Privacy Policy

Effective Date: October 2, 2023

This privacy policy (the “Privacy Policy”) explains the collection, use, and disclosure practices of the websites, mobile applications, and other online and offline products and services (collectively, the “Services”) owned and operated by Milestones Labs, Inc. (“Milestones,” “we,” “us,” or “our”). This Privacy Policy also describes how we collect and use information when you access and use our websites (the “Site”). Please be advised that the practices described in this Privacy Policy also apply to information that you submit to us offline and to Personal Information (as described below) that we may collect from third parties. By using our Site or submitting information to us, you acknowledge and understand the terms of our Privacy Policy and are giving express consent to our Terms of Service.

COLLECTION & USE OF YOUR PERSONAL INFORMATION

As used in this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, reasonably can be linked, directly or indirectly, with an individual or household, or as otherwise defined under applicable law. We collect Personal Information from various sources including:

directly from you;
automatically from the use of our Services;
from affiliated and unaffiliated third parties;

The types of Personal Information we collect about you depend on your interactions with us and are described in more detail below.

Information We Collect Directly from You. We collect information directly from you in a variety of ways. Any information you provide to us is voluntary, but please note that some information may be necessary for us to provide you with our Services. The categories of Personal Information we collect directly from you include:

Identifiers, such as your property address and property-related information, first name, last name, phone number, email address, and mailing address;
Information you provide on our Site to request Services, for example, your username, password, location, zip/postal code, mailing address, fax number, and email address;
Any financial information necessary to provide our Services;
Feedback you provide to us about our Services, including in response to surveys or through our customer service centers;
Browsing information.

Information Automatically Collected from Your Use of the Site. We may automatically collect information about you from your use of our Services, including by using website analytics tools or other technologies, like cookies and web beacons (which are described in more detail below).The categories and types of information we collect automatically from your use of the Services include:

Identifiers, such as your IP address and unique device identifiers;
Internet or other electronic network activity information, such as the type of browser you use, app version, access dates and times, pages viewed, and the page you visited before navigating to our Site;
Geolocation data;
Other information that relates to or is capable of being associated with you, such as information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, and mobile network information.

Cookies are small text files that are stored on your computer when you visit certain online pages that record your preferences. We use cookies to track use of our Site and other Services. We may also use cookies to monitor traffic, improve the Site, make the Site easier and/or relevant for your use, and improve the performance of our advertising on other websites. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. However, certain features of our Site or other Services may not work if you delete or disable cookies.

INFORMATION WE COLLECT FROM OTHER SOURCES

We may collect information about you from other sources. For example, we may collect information about you from:

Third-party social media services, such as Facebook, Twitter, and Instagram, that you use to interact with our Services (e.g., to provide feedback on our Services) or that allow you to share information (e.g., via plugins, widgets, or other tools);
Unaffiliated parties, such as our service providers, analytics companies, advertising networks, affiliates, and other third parties that provide us with information, so we can better understand you and provide you with information that may be of interest to you.

SMS AND TEXT MESSAGE COMMUNICATIONS

SMS Opt-In and Consent. We only send SMS or text messages to users who have affirmatively opted in through clear and conspicuous consent mechanisms. Consent to receive SMS messages is not a condition of purchase or use of our Services.

SMS AND TEXT MESSAGE COMMUNICATIONS

Information We Collect for SMS. When you opt in to SMS communications, we may collect your mobile phone number, message delivery and interaction data, and event triggers related to your account activity (e.g., lead submissions, hub activity).

How We Use SMS Data. We use SMS-related data to deliver account notifications and alerts, send real-time lead or inquiry notifications, provide service-related updates, and improve service reliability and messaging relevance. We may send promotional messages only if you separately opt in to receive them.

No Sale of SMS Data. We do not sell or share mobile phone numbers or SMS data to third parties for their marketing purposes.

Opt-Out. You may opt out of SMS messages at any time by replying STOP to any message. You may also request help by replying HELP. Opt-out requests are honored promptly.

INFORMATION SHARED WITH COLLABORATORS

We provide online workspaces, or “hubs,” for you to access and share information, interact with resources and tools, and communicate with industry professionals. Each hub is private and secure, accessible via login and password. Individuals with access to each hub are collectively referred to as “hub members.” By joining a hub, you acknowledge that information contained therein may be accessible to other hub members – including files, property information, transaction history, written communication, professional services, and other Personal Information. Hub members should not include any Personal Information that do not wish to be viewed by other Hub Members. By inviting others to join a hub, you acknowledge that you are opting to share information within the hub with them.

