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Privacy Policy

PRIVACY POLICY

Last update: 2021-07-14

1. GENERAL PROVISIONS
1.1. We care about your privacy and the security of your data, so we have developed this Privacy Policy (hereinafter the “Privacy Policy”), which explains how we process and protect your personal data, what your rights we ensure, and provides other information about the processing of your personal data.
1.2. “You” in this Privacy Policy mean the person who visits the Website, uses our App, visits our Social Accounts, contact us via electronic communication channels, apply to the job for us, as well as the person who represents the organization that concludes the contract with.
1.3. In this Privacy Policy, the term “personal data” (hereinafter referred to as “Personal Data”) means any information or set of information by which we may directly or indirectly identify you, such as your name, email address, telephone number, etc.
1.4. We process Personal Data in accordance with the provisions of the General Data Protection Regulation No. 2016/679 (EU) (hereinafter – “GDPR”) and the requirements of the legal acts of the Republic of Lithuania, as well as the instructions of the authorities.
1.5. The Privacy Policy applies when you visit or order goods at the Millo website or e-shop, available at https://getmillo.com/  (hereinafter the “Website”), use our mobile application (hereinafter the “App”), our accounts on Facebook, LinkedIn, Twitter, Youtube and Instagram social networks (hereinafter “Social Accounts”), view the information provided by us, order the goods that we offer, access or exchange information on the Website or the App, contact us by phone, other electronic means, express your interest in our offers and news or apply for other issues.
1.6. Our Website and App may contain links to third party websites, applications, platforms, or social network accounts. This Privacy Policy does not apply to third party websites, applications, or services. Please review their privacy policies before submitting your Personal Data to these third parties. We do not control and are not responsible for the third parties’ content, services, or data processing.
1.7. If you order our goods, use our App, visit our Website or Social Accounts, contact us, subscribe to our newsletter, participate in games or contests organised by us, we consider that you have read and agree to the terms of the Privacy Policy and the purposes, methods, and procedures for the use of Personal Data set out therein. If you do not agree with the Privacy Policy, you may not use the Website, the App, Social Accounts, order the goods or contact us for our offers.
1.8. This Privacy Policy is subject to change, so please visit the Website from time to time to read the latest version of the Privacy Policy published.


2. WHO ARE WE?
2.1. UAB “Millo Appliances”, legal entity code 303331122, registered office address M. Mažvydo g. 12-33, LT-06269 Vilnius, address where the activity is carried out Mokyklos g. 36, LT-14182 Bukiškis, Vilnius, Lithuania, data about the company are collected and stored in the Register of Legal Entities of the Republic of Lithuania (hereinafter the “Company” or “us”).
2.2. We manage our App, the Website and Social Accounts and act as a Personal Data Controller in offering and providing our goods, performing the Company’s day-to-day operations, or complying with legal requirements.

     

    3. WHAT YOUR PERSONAL DATA DO WE PROCESS?
    3.1. We process your Personal Data obtained in the following ways:
    3.1.1. When you provide us with Personal Data, for example, register on the Website, the App, order our goods, contact us by e-mail or telephone, etc.;
    3.1.2. We collect your Personal Data such as the history of your orders, your IP address, the history of your visits to the Website, your choices, open URL links, etc., when you order our goods, use or visit the App and the Website, Social Accounts;
    3.1.3. When we receive Personal Data from other parties, for example, when we receive information from public registers, state or local government institutions or bodies, our partners, other third parties, such as payment institutions, about payments made, etc.;
    3.1.4. When your personal data, with your consent, is provided to us by other persons, including companies using our services, for example, when such Companies indicate your contacts, refer to you as an authorized person, and so on;
    3.1.5. When you apply for the job in the Company or participate in games or contests organised by us.
    3.2. We process Personal Data to allow you to order our goods, to fulfil our contractual obligations, as well as pursuing our or third parties’ legitimate interest in carrying out instructions or obligations prescribed by the legal acts.
    3.3. The person providing Personal Data to us, both when providing his/her Personal Data and Personal Data of other persons (such as employees, representatives), is responsible for the correctness, completeness, and relevance of such Personal Data, as well as for the consent of the data subject for his/her Personal Data provision to us. We may ask you to confirm that a person has the right to provide us with Personal Data (for example, by filling in service order or registration forms). If necessary (for example, a person inquires us about receiving his/her Personal Data), we will identify the provider of such data.
    3.4. We process your Personal Data for the following purposes and under the following conditions:

