Last Updated: March, 14, 2022

Milestone Technologies, Inc. is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy (“Privacy Statement”) describes our practices regarding the use, maintenance, and disclosure of your Personal Data that we collect through our Website and services (“Services”). We respect the privacy of your Personal Data and undertake to ensure that the data you provide us with will be treated only in the manner described in this Privacy Statement. 

Whenever the Privacy Statement mentions the terms “Milestone” or “we” or “us” or “our”, it refers to Milestone Technologies, a Company with its principal place of business at 3101 Skyway Court, Fremont, CA 94539, which is responsible for your Personal Data under this Privacy Statement.

We conduct our business in compliance with applicable laws and shall collect, use, and process your Personal Data only in accordance with applicable data protection and security laws, regulations, and guidelines. 

We urge you to read this Privacy Statement thoroughly. By accessing and using our Website, you will have represented your agreement to this Privacy Statement and bound by its terms. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your Personal Data or interact with the Website.

• Scope of the Privacy Statement
• To make our Services accessible to you and to administer and manage your relationship with us, we will necessarily need to collect, use, disclose and/or process your information and Personal Data, to which you consent by agreeing to this Privacy Statement. 
• For the purpose of this Privacy Statement, the term Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
• Our privacy and security practices in connection with the access and use of our Services are governed by the Terms of Use agreement, which is a binding contract between you and us and incorporated herein by reference. 
• Our Privacy Statement does not apply to services offered by other companies, third-party service providers, or individuals, including products or sites that may be displayed in search results or other sites linked from our Services. Therefore, you should consider the privacy practices of those third-parties carefully.

Collection of your Personal Data 

We collect the information you provide us directly or automatically when you use the Services. The collection of your Personal Data shall be strictly restricted to what is necessary for fulfilling the purposes identified hereinbelow. We may collect and retain the following Personal Data from and about you if you interact with us through the Services;

• Your Personal Data, such as but not limited to your Name, E-mail Address, Company Name, Telephone Number, Your Role/Occupation, and how you heard about us.
• When you use or visit our Services, we may collect information about your computer hardware and software. This information can include your IP address, web browser type, web browser version, internet service provider, site trends, location, referring URL, timestamp information, app packages, app names, URLs, email address, poll inputs, and the operating system that your computer or device is running. This information is used by Milestone for service operation, maintaining quality service, and providing general statistics regarding the use of the Milestone website.
• Any information entered by you when you interact with the Services or our personnel for any purpose, including but not limited to reporting a problem with or difficulty using our Services or for providing feedback. 
• Any information that we ask for and may collect from various sources, which may include but are not limited to, information you voluntarily provide us at any events, seminars, conferences, talks, promotions, surveys organized by us, and/or information we collect when you submit web forms on our Services or if you use interactive features of our Services.
• Please keep in mind that if you directly disclose Personal Data through Milestone’s public message boards, others may observe and use this information.

Use of your Personal Data

We use the Personal Data and information collected from you or other sources  or that you provide to us for the purpose of fulfillment of our obligations under our agreement with you and to comply with our statutory legal obligations. Without prejudice to the above, enumerated hereunder is a non-exhaustive list of the purposes for which your Personal Data may be used/processed;

• To operate the Milestone website and deliver the services you have requested;
• To inform you of other products or services available from Milestone and its affiliates;
• To contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered;
• To provide you with information that you may request from time to time;
• To send promotional emails about new products, special offers or other information which we think you may find interesting; 
• To maintain, operate and improve the Services;
• Contact you to ensure that the information we have in our records is accurate or when in need of additional information to complete your profile;
• To facilitate communication and improve our business relationship with you and to respond to your queries, requests, or complaints and/or resolve any issues and disputes which may arise in connection with any dealings with us;
• Create our own internal statistical for in-house analytical purposes;
• Prevent activity we determine to be potentially illegal; enforce this Privacy Statement and/or our Terms of Use or any other purpose referenced herein or therein;
• To control and monitor and ensure compliance with security arrangements and policies adopted by us, and also to ensure their compliance with the law and other regulatory obligations; 
• To comply with any request or direction or lawfully disclose information required by any applicable law, regulation, direction, court order, bylaw, guidance, circular, or code applicable to us; 
• To monitor and identify areas of our Services which may need improvement; 
• To investigate, detect and prevent any fraudulent transaction, unauthorized access to the services, and prohibited or illegal activity or omission or misconduct; 
• We may use information for the security of our company, customers, employees or our Services;
• We shall not use your Personal Data for any purpose other than its intended purpose. We may use your Personal Data for purposes not stated hereinabove but only with your express or implied prior consent for such use. 

