Privacy Policy

How do we use your information?

Personal Information

We may use Personal Information we collect (including in combination with Other Information) to:

• Recognize new or past customers or users, customize your experience when you use the Services or serve you with advertising content that we believe will interest you;
• Communicate with you about your account, your use of the Services, or related issues or respond to or fulfill your requests for products, services, and information;
• Provide you with information about the Services and update you on any changes or improvements;
• Engage in general marketing efforts, such as sending you information about special promotions, offers, new features or products, whether for MicroLumen or trusted third parties;
• Provide, maintain, protect and improve the Services and other products and to develop new ones;
• Further our business or operational purposes, for example, data analysis, audits, fraud monitoring and prevention of fraud or other illegal activities or other prohibited conduct in accordance with our Terms of Use (which can be found at https://www.microlumen.com or otherwise protect our company, our users, or our Services; and
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Other Information

Because Other Information (as defined above) does not personally identify you or relate to you individually, MicroLumen may collect, share, disclose and otherwise use Other Information for any legal purpose, such as sharing such Other Information publicly to demonstrate trends in the use of our Services and for other purposes.

However, if MicroLumen combines Other Information with Personal Information in a way that can identify you or be used to identify you personally, we will treat that information as Personal Information, subject to the provisions of this Privacy Policy.

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Do we share your information?

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

Service Providers

We may share your Personal Information with Service Providers that provide business, professional or technical support functions, assistance in operating our business, or other activities in support of the Services or our businesses. Our Service Providers are not authorized to use your Personal Information for purposes other than those related to the services they are providing to us.

Promotions

From time to time, we may offer sweepstakes, contests, or other promotions (each, a “Promotion”) through the Services, such as to incentivize a survey. If you enter a Promotion, we may disclose your Personal Information to third parties or the public in connection with the administration of such Promotion, as required by law or as permitted by the Promotion’s official rules or this Privacy Policy.

Business Partners

We may disclose Personal Information to our operational, business and marketing partners (collectively “Business Partners”) for operational, business, marketing, or other purposes consistent with this Privacy Policy. For example, Business Partners may send you information about events and products by mail or e-mail.

Co-Branded Services

From time to time, MicroLumen may partner with select third parties (each a “Co-Branded Party”) to provide content, website pages, services or other offerings (both within or outside of our Services) on a joint or “co-branded” basis (“Co-Branded Services”). By providing Personal Information through a Co-Branded Service, you agree that you are providing such Personal Information to both MicroLumen and each of the Co-Branded Parties without any other notice or further consent.

In addition, by signing up for updates or alerts or participating in promotions, surveys, or other interactive features contained within a Co-Branded Service, you agree that MicroLumen may share the Personal Information you provide through such Co-Branded Service with the relevant Co-Branded Parties.

MicroLumen has no control over, or responsibility for, the information collection and use practices of Co-Branded Parties, who may have privacy policies that differ from our own. So you should read these policies carefully to understand their policies and your options. You may avoid sharing your Personal Information with these third parties by choosing not to register or use the relevant feature.

Select third parties

We may share your Personal Information with select companies that we believe may have offers of interest to you.

Information transfers, storage, and processing

When we share your Personal Information with our Business Partners and Service Providers, your Personal Information may be transferred to and/or made accessible from countries out of the EU/EEA. In such circumstances, we will enter into model contractual clauses as adopted by the European Commission or rely on alternative legal bases such as the EU-U.S. Privacy Shield, where applicable, or binding corporate rules where our Business Partners or Service Providers have adopted such internal policies approved by European data protection authorities.

Legal purposes

We may disclose your Personal Information to verify or enforce compliance with our internal policies and applicable laws and whenever we believe disclosure is necessary to limit our liability or to protect or enforce the rights, interests or safety of our Services, our users or others.

We may disclose your Personal Information to the government or third parties to comply with the law, applicable regulations, subpoenas, court orders, law enforcement requests, legal claims, government or quasi-government inquiries, or other legal process, for example, in connection with suspected illegal activity associated with the Services or our businesses.

If we are legally compelled to disclose your Personal Information to a third party, we will attempt (if permitted by law) to notify you at the e-mail address in our records (if any). MicroLumen reserves the right to release Personal Information collected through the Services to law enforcement or other government officials, as we deem necessary or appropriate in our sole discretion.

