Privacy Policy

Effective Date: January 1, 2020.

Millennial Capital Development and its subsidiaries and affiliates (collectively, “Millennial Capital Development”, “us” or “we”) understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with Millennial Capital Development's business activities, like conferences and events, and client services, and on websites, applications, and communications that post a link to this Privacy Policy (collectively, “the Sites”), in our capacity as data controllers. Please see our Terms of use for more information about our online terms and policies in general.

Information we collect

Millennial Capital Development collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you register for or apply for jobs through the Millennial Capital Development Recruitment Portal, create a user profile, register for Millennial Capital Development newsletters and alerts, participate in our alumni activities through our Alumni Center, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information required to apply for a job or request services from us.

We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.

Millennial Capital Development may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, foot traffic in retail environments). We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Millennial Capital Development, in compliance with applicable law.

Use of information

Millennial Capital Development uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Millennial Capital Development’s agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it in the course of our business activities, including in connection with some client services, for example, to provide certain services or products such as our consultancy or benchmarking. We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.

Millennial Capital Development and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. Millennial Capital Development and its service providers may collect information about whether you open or click any links in the knowledge, research or event communications that we send to you. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and Other Tracking Technologies.

Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.

Use of information collected via mobile devices

In connection with our mobile applications, Millennial Capital Development may use third party service providers to analyze user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, Millennial Capital Development may receive reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. Millennial Capital Development may also receive reports on certain errors occurring within mobile applications.

In addition, our Millennial Capital Development Insights app offers a personalized list of recommendations (called “Curated Insights”) directing you to Millennial Capital Development content that we think you will find interesting. Recommendations are based solely on what you have viewed one our platform, website or apps. Any unique user identifier that is generated by the app helps personalize your experience and tracks the articles that you read in the app. We do not share your viewing history or trends with other users or any external third parties (i.e., persons or entities that are not affiliates or third-party service providers of Millennial Capital Development) except in the completion of our duties.

The legal basis by which we process your personal data

Our processing of your personal data for the purposes mentioned above is based:

· in part, on our legitimate interests in promoting and protecting Millennial Capital Development, building and maintaining relationships. recruitment, and providing our services;

· in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;

· in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.

Disclosure of personal data: data recipients and international data transfers

Personal data collected in the course of Millennial Capital Development business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to Millennial Capital Development subsidiaries and affiliates and their personnel across our global organization, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Millennial Capital Development and our third-party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Millennial Capital Development subsidiaries, affiliates and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

Millennial Capital Development will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Millennial Capital Development may provide access to your personal data to third party service providers engaged by Millennial Capital Development to provide services related to the Sites as well as related to Millennial Capital Development’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you.

In addition, we may disclose information about you:

· If we are required to do so by law or legal process;

· To law enforcement authorities or other government officials;

· When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

· If disclosure is necessary to protect the vital interests of a person;

· To enforce our Terms of use;

· To protect our property, services and legal rights;

· To prevent fraud against Millennial Capital Development, our subsidiaries, affiliates and/or business partners;

· To support auditing, compliance, and corporate governance functions; or

· To comply with any and all applicable laws.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

User forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Millennial Capital Development is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.

Link to third party sites

Millennial Capital Development may provide links to third party websites or information as a service to our users. If you use these links, you will leave the Sites. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Millennial Capital Development of the third party, the third party website, or the information contained therein, and Millennial Capital Development shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Social Networking

The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Millennial Capital Development. The Sites also may allow you to log in to a Millennial Capital Development account using certain social network account credentials.

By associating your social network account with Millennial Capital Development or logging in to a Millennial Capital Development account using your social network account credentials, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with Millennial Capital Development and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.

Security

Millennial Capital Development has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Millennial Capital Development personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, Millennial Capital Development cannot guarantee that unauthorized persons will not obtain access to your personal data.

Data retention

Millennial Capital Development retains personal data, as necessary, for the duration of the relevant business relationship.

We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our in ternal and/or legally imposed information management policies and schedules. If you request that we delete your personal data, Millennial Capital Development will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Children

The Sites are not designed for or directed at children 16 years of age or younger, and Millennial Capital Development does not intentionally collect or maintain personal data about anyone under this age. Millennial Capital Development does not limit information behind paywalls or other barriers, parents or guardians should monitor and limit access to services. Please contact us at privacy@millennialsinc.com to notify us if data has been collected from minors.

Millennial Capital Development Recruitment portal/Millennial Capital Development Recruiting Program/Alumni Center

Through the Millennial Capital Development Recruitment portal, you can apply for positions with Millennial Capital Development or sign up for a Millennial Capital Development Recruiting Program where you can be notified of any potential job openings or other similar opportunities that might be of interest. The Recruitment Privacy Notice describes more in detail how Millennial Capital Development and our subsidiaries and affiliates handle and protect the personal data that we collect in connection with the recruitment process.

If you are a former Millennial Capital Development employee, you may be eligible to join our Alumni program and have access to the Alumni Center website. The Alumni Center website is accessible only to current and former Millennial Capital Development colleagues and the relevant conditions are set forth in the Alumni Center website.

Your rights

Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at dataprivacy@millennialsinc.com. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.

Unsubscribe

If you have registered for Millennial Capital Development newsletter or alerts, or you receive invitations to survey or events from Millennial Capital Development and you prefer not to receive future email communications from us, please review the communications settings in your profile on Millennial Capital Development.com, follow the instructions on the page of the Site where you have provided such information, subscribed or registered or write to global-unsubscribes@Millennialsinc.com to unsubscribe from all Millennial Capital Development communications.

Your California privacy rights

If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacycalifornia@Millennialsinc.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of personal data collected, processed, and disclosed by Millennial Capital Development, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed.

In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about Millennial Capital Development’s collection, use, disclosure, and sale of personal data about you including:

· The categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information,

· The categories of sources from which we have collected that information in the preceding 12 months,

· The commercial or business reason(s) we have collected, used, disclosed, or sold that information, and

· The categories of third parties to whom we have disclosed or sold that information in the preceding 12 months.

· In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months.

You may also have the right to request deletion of personal data about you that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.

If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us at privacycalifornia@Millennialsinc.com, When we process your request, we require you to provide certain personal data about you in order to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. Millennial Capital Development will not discriminate against you based on your exercise of any of these rights.

Consent; changes to Privacy Policy

By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.

If you have any questions about our Privacy Policy or if you would like to communicate with our EU Data Protection Officer or the Data Privacy Team, please contact us at: privacy@millennislainc.com