      Purpose of the processing of Personal Data

      Personal data being processed

      Personal Data processing period

      Legal basis for the processing of Personal Data

      Registration in the e-shop and, user identification, use of a registered user account

      Name, surname, e-mail, phone number, country, address, company name (if applicable), relationship with the legal entity (if applicable), orders and purchases history, information about goods ordered, notifications about order status, or the Website updates, method of payment for goods and payment information.

      During the period of use of the account and 5 years after the last login to the account, and in case of revocation of the consent – until the expiry of the consent (when data are processed based on consent)

      Consent of the data subject to the processing of such data (Article 6(1)(a) GDPR)

       

      Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Sale of goods, provision of services, including delivery or returns of goods

      Name, surname, e-mail, phone number, country, address, company name (if applicable), relationship with the legal entity (if applicable), promo code (if applicable), orders and purchases history, information about payment in instalments, information about goods ordered, notifications about order status, method of payment and payment information.

      During the validity period of the agreement/during the fulfilment of the order and 10 years from the expiry of the agreement/completion of the order

      Data processing is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)

       

      Legitimate interests of the controller or of a third party (Article 6 (1) (f) of the GDPR)

      Fulfilment of warranty obligations, administration of the goods' quality issues

      Name, surname, e-mail, phone number, country, address, company name (if applicable), relationship with the legal entity (if applicable), orders and purchases history information about goods ordered, method of payment for goods and payment information, information required for provision of warranties and administration of quality issues services.

      During the warranty service/quality issue administration period and for 5 years after the end of the warranty service/quality issue administration or the last contact

      Data processing is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)

       

      Legitimate interests of the controller or of a third party (Article 6 (1) (f) of the GDPR)

      Ensuring proper functioning and development of the App, detection of the technical issues, providing customer support regarding the use of the App

      E-mail, device ID, data collected by cookies and other similar technologies, the type of mobile device, device operating system (iOS, Android), information about the goods connected to the App (e. g. manufacturer, model, unique serial number, UUIP number, application version, Bluetooth config version, firmware version, Bluetooth firmware version, main PCB revision, UI PCB revision, Bluetooth hardware revision).

      App data are stored as described in the section of this Privacy Policy “How Do We Use Analytical Data, Cookies and Other Tracking Technologies”.

       

      E-mail processed by us in course of the customer support procedures is stored for not longer than 3 (three) months after resolving the relevant support request.

       

      App data that is not included in the cookie information is stored for a maximum of 1 year from the date of collection, unless the person revokes his/her consent (when the data are processed on the basis of consent.

       

      Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR)

       

      Consent of the data subject to such data processing (Article 6(1)(a) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Communication and consultations on goods and management of inquiry 

      Name, surname, e-mail, phone number, country, address, company name (if applicable), information required to resolve shipping or goods quality issues, the content of the request and the response to the request.

      During the issue administration period and 5 years after the end of the issue administration or last contact

      Consent of the data subject to such data processing (Article 6(1)(a) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Conclusion and execution of contracts necessary for the company’s activities, other internal management

      Name, surname, phone number, e-mail, position, workplace information, address, relationship with the legal entity, self-employment certificate data, other data required for cooperation, evidence of professional qualifications.

      During the period of provision of services/cooperation and 5 years after the end of provision of services/cooperation unless a longer storage period is mandatory in accordance with the Index of General Document Storage Periods approved by order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011.

      Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Execution of financial operations, accounting, debt management

      Name, surname, e-mail, phone number, country, address, company name (if applicable), position, workplace information, address, relationship with the legal entity, account number, credit institution, payment information, information about payment in instalments, debt information, data transferred by the company collecting the contributions and confirmations of payments.

      According to the regulatory legal acts, as well as in accordance with the Index of General Document Storage Periods approved by order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011.

       

      When the data does not fall within the above-mentioned storage area – the period of validity of the contract/cooperation between the parties and 10 years after the end of the contract/relationship (last contact)

      Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR)

       

      Data processing is necessary for to fulfil a legal obligation imposed on the data controller (Article 6(1)(c) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Evaluation and selection of candidates for the offered job

      Name, surname, e-mail, phone number, address, education and activity data, content of the CV, other information required for the selection/evaluation of the candidate or provided by the candidate.

      The selection period and 3 months after the selection if the candidate's consent to the retention of data after the selection has been obtained. 

       

      When data are received not for a specific selection, they shall be stored for 3 months after the date of their receipt.

      Consent of the data subject to such data processing (Article 6(1)(a) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Management and analysis of use of electronic information channels (the Website, Social Accounts) in order to update, modify, improve, tailor, customize, or otherwise adjust the Website; ensuring functionality and security, quality improvement

       

       

       

      IP address, data collected by cookies and other similar technologies, device ID, the type of mobile device, device operating system (iOS, Android), information about the Website being opened, date and time of connection, information about the region in which the Website is opened, usage data, diagnostic data.

      Data collected through the integration of Social Accounts.

       

       

      Website data are stored as described in the section of this Privacy Policy “How Do We Use Analytical Data, Cookies and Other Tracking Technologies”.

       

      Website data that is not included in the cookie information is stored for a maximum of 1 year from the date of collection, unless the person revokes his/her consent (when the data are processed on the basis of consent.

       

      Information in Social Accounts is stored according to the conditions set by the owner of this network

      Consent of the data subject to such data processing (Article 6(1)(a) GDPR)

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Sending news, conducting surveys, direct marketing

      Name, surname, e-mail address, the data requested in the survey announcement/questionnaire 

      Data are processed for 5 years from the receipt of consent

      Consent of the data subject to such data processing (Article 6(1)(a) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Organization of advertising competitions, games, promotions

      Name, surname, address, e-mail address, telephone number, data requested to be specified in a contest, promotion, game, advertisement/questionnaire, social network account information and messages shared with us by the account holder.

      Data shall be stored for the entire period of the game, promotion, contest and 1 year from the end of the game, promotion, contest

      Consent of the data subject to such data processing (Article 6(1)(a) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

      Settlement of disputes and claims

      Name, surname, e-mail, telephone number, address, content of the claim or another similar document, information/documents related to the dispute/claim

      The entire period of the dispute/claim and 3 years after the end of the out-of-court dispute/claim resolution and 10 years after the end of judicial proceedings.

      Data processing is necessary to fulfil a legal obligation imposed on the data controller (Article 6(1)(c) GDPR)

       

      Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR)

       

      You have the right to refuse or withdraw your consent to the processing of your Personal Data at any time when these are processed on the basis of your consent. 

      3.5. In some cases, Personal Data may be stored for a longer period if storage of personal data is required to protect our or any third parties’ legitimate interests, e. g. in case of a legal dispute, or if we are obligated to do so by law. 
      3.6. In Social Accounts we can share information about ourselves, our events, news, surveys, as well information about the employees we are looking for. Social accounts users are also subject to the privacy policies of the social networks owners that include Social Accounts. When you contact us on Social Accounts, depending on the privacy settings you choose, we may see certain user account information such as profile first name, surname, image, sex, e-mail address, location. If a user posts information by communicating with us on Social Accounts, depending on the privacy settings chosen, the posted information may be made public (for example, shared on our Social Account).
      3.7. In some cases, we may send you messages related to ordering our goods, for example, informing you about the confirmation of the order, about the shipping details, changes in our policies, the App updates. Such notices are necessary for the proper provision of our services and are not considered promotional notices.
      3.8. You have the right to change and update your information provided to us. In some cases, we need to have accurate, up-to-date information about you, so we may ask you periodically to confirm that the information we hold about you is correct.