With your consent or at your direction

We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

Business transfers

We may sell or purchase assets during the normal course of our business. If another company acquires MicroLumen, or if any bankruptcy or reorganization proceeding is brought by or against MicroLumen, your Personal Information may be a MicroLumen asset that can be sold or transferred. Please note that an entity receiving such information in connection with one of these transactions may not comply with all of the terms of this Privacy Policy.

If you access Social Networks through the Services to log in to the Services or to share information about your experience on the Services with others, these Social Networks may be able to collect Personal Information about you, including information about your activity on the Services, and they may notify your connections on the Social Networks about your use of the Services, in accordance with their own privacy policies.

When you use the Services, you could be directed to other websites, applications or services (together with Social Networks, referred to as “Third-Party Sites”), for example, by “clicking” on banner advertisements, links from advertisers, sponsors and marketing partners (including those who may advertise the Services as part of a Co-Branding Service).

MicroLumen has no control over, and therefore no responsibility for, the data collection and privacy practices of Third-Party Sites, which may use Cookies, pixel tags and other technologies to serve and offer relevant ads. When you visit such Third-Party Sites, you are bound by their privacy policies, which you should review to understand their information practices.

Of course, if you choose to engage in public activities relating to the Services on any Third-Party Sites, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing Personal Information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

Aggregate, anonymous, or deidentified information

We may share aggregate, anonymous, or deidentified information with third parties without restriction, including for their marketing or analytics uses.

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How do we protect your information?

Technical and administrative safeguards

MicroLumen uses Secure Socket Layer (“SSL”) technology to encrypt or scramble billing information (if any) and other Personal Information during transmission. In addition, we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems, and we restrict access to Personal Information to MicroLumen personnel and agents who need to know that information in order to process it for MicroLumen, and who are subject to strict contractual confidentiality obligations and appropriate consequences for failing to meet such obligations. Please be aware that, despite our efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.

User precautions

Again, no system or online transmission of data can be guaranteed to be 100% secure and you should always take appropriate steps to protect your Personal Information, including updated antivirus and anti-malware software and strong and confidential passwords. In the interest of protecting your account security, MicroLumen recommends that you change your password on a regular basis and immediately if you suspect that your account security has been jeopardized.

How long do we keep your information?

We will keep Personal Information as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. If you believe that your MicroLumen account or any information you provided to us is no longer secure, please notify us immediately through the Contact Us information provided below.

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What are your choices?

You may opt out of receiving general and marketing e-mails via the “unsubscribe” link in such e-mails or by e-mailing us at privacy@microlumen.com. You may still receive transactional messages. You may also request that we delete your Personal Information by sending us an e-mail at privacy@microlumen.com, and MicroLumen will attempt to comply with your request, unless MicroLumen needs to keep that information for legitimate business or legal purposes. For your protection, when you seek to access or change your Personal Information, MicroLumen may require you to verify your identity before MicroLumen can act on such request.

Your instructions to MicroLumen to limit the use of your Personal Information for these purposes will be processed as soon as reasonably practicable. Please note that MicroLumen is not responsible for informing third parties (including without limitation our Service Providers or Business Partners) with whom we have already shared your Personal Information of such changes or for removing or causing removal of your Personal Information from the databases of such entities.

In addition, you may set your browser to block all Cookies, including Cookies associated with the Services, or to indicate when a Cookie is being set by us. Consult the instructions provided by your web browser (typically in the “help” section). For more information about MicroLumen’s use of Cookies, refer to our Cookie Notice. For general information about Cookies, how to identify, manage and delete them, visit http://allaboutcookies.org.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Visit the following website, http://www.allaboutdnt.org for more information on this developing area.

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Your California privacy rights

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own direct marketing purposes.

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What about children?

MicroLumen does not market to children or knowingly collect, use, or disclose information from children under 16. If we learn that we have collected the Personal Information of a child under 16 — or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States—we will take steps to delete the information as soon as possible. Please contact us immediately if you become aware that a child under 16 has provided us with personal information.

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International

This English-language Privacy Policy is MicroLumen’s official statement of MicroLumen’s privacy practices with respect to the Services. In case of any inconsistency between this English-language Privacy Policy and its translation into any other language, this English-language document will take precedence over such translation.

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How do you contact us?

If you have any questions regarding MicroLumen’s privacy practices, please do not hesitate to contact us as follows:

• Write to us at: MicroLumen, Inc., 1 MicroLumen Way, Oldsmar FL 34677, Attn: Chief Privacy Officer
• E-mail us at: privacy@microlumen.com

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