Effective Date: July 25, 2018.
Your privacy is critically important to us. At C.Miller & Co., we live by a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim for full transparency on how we gather, use, and share your personal information.
What This Policy Covers
- Our websites (including cmillerco.com);
- Our mobile applications (including the nico mobile app for iOS); and
- Our other products and services that are available on or through our websites.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a nico account to provide a username and email address–and that’s it. You may provide us with more information–like your name–but we don’t require that information to create nico account.
- Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a nico account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that–public–so please keep that in mind when deciding what information you would like to include.
- Transaction and Billing Information: If you buy something from us–a subscription to a nico plan for example–you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
- Communications With Us (Hi There!): You may also provide us information when you respond to surveys, communicate with our support team about a support question, or post a question in our public forums.
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
- Usage Information: We collect information about what happens when you use our Services (e.g., page views, support document searches) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored Information: We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing selfie to your public profile.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your nico account through another service (like Google) or if you connect our nico app to a social media service (like Twitter) through our sharing features, we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
How And Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services–for example, to set up and maintain your account, backup and restore your nico data, or charge you for any of our paid Services;
- To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to use our apps and websites more efficiently;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of C.Miller & Co. and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example through an email, about offers and promotions offered by C.Miller & Co. and others we think will be of interest to you, solicit your feedback, or keep you up to date on C.Miller & Co. and our products; and
- To personalize your experience using our Services, provide content recommendations, and target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time.)
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
How We Share Information
We do not sell our users’ private personal information.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of C.Miller & Co., third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as the social media services that you connect to the nico app through our sharing features.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
- Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
Information Shared Publicly
Information that you choose to make public is–you guessed it–disclosed publicly.
That means, of course, that information like your public profile or other content that you make public through our websites or apps are all available to others; For example, the photo that you upload to your public profile, or any bio information you provide, may be seen by others.
Public information may also be indexed by search engines or used by third parties.
Please keep all of this in mind when deciding what you would like to share.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it.
For example, we keep the web server logs that record information about a visitor to one of C.Miller & Co. websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to C.Miller & Co.'s websites and investigate issues if something goes wrong on one of our websites.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services–for example, paid plans–may not be accessible.
- Limit Access to Information On Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location to a photograph, for example).
- Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
- Set Your Browser to Reject Cookies: At this time, C.Miller & Co. does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using C.Miller & Co.’s websites, with the drawback that certain features of C.Miller & Co.’s websites may not function properly without the aid of cookies.
- Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can close your accounts or stop using our apps :(. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
If you would like to contact us about one of your rights, scroll down to How to Reach Us to, well, find out how to reach us.
EU individuals also have the right to make a complaint to a government supervisory authority.
How to Reach Us
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That’s it! Thanks for reading.
- July 25, 2018: First Publication
This document was adapted from Automattic's