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Last updated: September 17, 2018

                                                                     Mylefly Privacy Policy

We, at Mylefly Ltd. (the “Company”, “we”, “us”, or “our”) are committed to protecting your personal information and your right to privacy. This privacy policy (the “Privacy Policy”) describes the ways we collect information from and about you, how we use it and what rights you have in relation to it, so that you may decide whether or not to provide information to us. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our site and our services. By accessing our website or using our services you agree to this Privacy Policy in addition to any other agreements we might have with you. In the event that such agreements contain terms that conflict with this Privacy Policy, the terms of those agreements will prevail. This Privacy Policy does not govern the practices of entities that our Company does not own or control, or entities that do not own or control our company or people that our Company does not employ or manage.

This Privacy Policy applies to all information collected through our website (such as mylefly.com), and/or any related services, sales, marketing or events (we refer to them collectively in this Privacy Policy as the “Sites”).  

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.  

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us  

In Short: We collect personal information that you provide to us such as name, Email address, phone number, location data and login data (username and password).

We collect personal information that you voluntarily provide to us when registering at the Sites, when you contact us through the Sites, expressing an interest in obtaining information about us or our products and services, when we correspond with you as a customer or prospective customer, when participating in activities on the Sites or otherwise contacting us.

The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.  

Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Google or Linkedin account. If you choose to register in this way, we will collect the Information described in the section called "Social Logins" below.

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (the “Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.  

We use the information we collect or receive:  

• To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account (such as your Google, Facebook or Linkedin account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "Social Logins" for further information.

• To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual resons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• To post testimonials with your Consent. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at info@mylefly.com and be sure to include your name, testimonial location, and contact information.

• To protect our Sites for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for data breach monitoring and prevention).

• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or Contractual reasons.

• To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: Your data will not be shared with any third party without your cosent. We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples may include: data analysis, email delivery, database management services, customer service and marketing efforts. We may allow selected third parties to use cedrtain technologies on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the use of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, transfer, rent or trade any of your information with third parties for their promotional purposes.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We are not making any use of tracking cookies and other tracking technologies to collect and store information.

We may use cookies only for essential website administration, such cookies does not collect any personal data. We do not use tracking cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Sites offers you the ability to register and login using your third party social media account details (like your Facebook, Google and Linkedin logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their Privacy Policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?  

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Please be aware that your information may be transferred to, stored, and processed by us in any other country in which our Company or agents or contractors maintain facilities, and by accessing our sites and using our services, you consent to any such transfer of information outside of your country.

In particular Mylefly complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, Mylefly is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age.  By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site.  If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws.  These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us info@mylefly.com. We will consider and act upon any request in accordance with applicable data protection laws.  

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:

• Noting your preferences at the time you register your account with the Sites.
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below

CALIFORNIA RESIDENTS SPECIFIC PRIVACY RIGHTS

In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.

We do not currently respond to browser “Do Not Track” (DNT) signals or other mechanisms. If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, email us at info@mylefly.com.