      4. HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE KEEP?
      4.1. We collect and process only such Personal Data as is necessary to achieve the Personal Data Processing purposes we have specified.
      4.2. When processing your Personal Data:
      4.2.1. We comply with the requirements of current and applicable legislation, including GDPR;
      4.2.2. We process your Personal Data in a lawful, fair, and transparent manner;
      4.2.3. We collect your Personal Data for specified, clearly defined and legitimate purposes and do not process them in a way incompatible with those purposes, except to the extent permitted by law;
      4.2.4. We take all reasonable steps to ensure that Personal Data that is inaccurate or incomplete, in accordance with the purposes for which they are processed, would be rectified, supplemented, suspended, or destroyed without delay;
      4.2.5. We hold them in such a form that your identity can be established for no longer than is necessary for the purposes for which the Personal Data are processed;
      4.2.6. We do not provide Personal Data to third parties or disclose them, other than as set forth in the Privacy Policy or applicable law;
      4.2.7. We ensure that your Personal Data are processed securely. 


      5. TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?
      5.1. We will only transfer your Personal Data as described in this Privacy Policy.
      5.2. We may transfer your Personal Data to:
      5.2.1. Our partners or consultants (such as professional service providers such as accountants, legal consultants, audit firms etc.) and our trusted services providers when they provide services to us, to you on behalf of us and under our instructions (IT, cloud, security services providers, providers of other key operational systems such as banking modules, carriers of goods etc.) We will control and shall always remain responsible for the use of your personal data. The list of our service providers and partners:
      5.2.1.1. Marketing – SuperYou, UAB (Lithuania);
      5.2.1.2. Accounting, financial services- ROSK Consulting, UAB (Lithuania);
      5.2.1.3. Website, App, other IT solutions: 
      5.2.1.3.1. Bbold online, UAB (Lithuania);
      5.2.1.3.2. SuperYou, UAB (Lithuania);
      5.2.1.3.3. scale3c, UAB (Lithuania); 
      5.2.1.3.4. Klaviyo, Inc (USA); 
      5.2.1.3.5. CODE WHALE, Inc (USA);
      5.2.1.3.6. TrustPilot, Inc. (USA); 
      5.2.1.3.7. Zendesk, Inc. (USA).
      5.2.1.4. IT security and technical services – TELIA Lietuva, AB (Lithuania);
      5.2.1.5. Cloud and hosting:
      5.2.1.5.1. Progresyvūs sprendimai, UAB (Lithuania); 
      6.2.1.5.2. RIVILĖ, UAB (Lithuania).
      5.2.1.6. Payments:
      5.2.1.6.1. Stripe Payments Europe Limited (Ireland);
      5.2.1.6.2. Stripe, Inc. (USA) (data is securely transferred to the service provider by signing the EU Standard Contractual Clauses for Data Transfers Outside the European Economic Area approved by the European Commission);
      5.2.1.6.3. Shopify Payments, Inc. (USA) (data is securely transferred to the service provider by signing the EU Standard Contractual Clauses for Data Transfers Outside the European Economic Area approved by the European Commission);
      5.2.1.6.4. Klarna Bank, AB. (Sweden).
      5.2.1.6.5. PayPal, S.à r.l. et Cie, S.C.A. (Luxembourg);
      5.2.1.7. Insurance – Baltic Underwriting Agency, AB (Lithuania);
      5.2.1.8. Carriers - Skubios siuntos, UAB (Lithuania).
      5.2.1.9. Other – HubSpot Ireland Ltd. (Ireland).
      5.2.2. Social network platform operators (so that we can publish your content to Social Network accounts):
      5.2.2.1. LinkedIn Ireland Unlimited Company (Ireland) and LinkedIn Corporation (USA) (data are transferred according to EU standard contractual clauses);
      5.2.2.2. Facebook Ireland Ltd. (Ireland) and Facebook, Inc. (USA) (data transferred according to EU standard contractual clauses);
      5.2.2.3. Twitter International Company (Ireland) and Twitter Inc. (USA) (data transferred according to EU standard contractual clauses);
      5.2.2.4. YouTube Inc. (USA).
      5.2.3. State or local government institutions and authorities, law enforcement and pre-trial investigation institutions, courts and other dispute resolution institutions, other persons performing functions assigned by law, in accordance with the procedure provided for by legislation of the Republic of Lithuania. We provide these entities with mandatory information required by law or specified by the entities themselves;
      5.2.4. Other third parties, such as payment institutions, etc.;
      5.2.5. If necessary, to companies that intend to buy or would buy the Company's business or would conduct joint activities with us or would cooperate in another form, as well as to companies established by us.
      5.3. We normally process Personal Data within the European Economic Area, but in some cases your Personal Data may be transferred outside the European Economic Area (hereinafter “EEA”). Your Personal Data will only be transferred outside the EEA under the following conditions:
      5.3.1. Data are transferred only to our reliable partners who ensure the provision of our services to you;
      5.3.2. Data processing or provision agreements have been signed with such partners, which ensure the security of your Personal Data;
      5.3.3. The Commission of the European Union has decided on the eligibility of the country in which our partner is established, i.e., an adequate level of security is ensured; or
      5.3.4. You have given your consent to the transfer of your Personal Data outside the European Economic Area.
       