Disclosure/ Sharing of your Personal Data

Milestone does not sell, rent or lease your Personal Data to third parties without your consent. However, Milestone may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your Personal Data is not transferred to a third party. In addition, Milestone may share your Personal Data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. Third parties are prohibited from using your Personal Data except to provide these services to Milestone, and they are required to maintain the confidentiality of your information.

Milestone does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

We may disclose your Personal Data to third-party recipients for the purposes described above, including: (i) To third parties whom we engage to provide services or benefits to you or us, such as professional advisers, auditors, insurers, and outsourced service providers (e.g., payroll services providers, health insurers and pension trustees); (ii) To other members of our group or affiliates; (iii) To third parties, their agents and professional advisers, subject to confidentiality obligations, for the purpose of a due diligence exercise by third parties in connection with any proposed merger, acquisition, reorganization or transfer of our business and to any person proposing to participate in, or promote, underwrite, or manage any such arrangement; (iv) To competent regulatory authorities and other bodies as requested or required by law; provided that all third parties listed at (i) to (iv) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Privacy Statement.

We may, with your prior and expressed consent, share Personal Data for reasons not described in this Privacy Statement with third parties.

Use of Cookies and Other Tracking Technologies

The Milestone website uses “cookies” to help personalize your online experience. A cookie is a text file placed on your hard disk by a web page server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Milestone pages or register with the Milestone site or services, cookies help Milestone recall your specific information on subsequent visits. Cookies also simplify the process of recording your Personal Data, such as billing address and shipping address, for example. When you return to the Milestone website, cookies can retrieve the previously provided information to use the Milestone features you customized efficiently.

Milestone tracks the pages you visit through cookies (see below) to determine what Milestone services are the most popular. We use this data to deliver customized content and advertising within Milestone to you whose behavior indicates that they are interested in a particular subject area.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies; however, you can usually modify your browser setting to decline cookies. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Milestone services or Web sites you visit.

Transfer of your Personal Data

We may send the information we collect to servers located in the United States and/or other countries around the world. Therefore, by interacting with and using the Services, you understand that we may transfer your Personal Data to such countries, and you consent to such transfer. 

We do not transfer your Personal Data to third parties unless it is necessary to fulfill our obligations to you and permitted by law. We shall make appropriate arrangements to ensure that your data is processed securely and complies with applicable data protection laws specific to your country.

Security of your Personal Data

We maintain appropriate technical and organizational security measures in accordance with applicable laws and regulations and industry standards to protect your Personal Data from unauthorized access, use, or disclosure. Milestone secures the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. 

The nature of the internet is such that Milestone cannot guarantee the security of any information you transmit to us online. However, Milestone takes all steps required by applicable law (including appropriate technical and organizational security measures) to protect your Personal Data.

Access to your Personal Data is allowed to only a restricted number of our personnel. All our employees and intermediaries, who have access to and process your Personal Data, are trained in handling Personal Data and are required to respect the confidentiality of your Personal Data. 

You agree that any security breaches beyond our reasonable control are at your sole risk and discretion. We cannot and do not accept responsibility for the same. If you have any questions about our security arrangements, please contact us at the contact details provided herein.

Retention of your Personal Data

Milestone will only retain your Personal Data for as long as necessary to fulfill the purposes for which Milestone collected it.

Milestone’s retention periods differ depending on the type of categories of Personal Data. To determine the appropriate retention period for Personal Data, Milestone takes into account various criteria, including considering the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which Milestone processes your Personal Data and whether Milestone can achieve those purposes through other means, the impact on our Services we provide to you if we delete some of your information and the applicable legal requirements such as mandatory retention periods. In general, Milestone will hold your Personal Data for the duration of our relationship with you and for a period of time after as necessary to comply with our legal and regulatory obligations under applicable law and, if relevant, to deal with any complaint or dispute that might arise between us.

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

Personal Data of Minors

We do not consciously collect Personal Data from minors (i.e., individuals under 13 years of age or any such age as required in your country for you to be authorized to use our Services) and respect the privacy of minors who may inadvertently use our Services and provide us with Personal Data. Therefore, if you are a minor, do not submit any Personal Data to us. If you are a parent or a guardian, we strongly recommend you supervise the online activity of your minor children and ensure that your children do not disclose any Personal Data. If you believe that we may have unknowingly collected Personal Data from minors without parental consent, please contact us at the contact details provided below so that we may adopt immediate measures to remove the information from our servers.