INFORMATION SHARED WITH COLLABORATORS

USE OF YOUR INFORMATION

For each category of Personal Information we collect about you, we use such category of Personal Information for the business and commercial purposes set forth below:

To provide you the Services and otherwise complete the transactions you request, perform our contractual obligations, and as otherwise anticipated within the context of our ongoing business relationship;
Create and manage your online accounts;
Communicate with you, including by telephone, text, email, and chat, regarding your use of the Services;
Respond to your requests and any other communications from you, including providing customer service;
Send advertising or marketing communications about products, services, offers, promotions, rewards, and events offered by us and provide news and information that we believe may be of interest to you;
Offer and administer surveys, contests, prize draws, sweepstakes, and other promotions;
Conduct internal research and development;
Analyze your engagement with us and your use of our Services to better understand your interests and behaviors and customize your experience;
Detect security incidents and protect against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, and breach of contract, and to protect against harm to the rights, property, or safety of us and our users, customers, employees, or the public;
Debug, identify, and repair errors that impair the functionality of our Services;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our business;
Comply with our legal obligations, including our tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law or any regulatory requirements or provisions;
With our legal, financial, insurance, and other advisors in connection with the kinds of transactions described above or in connection with the management of all or part of our business or operations.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your Personal Information as follows:

To Our Service Providers. We may share Personal Information with one or more service providers with which we have contracted to provide services to us or to offer the Services you have requested from us.

To Affiliated Companies. We may share your Personal Information with other companies under common control with us.

For Our Internal Analyses and Operations. We may share Personal Information with third-party vendors for our own internal statistical, design, or operational purposes, such as estimating our audience size, measuring aggregate traffic patterns, and understanding demographic trends among our users. The use and disclosure of your Personal Information by these other parties is restricted to the performance of such tasks and is subject to confidentiality.

For Legal and Other Compliance. We may share Personal Information when we believe it is appropriate for the following purposes (a) to comply with legal process or applicable law; (b) to enforce or apply this Privacy Policy or our other policies or agreements; (c) protect the rights, property, or safety of ourselves, our users, and the public; (d) to protect our users from fraudulent, abusive, or unlawful use of our Site; (e) to enable us to detect or prevent fraud, material misrepresentation, or criminal activity; (f) to law enforcement or authorities in conjunction with an investigation, or in response to a subpoena or court order; or (g) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

As Part of Business Transfers. We may share Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction.

As Aggregated, Anonymized Information.We may share aggregated, anonymous, or de-identified information to our advertisers, business partners, and other third parties that cannot reasonably be used by those third parties to identify you.

To Affiliated Companies. We may share your Personal Information with other companies under common control with us.

As Part of Business Transfers. We may share Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction.

To Third Parties With Your Authorization. We may disclose your information to third parties for whom you have given us authorization or consent to make such disclosure.

Sale of Personal Information. We do not sell Personal Information as defined under the California Consumer Privacy Act (CCPA) or other applicable state privacy laws.

LINKS TO THIRD PARTIES

We may provide links to third-party websites from our Site as a service to our users. We have no ability to control nor are we responsible for the privacy and data collection, use, and disclosure practices of any third-party websites, including those we may link to from our Site. When you click on links that take you to external websites, you will be subject to their privacy policies and practices and not ours. We strongly encourage you to review and understand the privacy policies and terms of use of any website that you visit.

SECURITY

We are committed to protecting the security of your Personal Information. We use technical, administrative and physical security measures designed to protect your Personal Information from unauthorized access, use, or disclosure.

CHILDREN

Our Services are designed for adults, not children under the age of 16. As such, we do not knowingly collect Personal Information from children under the age of 16, and our Services are not designed for such information.

FOR COLORADO RESIDENTS: For additional information about your Colorado consumer privacy rights, or to make a consumer privacy request, please email privacy@milestones.ai.

FOR CONNECTICUT RESIDENTS: For additional information about your Connecticut consumer privacy rights, or to make a consumer privacy request, please email privacy@milestones.ai.

FOR NEVADA RESIDENTS: We are providing this notice pursuant to state law. You may be placed on our internal Do Not Call List by emailing privacy@milestones.ai or by contacting us via the information set forth at the end of this Privacy Notice. For further information concerning Nevada’s telephone solicitation law, you may contact: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: (702) 486-3132; email: aginquiries@ag.state.nv.us.

FOR OREGON RESIDENTS: We will not share your Personal Information or Browsing Information with nonaffiliated third parties for marketing purposes, except after you have been informed by us of such sharing and had an opportunity to indicate that you do not want a disclosure made for marketing purposes.

FOR VERMONT RESIDENTS: We will not disclose information about your creditworthiness to our affiliates and will not disclose your Personal Information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

FOR VIRGINIA RESIDENTS: For additional information about your Virginia privacy rights, please email privacy@milestones.ai.