      6. WHAT RIGHTS DO YOU HAVE? 
      6.1. As a data subject, you have the following rights regarding your Personal Data:
      6.1.1. To know (to be informed) about the processing of your Personal Data (right to know);
      6.1.2. To access your Personal Data and the way they are processed (right of access);
      6.1.3. To request the correction or, depending on the purposes of the processing of Personal Data, supplementing of incomplete Personal Data (right to rectification);
      6.1.4. To request the erasure of your Personal Data or the suspension of your Personal Data processing activities (excluding storage) (right to erase and right to “be forgotten”);
      6.1.5. To request us to restrict the processing of Personal Data for one of the legitimate reasons (right to restrict);
      6.1.6. The right to transfer data (right to transfer). This right will be exercised only if there are grounds for its exercise and appropriate technical measures to ensure that the transfer of the requested Personal Data does not pose a risk of security breach to the data of other persons;
      6.1.7. The right to object the processing of your personal data when we process Personal Data on the basis of a legitimate interest of the Company or a third party, including profiling. If you object, we will only be able to further process your Personal Data for compelling legitimate reasons that take precedence over your interests, rights, and freedoms, or to make, enforce or defend legal claims;
      6.1.8. Withdraw your consent to the processing of your Personal Data when this data is processed or intended to be processed for direct marketing purposes, including profiling as far as such direct marketing is concerned (based on the Personal Data you provide, profiling may be carried out for direct marketing purposes in order to offer you individually tailored solutions and proposals. You can revoke your consent to the processing of personal data by automated processing, including profiling, or object to it at any time).
      6.2. We may refuse to implement your rights listed above, except for refusal to process your Personal Data for direct marketing purposes or in other cases where Personal Data are processed with your consent, where GDPR provisions allows us to disregard your request, or where in cases provided for by law, the prevention, investigation, and detection of criminal offenses, breaches of official or professional ethics must be ensured, as well as the protection of the rights and freedoms of the data subject, us and others.
      6.3. You can exercise some of your rights as a data subject by changing the settings of the user account and the information contained therein. You may submit any request or instruction related to the processing of Personal Data to us in writing by e-mail hello@getmillo.com . When you make such a request, we may, to better understand the content of your request, ask you to complete the necessary forms, as well as provide an identity document or other information that will help us verify your identity. If you make a request by e-mail, depending on its content, we may ask you to come to us or make a written request.
      6.4. Upon receipt of your request or instruction regarding the processing of Personal Data, we will, no later than within 1 month from the date of the request, provide a response and perform the actions specified in the request or inform you why we refuse to perform them. If necessary, the specified period may be extended by a further 2 months, depending on the complexity and number of applications. In this case, we will notify you of such an extension within 1 month of receiving the request.
      6.5. If Personal Data are deleted at your request, we will retain only copies of information that is necessary to protect the legitimate interests of us and others, to comply with government obligations, to resolve disputes, to identify disruptions, or to comply with any agreements you have with us. 