Links to other Websites

This website may contain links to third-party websites. Such websites are not under Milestone’s control. Milestone encourages you to review the privacy statements of websites you choose to link to from Milestone to understand how those websites collect, use and share your information. However, Milestone is not responsible for how those websites may use your Personal Data or for the privacy statements or other content on websites outside of the Milestone and Milestone family of websites.

Additional Terms for California Residents 

These additional terms shall apply to residents of California. Milestone shall handle your Personal Data in consonance with the California Consumer Privacy Act (CCPA). We will not, without your consent, disclose your Personal Data. You hereby give us consent to disclose your Personal Data for business purposes. You consent to and agree to direct us to and/or use the Services to disclose Personal Data or interact with a third party intentionally. 

We will not, without your consent, sell or disclose your Personal Data for valuable consideration. If you have given us your Personal Data, we have not sold or disclosed it for valuable consideration in the twelve (12) months immediately preceding the last update of this Privacy Statement.

You consent and agree that we may disclose the following categories of such Personal Data of consumers (“Consumer” or “Consumers”; as defined under the CCPA) in the 12 months immediately preceding the last update of this Privacy Statement: 

• • Identifiers such as your name, email address, etc.; 
  • Geolocation data such as the location of a Consumer’s device or computer, etc.;
  • Internet or other electronic network information; 
  • Professional or employment-related information;
  • Inferences drawn from any of the above information.
  • As a resident of California, you have certain additional rights concerning your Personal Data:
    • Right to access. You have a right to and are allowed access to the data we collect and process. 
    • Right to deletion. You have a right to request the deletion of your Personal Data. This right is a subjective right; we may not comply with a data deletion request if we are permitted and/or  required under law. 
    • Right to disclosure. You have a right to request disclosure of the categories of Personal Data collected, sources from which Personal Data is collected, purpose of collecting Personal Data, categories of third parties with whom Personal Data is shared. 
    • You have a right not to be discriminated against for exercising certain rights under California law. 
  • You may exercise your rights by contacting us at the contact details provided below.  

• • Additional Terms for European Union Citizens

• • • • These additional terms shall apply only to residents in the European Union (“EU”). We ensure that the data we collect, store, use, and process comply with the General Data Protection Regulation (“GDPR”). Therefore, elucidated hereunder are additional terms applicable to citizens of the EU.

Legal basis for processing your Personal Data: If you are an EU citizen, we process Personal Data only for purposes for which we collect it. We shall process data only if we have your consent or if the processing is necessary for complying with our legal obligations or where the processing is in our legitimate interest. Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place. If you need further clarification concerning the legal basis on which we collect and use your Personal Data, you may contact us at the contact information provided below.

• • • Residents of the  have certain additional rights in relation to their Personal Data under the GDPR:
      • Right to access. You have a right to and are allowed access to your Personal Data that is processed. 
      • Right to erasure. You may request the erasure of your Personal Data only under certain circumstances, which include but are not limited to unlawful processing of your data if your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed or if you withdraw your consent, etc.  However, we may need to retain certain information to comply with our legal obligations. 
      • Right to rectification. You may at any time request for rectification of the Personal Data that we process. You may also complete Personal Data if it is incomplete. 
      • Right to restriction of processing. You have a right to restrict the processing of Personal Data if you contest the accuracy of the data, lawfulness of processing,  if you have an objection to the processing of the data, or if the data is no longer needed for the purpose of processing. We will inform you when such restrictions are lifted.  
      • Right to data portability. You have a right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format. You are also entitled to the right to transmit your Personal Data from one controller to another where it is technically feasible.
      • Right to object. You have a right to object to the processing of your Personal Data. You have a right to object where your Personal Data is processed for marketing purposes. 

You may exercise any of the above rights by contacting us at the contact details provided herein.  

Transfer of Personal Data: Please note that you are signifying consent to transfer your Personal Data outside the EU. Such transfer to which you hereby consent is primarily for processing, whereby we ensure adequate protection through a series of agreements with our service providers.

