you with notices about your account/subscription, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
- to improve our Program, products or services, marketing, or customer relationships and experiences;
- in any other way we may describe when you provide the information;
- or for any other purpose with your consent.
How we use your Transaction Data. When you participate in our Program by enrolling an eligible credit card (i.e. Visa, Mastercard), you will be required to provide consent to have transactions on your enrolled card monitored by the card network. That card network will share with us, and with Olive Group Ltd (“Program Vendor”), certain Transaction Data from those the monitored transactions that includes the date, time, amount, merchant category, and merchant name. Notwithstanding anything to the contrary in our Terms of Use, Privacy Policy or this Addendum, Milla and Program Vendor will use your Transaction Data solely to:
- enable card linked offers,
- identify offers that may be of interest to you based on location,
- provide Program notifications,
- calculate Cashback reward payment amounts
- report in aggregate to merchants the success of their offers in the Program.
4. PERMISSION FOR COLLECTION OF INFORMATION
By using the Program, you are hereby consenting to the collection of your information by us. The information in some cases may include personal and sensitive personal information. In case of collection of sensitive personal information, you will be required to confirm your acceptance of this Addendum and our Privacy Policy. By accepting the present Addendum and our Privacy Policy, you are also representing that you are eighteen (18) years of age or older. If you are under the age of eighteen (18), then please do not share any sensitive personal information or personal information with us without having your parent or legal guardian accept this Addendum and our Privacy Policy on your behalf.
Please be aware that, if you do not allow us to collect information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. By providing your information to us you are consenting to the use of such information by us in accordance with this Addendum and/or our Privacy Policy.
5. SHARING OF INFORMATION COLLECTED FOR THE PROGRAM
We may disclose aggregated information about the use of the Program, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- to our subsidiaries and affiliates;
- in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our customers and users is among the assets transferred;
- to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information;
- with your consent.
We may also disclose your personal information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
- to enforce or apply the Program Terms and other agreements, including for billing and collection purposes; and/or
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
When you participate in the Program your Transaction Data and a token representing your enrolled card will be shared between Milla, Program Vendor, and the card network associated with your enrolled card (i.e. Visa, Mastercard). No additional Personal Information is shared with these third-parties about your account with us without your consent.
6. QUESTIONS OR COMPLAINTS
If you have any complaints or concerns regarding the information shared with us, please feel free to contact us at [email protected].