Milo Privacy Policy

This Privacy Policy explains which personal data we (“Loose Cannon Systems”, or “LCS”) collect and how we use it when you use the Milo website (https://www.okmilo.com) and/or any of LCS’s online or mobile products (including the Milo Link mobile app), Milo hardware or software, or other services (collectively, “Services”), including when you access the Services through mobile devices. By using the Services you agree to LCS’s Privacy Policy and that we may process, transfer and store your information in the United States. Loose Cannon Systems, Inc. (PO BOX 1447, Ross, CA 94957) is the controller of your personal data.

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES.

LCS will post any modifications or changes to the Privacy Policy on the Milo website. We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it frequently. If we make a material change to this Privacy Policy, we will notify you by email or by means of a notice on the Milo website or via push notifications within our mobile applications prior to the changes taking effect, in accordance with any applicable legal obligations. Your continued use of the Services signifies your acceptance of our modified Privacy Policy. We regularly update our software applications (including our mobile and desktop applications) to make improvements, including improvements that better serve your privacy rights. To ensure that this Privacy Policy accurately reflects your use of the Services you will need to ensure that you are using the most recent release of the Milo’s software applications.

 

1. Information We Collect

Information You Provide
LCS collects a variety of information that you provide directly to us, including personal data that may be contained in videos, comments, or other submissions you upload or post to the Services. “Personal Data” is information that is related to an identified or identifiable natural person and is protected as personal data under applicable data protection laws.
The specific types of information collected will depend upon the Services you use, how you use them, and what you choose to provide, and may include your full name, email address, phone number, product serial number, home address, mobile phone number, credit card information, shipping address, gender, birth date, and zip code. Our mobile services may request your Wi-Fi network name and access to your photos and videos to enable you to download photos and videos to your computer/mobile device or upload photos and videos to your Milo account or social media accounts. Those who win a prize in our contests may be required to provide their social security number and other identification for tax purposes, which will only be used for prize fulfillment purposes. When you shop through our web store, we may collect data such as the purchases you have made, items in your shopping cart, and how often you make purchases. We also collect information you choose to include in your Milo account, including, but not limited to, videos and photos, any comments on yours or others’ posts, interests and preferences, location, videos and photos that you have favorited, and other Milo users whose Milo accounts you follow.

How We Collect Information You Provide

Information We Automatically Collect
When you use our Services that connect to the Internet, including, but not limited to, when you access the Services via Milo devices, applications, your Milo account, and our web sites and web store, we may collect the Personal Data described below for such purposes as improvement of our products and software services, troubleshooting bugs, providing the Services, managing the Services, security and monitoring purposes, tracking and analyzing usage, providing content for referring traffic sources and improving overall performance of the Services. Such information includes aggregated user data (which does not allow us to identify you), as described in more detail below. We also use third party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information, as further disclosed in the Cookie Policy.

Websites
When you use our websites (including our web store), we collect and analyze information about your computer or mobile device, such as your browser type, IP address, a mobile device identifier (e.g., a IDFA on Apple products like the iPhone and iPad or similar advertising identifiers), browser language, operating system, error logs, the state or country from which you accessed the Services, referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services and upload or post content, error logs, and other similar information. We monitor customer traffic patterns and site usage to help us develop the design and layout of the site, and to improve the content of our website to better match the interests of our website users.

Milo Devices
When you connect your Milo device to the Internet or to the Milo Link mobile app, we may automatically receive certain information about your Milo device and your use of it, including camera type, serial number, IP address, firmware version, log files, camera modes, settings, durations, error rates, and other similar usage information. This information helps us to improve our products and services, troubleshoot bugs, and analyze camera errors.

Mobile Software Applications
When you use the Milo mobile application, Milo Link, we may automatically receive certain information about your mobile device and use of the application, including a mobile device identifier, advertising identifiers), operating system, version, IP address and other similar information, such as time spent in different portions of the Milo mobile application and error rates. We may also collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., precise GPS information using the mobile devices used to access the Services), as detailed further below.

Location Information
When you install our mobile applications, you will if legally required be asked to grant access to your mobile device’s geolocation data. If you grant such permission, we will collect information about your precise geolocation (i.e., your real-time geographic location), and will use that information to customize the Services with location-based information and features. You can withdraw your consent at any time. Moreover, you can disable the GPS or other location-tracking functions on your mobile device, provided your mobile device allows you to do this. See your device manufacturer’s instructions for further details. We may also be able to collect location information through your use of a Milo device. If so, we will ask you before this information is captured and you will be given the opportunity to turn it off.