• • • Additional Terms for United Kingdom Citizens

• • These additional terms shall apply to residents of the United Kingdom (UK). Milestone shall collect, use, store and process your Personal Data only in accordance with the Data Protection Act 2018 and other regulations and guidelines on data privacy protection and data security. Therefore, elucidated hereunder are rights available to persons in the UK: 
    • Right to access. You have a right to and are allowed access to your Personal Data that is processed. 
    • Right to erasure. You may request the erasure of your Personal Data only under certain circumstances which include, but are not limited to, unlawful processing of your data if your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or if you withdraw your consent, etc. However, that we may need to retain certain information to comply with our legal obligations. 
    • Right to rectification. You may, at any time, request for rectification of your Personal Data that we process. You may also complete Personal Data if it is incomplete. 
    • Right to restriction of processing. You have a right to restrict the processing of Personal Data if you contest the accuracy of the data, lawfulness of processing and or if you have objected to processing of data or if the data is no longer needed for the purpose of processing. We will inform you when such restrictions are lifted.
    • Right to data portability. You have a right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format. You are also entitled to the right to transmit your Personal Data from one  controller to another where it is technically feasible.
    • Right to object. You have a right to object to the processing of your Personal Data.

You may exercise any of the above rights by contacting us at the contact details provided herein. In exercise of your rights, you may be required to provide us with sufficient information to confirm your identity, which shall include but shall not be limited to your full name, address, username, or registration details. In addition, you will be required to confirm the right you wish to exercise and the Personal Data to which your request relates. 

• • • Additional Terms for Singapore Citizens
    • These additional terms shall apply to residents of Singapore. Milestone shall collect, use, store, and process your Personal Data in accordance with the Personal Data Protection Act 2012 (“PDPA”). Details of our obligations, your rights, and other essential provisions are set out hereinbelow. 
    • Accuracy of your Personal Data: We will make all reasonable efforts to ensure that the Personal Data we collect is accurate, complete and up-to-date. We shall adopt methods to verify and authenticate information provided by you. We shall make sure that any changes made or requested are updated in our records. We rely on the information you provide for performing our obligations/Channels to you; you are required to provide us accurate and complete information and promptly update us in if there are any changes to your Personal Data.
    • Your Rights 
      • You shall, to the extent that the applicable law allows, have the right to request access to your Personal Data. 
      • You have a right to request correction or rectification of your Personal Data entrusted to us or update your Personal Data held by us.
      • You have a right to request limited processing and use of your Personal Data. 
      • You may, by giving notice, withdraw any consent given to us for the collection, use, or disclosure of your Personal Data. Upon receipt of such notice, we shall  inform you of the repercussions of withdrawing your consent. We may not allow withdrawal of consent in circumstances where it is required or authorized under this Act or any other written law. It is essential to note that your withdrawal of consent could result in legal consequences arising from such withdrawal. 

You may exercise any of the above rights by contacting us at the contact details provided herein. 

Transfer of Personal Data Outside Singapore: In fulfilling our obligations to you, it may become necessary to transfer data that we collect from you to jurisdictions outside Singapore for processing and storing. By providing information to us, you are consenting to the transfer, storing, and processing of that information outside Singapore in accordance with the terms of this Privacy Statement.

Changes to this Privacy Statement

Milestone may periodically update this Privacy Statement to reflect any changes in the processing of your Personal Data. Where material changes are made to this Privacy Statement, we will post a prominent notice on our website indicating that we have updated the Privacy Statement and will indicate when it was last updated at the top of the Privacy Statement. Therefore, you are requested to check our Website periodically for such updates. If you access our Services after a notice of change has been published on our page, you hereby agree to provide acknowledgment and consent to the changed terms.  

Dispute Resolution 

Milestone welcomes your comments regarding our Privacy Statement. If you believe that we have not adhered to this Privacy Statement, you may convey the same to us by contacting us in the manner mentioned below. Please describe how Milestone has not complied with its Privacy Statement in as much detail as possible in your email. Any disputes arising under this Privacy Statement shall be governed by the laws referenced herein. 

Timeframe for Processing User Requests

Upon receiving a request for the exercise of any of the rights stated under this Privacy Statement, we shall make best efforts to respond to and resolve the same without undue delay within thirty (30) days of its receipt. If the requests are complex or numerous, we may extend the thirty (30) day period by giving you notice. We reserve the right to charge you an administrative fee to process your request; we shall notify you of such a fee before proceeding with your request. 

Contact Information

If you have questions regarding this Privacy Statement or about our privacy practices, feel free to contact us at: 

Attn:

Anish Pandey

Data Protection Officer 

Milestone Technologies, Inc.

3101 Skyway Court

Fremont, CA 94539

privacy@milestone.tech