CONTROLLING YOUR PERSONAL INFORMATION

You have the right to submit a complaint or to object to the collection and use of your information by us at any time or to require us to review, transmit, change, or delete your information that we have collected and retained. We will respond to your request to exercise any of these rights after receiving a complete request, with the exception of information that is needed to complete the transaction for which the Personal Information was collected, to provide the information you have requested from us, as allowed or authorized by law, or that is reasonably anticipated within the context of our ongoing business relationship with you. You can exercise these rights by contacting us at:

Email: privacy@milestones.ai

Mailing Address: Milestones Labs, Inc. 925 Capital of Tx Hwy, Bldg. A, Suite 100, Austin, TX 78746

PRIVACY NOTICE FOR CALIFORNIA CONSUMERS

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. This California Privacy Notice is part of the Privacy Policy, and it may be updated on the same terms and in the same manner as the Privacy Policy. If you have any questions about the California Privacy Notice, please contact us using the contact information set forth in the Privacy Policy.

Categories of Personal Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, our website has collected the following categories of Personal Information from its consumers in the preceding twelve (12) months:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Name, Email, Address, Telephone Number
	Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.
	Physical location or movements.
F. Internet or other similar network activity		Internet or other electronic network activity information, such as the type of browser you use, app version, access dates and times, pages viewed, and the page you visited before navigating to our Site
G. Geolocation data		Location of Property, IP address

Sources for the Collection of Personal Information

We obtain the categories of Personal Information listed above from the following sources:

Directly from you. For example, from forms you complete, or products and services you purchase.
Indirectly from you. For example, information we receive from the use of our website.
Information we receive directly from you related to doing business with us.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To market content and product and service offerings relevant to your interests, including directly marketing through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
To respond to law enforcement requests as required by applicable law, court order, governmental regulations, or other legal obligations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we disclosed, and will continue to disclose, the categories of Personal Information listed above for a business purpose. We may disclose the Personal Information to the following categories of third parties for a business purpose:

Service providers and non-affiliated third parties such as internet service providers, data analytics providers, and social networks.
Non-affiliated third parties, with your prior consent.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our website users is among the assets transferred.
Law enforcement or authorities in connection with an investigation, or in response to a subpoena or court order.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold or shared Personal Information. We do not sell or share Personal Information. This includes mobile phone numbers and SMS-related data, which we do not sell or share with third parties for their marketing purposes.

Retention Periods

Due to the breadth and variety of data collected by us, it is not possible for us to provide you with a comprehensive list of timeframes during which we retain each category of Personal Information. We retain categories of information as reasonably necessary to satisfy the purpose for which we collect the information. This time period varies depending on the purpose for which we collected the information, the nature and frequency of our interactions and relationship with you, whether we have a legal basis to continue retaining the information, industry practices, the value and sensitivity of the information, and state and federal recordkeeping requirements.

Personal Information of Minors

We do not knowingly collect the Personal Information of minors. We do not sell or share the information of consumers under 16 years of age.

Sensitive Personal Information

We do no use or disclose sensitive Personal Information for any purposes other than those specified in the CCPA.

Your Rights and Choices under the CCPA

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we provide certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, you have the Right to Know:

The categories of Personal Information we collected about you.
The sources for the Personal Information we collected.
Our purpose for collecting.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information obtained from you, provided in a readily accessible format.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Deletion Request Rights

Right to Correct

You have the right to correct Personal Information you believe to be inaccurate.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Exercising Access, Data Portability, Deletion, and Correction Rights

To exercise the consumer rights described above, please submit a verifiable consumer request to us by either:

Emailing us at privacy@milestones.ai
Calling us at (512) 399-9230
Follow This Link to make a request online.

Only you, or someone legally authorized to act on your behalf such as an authorized agent, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. The CCPA allows a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may use an authorized agent to submit a request. Authorized agent requests will be processes like any other request, but we will also require you to provide the agent’s written permission to make the request and verify the agent’s identity with us.

WEB CONTENT ACCESSIBILITY COMPLIANCE STATEMENT

Milestones Labs, Inc. and its subsidiaries are committed to facilitating the accessibility and usability of all of its websites for all our customers, including people with disabilities. We strive to meet the standards of the World Wide Web Consortium’s Web Content Accessibility Guidelines 2.1 Level AA (WCAG 2.1 AA). Our efforts are ongoing as technology advances.

If at any time you have specific questions or concerns about the accessibility of any particular web page, please contact us at support@milestones.ai. Please be sure to specify the issue, the web site and the web page in your email, and we will make all reasonable efforts to make that page accessible for you.

CHANGES IN THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

QUESTIONS AND CONCERNS

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@milestones.ai