MLMIC INSURANCE COMPANY MOBILE APP PRIVACY POLICY

Last Updated January, 2020


INTRODUCTION

MLMIC Insurance Company (“MLMIC,” “we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application (the “Application”).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the application.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you use, and includes:

Personal Data

Demographic and other personally identifiable information (email, first name, last name, phone number, physical address, zip code) that you voluntarily give to us when choosing to participate in various activities related to the Application, such as sending feedback, and responding to surveys.

Geo-Location Information

We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s [Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data

Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notifications

We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to:

  1. Assist law enforcement and respond to subpoena.
  2. Compile anonymous statistical data and analysis for use internally or with third parties.
  3. Create and manage your account.
  4. Deliver targeted advertising and other information regarding promotions and the Application to you.
  5. Email you regarding your account or order.
  6. Enable user-to-user communications.
  7. Generate a personal profile about you to make future visits to the Application more personalized.
  8. Increase the efficiency and operation of the Application.
  9. Monitor and analyze usage and trends to improve your experience with the Application.
  10. Notify you of updates to the Application.
  11. Offer new products, services, mobile applications, and/or recommendations to you.
  12. Perform other business activities as needed.
  13. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  14. Request feedback and contact you about your use of the Application.
  15. Resolve disputes and troubleshoot problems.
  16. Respond to product and customer service requests.
  17. Send you a newsletter.
  18. Solicit support for the Application.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and criminal investigation, where permitted by law or regulation.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Other Third Parties

We may share your information with third parties for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may reserve the right to use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Application, which is incorporated into this Privacy Policy. By using the Application, you agree to be bound by our Cookie Policy.

THIRD-PARTY WEBSITES

The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

POLICY FOR CHILDREN

This Mobile App is intended for use only by individuals who are at least 18 years of age, and who are fully competent and able to enter into and be legally bound by our Privacy Policy. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us using the contact information provided below. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take the necessary steps to remove that information from our app and/or servers.

CALIFORNIA PRIVACY RIGHTS

California residents have additional data protection rights as provided by the California Consumer Privacy Act of 2018 (CCPA) and California Civil Code § 1798.83. These laws provide California residents the following rights:

Disclosures of Personal Data

California residents have the right to know:

Personal Data We Sell or Disclose for a Business Purpose

In connection with any personal data that we sell or disclose to a third party for a business purpose, California residents have the right to know:

MLMIC does not sell (as is defined by the CCPA) the Personal Data we collect, and will not sell it without providing California residents the right to opt out. ALTERNATIVE: In the preceding 12 months, we have sold or disclosed to one or more third parties the following categories of Personal Data: • [list categories of Personal Data sold] As a California resident, you also have the right to opt out of the sale of your Personal Data. If you exercise the right to opt out, we will refrain from selling your Personal Data unless you subsequently submit an authorization for the sale of your Personal Data. To opt out of the sale or disclosure of your Personal Data, visit our homepage and click the “Do Not Sell My Personal Information” link, or contact us at https://www.mlmic.com/contact.

Right to Deletion

Subject to certain exceptions set out below, upon receipt of a verifiable request from California residents, we will: • Delete your Personal Data from our records; and • Direct any service providers to delete your Personal Data from their records. Please note that we may not delete your Personal Data if it is necessary to: • Complete the transaction for which your Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you • Detect and protect against security incidents, fraudulent or illegal activity, or for prosecuting those responsible for such activity • Debug, identify, or repair errors that impair existing functionality • Exercise free speech • Comply with the California Electronic Communications Privacy Act • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all applicable ethics and privacy laws • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us • Comply with an existing legal obligation • Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information

Protection Against Discrimination

You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot: • Deny goods or services to you • Provide a different level or quality of goods or services to you Please note that we may charge a different price or rate to you if that difference is reasonably related to the value provided to us by your Personal Data.

California’s Shine the Light Law

In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Data to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please contact us at https://www.mlmic.com/contact.

CONTROLS FOR DO-NOT-TRACK FEATURES

Some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

OPTIONS REGARDING YOUR INFORMATION

Your Account Information You may at any time review or change the information in your account or terminate your account by: ● Logging into your account settings and updating your account ● Contacting us using the contact information provided below 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.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at: https://www.mlmic.com/contact