Information from Other Sources
We may receive information about you from third parties, such as commerce partners, marketers, social network services, connected TV and entertainment apps, and other parties that we may use to supplement the information we collect directly from you. If you connect to a third party network (such as a social network), platform, or service through the Services, you are authorizing us to collect, store, and use in accordance with this Privacy Policy any and all information (such as name, email address and location) that you agreed the network or other third party platform could provide based on your settings on the third party network or platform. You will be asked for your consent when you connect with the third party network, platform, or service via our Services, and/or when you connect with one of our applications through one of these services.

De-Identified Data
We may collect data that is already in de-identified form or we may manually de-identify information collected by the Services or via other means so that the information does not identify you. Our use and disclosure of such de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

 

2. Cookies and Similar Technologies

Please see our dedicated Cookies Policy.

 

3. Online Advertising and Analytics

Online Analytics
LCS may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in the section “Information We Automatically Collect” above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to online marketing, as described in the following section. If you’d like to opt out of Google Analytics, please use the Google Analytics Opt-Out Browser Add-on located here: https://tools.google.com/dlpage/gaoptout

Online Advertising
We do not serve third party advertisements to you while using okmilo.com. However, we do work with website analytics and advertising partners, including Google, Doubleclick Campaign Manager, AdRoll, Commission Junction and Facebook, to deliver Milo advertisements on third party publisher websites – these partners may set cookies on your computer’s web browser. These cookies allow our partners to recognize your computer so that the ad server can show you Milo advertisements elsewhere on the Internet, and so that our analytics software can measure your engagement and interactions while using okmilo.com. In this way, ad servers may compile certain information about where you, or others who are using your computer, saw our advertisements, whether or not you interacted with our advertisements, and actions performed on subsequent visits to okmilo.com. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you, and it allows us to optimize the performance of our advertising campaigns and the usability of our website. In other words, we use analytics data in concert with data about our online ads that have been shown using the Google Display Network, DoubleClick for Advertisers, or other online advertising networks. By doing so, we can understand how anonymous users interacted with our website after seeing our ads.

Notice concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the Network Advertising Initiative and the Digital Advertising Alliance opt-out links below in the section “Your Choices.” However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

For more information about these advertising and analytics services and how to opt out, please see “Your Choices” below.

 

4. Uses of Information and Legal Bases for Processing

LCS uses the Personal Data it collects described above in “Information We Collect” for the following purposes:

The legal bases pursuant to which we process information as discussed above are:

 

5. Sharing and Disclosure of Information

LCS will share information as outlined below or with your consent:

 

6. Your Choices

LCS provides you with a number of choices with respect to the information we collect and use as discussed throughout this Policy. Some of your choices include:

 

7. EEA Rights to personal information

EU and Swiss individuals have the following rights, under certain circumstances:

 

8. EEA User Right to Lodge a Complaint Before the Data Protection Authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at [email protected] and we will provide you with detailed information as regards the contact details of the respective competent supervisory authority.

 

9. China Rights to personal information

Chinese individuals have the following rights, under certain circumstances:

You may assert these rights at any time by logging into your Milo account and accessing features such as Edit Profile and Account Info. You may also email us to correct or change any information or request which Personal Data (e.g. name, address) we have stored or to assert any other of your rights as mentioned above by filling out our contact form by emailing us at [email protected]

 

10. Privacy Information for California Residents

If you are a California resident, California law requires us to provide you with additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (CCPA)).

Categories of Personal Information We Collect

Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we may collect are:

How We Use and Share These Categories of Personal Information

We use and share the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy. See sections “Uses of Information and Legal Bases for Processing” and “Sharing and Disclosure of Information” above for more information.
Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. Based on the definition of sell under the CCPA and under current regulatory guidance, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.

Your California Privacy Rights

CCPA Rights Disclosure: If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need to retain certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please email us at sup[email protected].

California Shine the Light Disclosure: California Civil Code Section 1798.83 permits customers of LCS who are California residents to request certain information, once per year, regarding our disclosure of their personal information (as defined by California law) to third parties for their own direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share personal information with third parties for their own direct marketing purposes.

