Main Content

Privacy Policy

Protecting your personal privacy is important to Millennium Communications Inc. (“we,” “us,” or “Millennium”). The purpose of this Privacy Policy is to help you understand how Millennium collects, uses and safeguards the information you provide to us. This Privacy Policy is solely applicable for the website located at http://www.millenniumweb.com (the “Website”).

By using or accessing the Website, you signify your agreement to be bound by this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU MAY NOT ACCESS OR OTHERWISE USE THE WEBSITE.

Privacy Shield Participation

Millennium complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. Millennium has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Millennium is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@millenniumweb.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@millenniumweb.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Millennium commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact Millennium at: privacy@millenniumweb.com

Millennium has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Millennium agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Millennium acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Personally Identifiable Information That We Collect

We will not collect personally identifiable information from you unless you voluntarily provide it to us. The personally identifiable information which you may provide to us could include your complete name and e-mail address for purposes such as posting a comment or applying for a position.

We may collect certain information, not personally identifiable, on our website and in connection with administration of promotions. We may collect information about your computer configuration such as your browser type, operating system, or ISP domain name. We may collect information about the site you last visited prior to the Promotion or about your activity during your visit to the Promotion site. We may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, YouTube, Google or Twitter. By using these services, you allow Millennium to access the available information from your third-party social network profile such as your name, age, gender, location, email address and list of friends. This information may be used by Millennium to administer the technical and operational aspects of the site, and may include using your IP address to help diagnose problems with our server. Your IP address may also be used to gather broad demographic information for aggregate use. This enables us to safeguard the promotion and diagnose problems in the operation of a promotion.

Non-Personal or Aggregate Information That We Collect

When you access the Website, we may automatically collect non-personally identifiable information from you, such as IP address, web pages viewed, browser type, referring service, usage and browsing habits on the Website, and similar data. We may also aggregate demographic information collected from our users (such as the number of users in a particular state) in a manner which does not identify any one individual.

Information Use

We strictly limit access to all personally identifiable information within our organization, and data is never shared outside of the company for any reason whatsoever (with, of course, the exception of the Promotion client, appropriate governmental or legal requests). We shall ensure that any third party for which Personal Information may be disclosed agree in writing to handle the data under the same level of protection as set forth in this policy.

We do not sell your personal information to third parties.

We will only use your personally identifiable information as described below, unless you have specifically consented to another type of use, either at the time the personally identifiable information is collected from you or through some other form of consent from you or notification to you:

We may use your personally identifiable information to respond to your inquiries or requests.

We may use your personally identifiable information to send emails from time to time, but we will not provide your personally identifiable information to third parties for them to contact you directly unless otherwise permitted by this Privacy Policy or if you provide your consent.

We may permit our vendors and subcontractors, such as our Promotional Administration partners, to access your personally identifiable information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

We may disclose personally identifiable information as required by law or legal process.

We may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services or our sponsors.

We may transfer your personally identifiable information in connection with the sale or merger or change of control of the Website, Millennium or the division responsible for the services with which your personally identifiable information is associated.

Non-personally identifiable or aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you.

Millennium’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Millennium remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Millennium proves that it is not responsible for the event giving rise to the damage.

Use of Cookies

We may also use cookies, and you must provide consent for the use of cookies on any Millennium hosted site which uses them. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A session cookie might be used to track a user through a multi-page registration process so they would not have to reenter information multiple times during the registration process. A persistent cookie remains on your hard drive for an extended period of time. For example, we may set a persistent cookie for a day to prevent a user from returning to a site and trying to enter a Sweepstakes more than once a day. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. Each browser has a function which enables the user to disable cookies if so desired, but in that case, the participant may not be able to participate fully in a promotion, and certain aspects of our site may be limited. We also gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, track users’ movements and to gather demographic information about the user base of both our client’s promotions and our website. We do not link this automatically-collected data to personally identifiable information.

In addition to our own methods of anonymous data collection, our clients may use other types of tracking technologies. Unless otherwise stated, the use of cookies and other tracking technologies by our clients for the purpose of administering a promotion is not covered by our privacy policy. We do not have access or control over these cookies.

Security

The security of your personally identifiable information is very important to us. When we collect your personally identifiable information, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the Internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers and your use of the Website demonstrates your assumption of this risk.

Your Disclosures in Blogs and Other Social Media

You should be aware that personally identifiable information which you voluntarily include and transmit online in a publicly accessible blog, social media platform or otherwise may be viewed and used by others without any restrictions. We are unable to control such uses of your personally identifiable information, and by using such services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties for any number of purposes.

User Content

Any User Content (as defined in the Terms of Use) will be considered non-confidential and non-proprietary. See the Terms of Use for additional details. Children.

We do not intentionally collect personally identifiable information from children under the age of 13. When we become aware that personally identifiable information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database.

Transfer of Personally Identifiable Information into the USA

Our servers are maintained in the United States of America. By using the Website or participating in the services, you freely and specifically give us your consent to export your personally identifiable information to the USA and to store and use it in the USA as specified in this Privacy Policy.

Other Services

As a convenience to you, the Website may contain links and/or embedded access to third-party websites not owned or controlled by Millennium. We are not responsible for the privacy practices or content of these third-party websites. When you use such third-party websites, you do so at your own risk.

Changes to this Privacy Policy

We reserve the right, at our discretion, to change, modify, add or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personally identifiable information in a way that materially differs from this Privacy Policy, including sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the Website following the posting of any changes to this Privacy Policy means you accept such changes.

Website Terms of Use

Use of the Website is governed by and subject to the Terms of Use contained at www.millenniumweb.com. This Privacy Policy is incorporated into such Terms of Use.

Contact Information

Should you have any questions, you may contact us at nudge@millenniumweb.com.

Effective Date

This Privacy Policy was last updated on August 21, 2019