“Client” means a customer of 19thMile.
“Client Data” means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
2. The Information We Collect on the Service:
We collect different types of information from or through the Service. The legal bases for 19thMile’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with 19thMile’s Terms of Service and that the processing is carried out in 19thMile’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.
2.1 Information provided by User.
When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service -related requests.
2.2 Information Collected by Clients.
A Client or User may store or transfer into the Service Client Data. 19thMile has no immediate association with the people whose Individual Information it has as a component of Client Data. Every Client is in charge of giving notification to its clients and third people concerning the reason for which Customer gathers their information and how this information is handled in or through the service as an aspect of Customer Information.
2.3 “Automatically Collected” Information
We receive and store certain types of information whenever you interact with us. For example, like many Web sites, we use “cookies,” “clear gifs” or “web beacons” and we obtain certain types of information when your Web browser accesses 19thMile or advertisements and other content served by or on behalf of 19thMile. We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our Services, and what posts, videos and other content you view on our Services.
2.4 Integrated Services
2.5 Information from Other Sources.
We also receive and analyse content, communications and information that other people provide when they use our Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
3. How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
We utilize the data to comprehend and analyze the utilization patterns and inclinations of our Guests and Clients, to enhance the Services, and to develop new products, services, highlight, and usefulness. Should this purpose require 19thMile to process Client Data, then the data will only be used in anonymized or aggregated form.
We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
A cookie is a small text file that can be stored on and accessed from your device when you visit one of our Sites, to the extent you agree. Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Sites. This allows our Sites to recognize your device from those of other users of the Sites. In this policy, we refer to all of these technologies as “cookies.”
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
While 19thMile takes all reasonable steps to protect the privacy of its Website visitors or Mobile Application users, 19thMile cannot promise that its current online applications programming will address every browser setting or honor every personal browser preference and urge users to better understand such restriction to not put 19thMile at risk by violating any laws pertaining to informational privacy or personal privacy.
In particular, 19thMile has not implemented the necessary program changes to honor “Do Not Track” or “DNT” browser signals and hence all users are requested to independently verify and follow the laws of India.
We utilize Google Analytics to quantify and assess access to and traffic on the Public Area of the Site, and make client route reports for our Site directors. Google works freely from us and has its own particular security arrangement, which we emphatically propose you to review. Google may utilize the data gathered through Google Analytics to assess Users’ and Visitors’ action on our Site. For more information, see Google Analytics Privacy and Data Sharing.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
4. Information Disclosure
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
4.1 Unrestricted Information
Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.
4.2 Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
4.3 Non Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
4.4 Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government order or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
4.5 Change of Ownership
If the ownership or control of all or part of our Services or their assets changes, we may transfer your information to the new owner.
5.1 Access, Correction, Deletion
We regard your Privacy Rights and furnish you with sensible access to the personal information that you may have given through your utilization of the Services.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.
5.2 Navigation Information
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
5.3 Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
19thMile has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly. If the Client requests 19thMile to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for 19thMile to identify the Client or its customer or third party and the information to delete or amend.
6. Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
7. Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
8. Interest Based Advertising
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the 19thMile products or services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.
We may use special tools that are commonly used for collecting information, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
We do not share with third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.
9. The Following Types of Cookies Are Used in the Site:
Strictly necessary/essential cookies – These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
Performance cookies – These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Functionality cookies – These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Behaviorally targeted advertising cookies – These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
10. Minors and Children’s Privacy
19thMile’s Websites or Mobile Application are general audience websites meant for professionals. 19thMile’s Website or Mobile Application content is not directed toward children who are under the age of 18. We do not knowingly collect Personal Information from children. If 19thMile or its Internet Service Providers become aware that a child has provided us with Personal Information without parental consent, that information will be deleted from our databases. If you have questions about Personal Information that may have been submitted by a child, please email us at email@example.com.
11. Data Security
19thMile makes reasonable efforts to ensure that our Internet Service Providers have implemented physical, electronic, technical, organizational and procedural security measures to assist with safeguarding your Personal Information, and to help protect against unauthorized access and disclosure. Only our authorized personnel and our Internet Service Providers who perform legitimate business functions for 19thMile are authorized to access your Personal Information. Notwithstanding our efforts, the Internet has inherent security risks. 19thMile cannot promise, and you should not expect, that your Personal Information, personal searches, and other communications will always remain secure. You should take care with regard to how you handle and disclose your Personal Information or any username or password that you are required to use to access services on our Websites or Mobile Application.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we do not guarantee its absolute security.
12. Data Retention
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- The contents of closed accounts are deleted within 3 months of the date of closure;
- Backups are kept for 3 months;
- Billing information is retained for a period of 7 years;
- Information on legal transactions between Client and 19thMile is retained for a period of 10 years;
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
14. Data Transfer
15. Data Controller and Data Processor
19thMile does not claim, control or direct the utilization of any of the Client Data put away or handled by a User or Client through the Service. Only the User or Clients are qualified for access, recover and coordinate the utilization of such Client Data. 19thMile is to a great extent ignorant of what Client Data is really being put away or made accessible by a User or Client to the Service and does not straightforwardly access such Client Data with the exception of as approved by the Client, or as important to give Services to the Client and its Users.
19thMile is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is 19thMile responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
16. Changes in Policy
If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
17. How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at firstname.lastname@example.org