 

11. Privacy Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products or services from us, you may submit a request to opt out of any potential future sales under Nevada law to [email protected] Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

 

12. Third Party Website Links and Features

Our Services may contain links to or features from other websites. This Privacy Policy covers the privacy practices by us, and does not cover the privacy practices of third party websites or features. We are not responsible for the privacy policies and/or practices of third parties. When linking to another Site or using a third party service, you should read the privacy policy on that site or service.

 

13. Customer Reviews

We use third party vendors to allow website visitors to submit original reviews of our products, and to display consumer reviews on product pages on our Services. Original review content submitted by you to such third party vendors’ review submission forms and via email may also be published on third party websites. Information that can directly identify you is not required to submit product reviews. LCS is not responsible for the privacy policies and/or practices of such third parties. The Terms of Use and Privacy Policies of such third parties govern any information you submit.

 

14. Children’s Privacy

Our Services are intended for general audiences and not for children under the age of 13. We do not knowingly collect personal information from children under the age of 13 and if we become aware of such collection, we will take reasonable steps to delete any such information as soon as practicable.

 

15. International Users

LCS operates primarily in the United States and as a result, we, and/or our service providers that perform services on our behalf, may collect, process, and store your information in the United States and in other locations outside of the European Economic Area. By using the services, you acknowledge this, and understand that any transfer of your data to the United States or another location will be in compliance with applicable data protection laws.

 

16. Privacy Shield – EU – US and Swiss US Data Transfers

LCS complies with the E.U. – U.S. and Swiss – U.S. Privacy Shield Frameworks (“Privacy Shield”), with respect to data transferred pursuant to the Privacy Shield Framework, as set forth by the U.S. Department of Commerce and approved by the European Commission and Swiss Federal Council regarding the collection, use, and retention of Personal Data as received from the European Union and Switzerland. Specifically, we adhere to the Privacy Shield Principles of (1) Notice; (2) Choice; (3) Accountability for Onward Transfer; (4) Security; (5) Data Integrity and Purpose Limitation; (6) Access; and (7) Recourse, Enforcement and Liability in respect of any Personal Data received from the European Union and Switzerland.

We collect and process data in accordance with this Privacy Policy. Please see “Information We Collect” for further details of the types of data which we collect from you, and “Sharing and Disclosure of Information” for the purposes for which we collect it.
If there is any conflict between the policies in this Privacy Policy and the extra protections provided by the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page on the Privacy Shield List, please visit https://www.privacyshield.gov/

Privacy Complaints Handling, Recourse and Enforcement
In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Data (without charge to you). European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at:

Email address[email protected]
We will respond to any complaints as soon as possible and within 45 days.
We encourage EU and Swiss individuals who have questions or complaints about how we process their Personal Data under Privacy Shield to contact us at [email protected]. We will work to resolve your issue as quickly as possible, but in any event within 45 days of receipt. If you have an unresolved privacy or data use complaints that we have not addressed satisfactorily, please contact, free of charge, our dispute resolution provider, JAMS, at https://www.jamsadr.com/eu-us-privacy-shield. If you are an EU or Swiss individual and unable to resolve any complaints through any of the above methods, you may be able to invoke binding arbitration through a Privacy Shield panel, in accordance with the Privacy Shield Framework at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint
Please note that if your complaint is not resolved through these channels, in certain limited circumstances, a binding arbitration option may be available.
LCS is subject to the investigatory and enforcement powers of the Federal Trade Commission in the case of any failure to comply with the Privacy Shield.

 

17. Changes in Our Privacy Policy

From time to time, our information practices may change. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy on our website or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, in accordance with applicable legal obligations. To access the Privacy Policy for your territory please change the country setting on the Site by clicking the country link in the top right corner of the pages. If specific terms are not available, we will default to this English version.

 

18. How we Protect Your Information

The security of your Personal Data is important to us. We have implemented administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. Despite our best efforts, however, no security measures are completely impenetrable.

 

19. Data Retention

We delete or anonymize your Personal Data as soon as it is no longer required for the purposes we have collected your Personal Data as outlined in this Privacy Policy, unless further processing or storage of your Personal Data is necessary in order to comply with a respective legal obligation.

 

20. Automated individual decision-making, including profiling

LCS doesn’t use your Personal Data to make decisions with legal or similar effects for you based only on the automated processing of your Personal Data.

 

21. Contact Info

If you wish to contact us or have any questions about or concerns in relation to this Privacy Policy, please contact us at:
[email protected]
or
Loose Cannon Systems, Inc.
PO BOX 1447, Ross, CA 94957
USA