       

      7. WILL WE SEND YOU NEWS? 
      7.1. You can give us your consent if you wish to receive our offers and information about our goods, activities and offers. You can also give us your consent to help us evaluate the quality of our services.
      7.2. With your consent, the news of your choice will be sent to you by e-mail specified by you. After receiving your consent, we can send you news, inquire about the quality of our goods and maintenance by e-mail, as well as invite you to fill in quality assessment forms.
      7.3.We may send in-app messages for you in the App for the above-mentioned purposes. We always provide you an opportunity to opt-out from receiving that kind of notifications.
      7.4. After sending the news, we can collect information about the people who received it, for example, which message the people opened, what links they clicked on, and so on. Such information is collected to offer you relevant and more tailored news.
      7.5. Your contacts may be passed on to our partners/processors who provide us with news delivery or quality assessment services.
      7.6. If you agree to receive news or share an opinion about the quality of our services, you may withdraw your consent at any time without giving reasons for the refusal (disagreement) by writing an e-mail to hello@getmillo.com  or in another way specified in the message provided to you (for example, by clicking on the relevant link in the newsletter) or by changing the App settings, etc. Then we will immediately stop sending news to your contacts.
      7.7. Withdrawal of consent does not automatically oblige us to destroy your Personal Data or provide you with information about the Personal Data we process, so you must make such a request separately in order for us to perform these steps as well.
      7.8. In order to show you more relevant personalized advertising, our advertising partners use various mobile and web cookies. Personalized advertising will be shown to you only with your consent. Advertising personalization cookies are used to measure a group, activate contextual advertising, and/or target campaigns. If you give us you permission to use cookies, a user profile with a pseudonym will be generated, but it will not be possible to identify the person’s identity. We have no control over these third-party tracking technologies and their use. These service providers are subject to confidentiality agreements with us and other legal restrictions. Third-party cookies are governed by the privacy policies of third parties. You can refuse personalized cookies by changing your browser settings or by other means, which are described in Chapter 10 of the Privacy Policy.

       

      8. HOW WILL WE ORGANISE GAMES, PROMOTIONS, CONTESTS?
      8.1.Participation in any games, promotions or contests we publish is optional. To participate in a contest, game, or promotion that we announce, you are required to provide the information that we specify, including Personal Data. Otherwise, you will not be able to participate in the game, contest, or promotion.
      8.2.You have the right to refuse to participate in our games, contests, promotions and to withdraw your consent to the processing and use of your Personal Data for this purpose at any time. You may do so by writing to us at the email address provided or by any other means (for example, by clicking on the relevant link in the email). If you withdraw your consent, you will be removed from the list of participants in the game, promotion or contest and will no longer participate in it. 
      8.3.If you participate in our games, contests, and promotions, we have the right to contact you using the contact details you have provided to us and/or to publish information about you as a winner on the Website, Social Accounts, or other publicity channels we specify in the rules of the game, contest, or promotion.
      8.4.We may use a software application based on automated decision making to process registrations and/or to determine winners. This will be notified in the rules of the game, promotion or contest or will be apparent from the links we provide. In this case, if you do not wish to be subject to automated decision making, you will not be able to participate in the game, promotion, or contest.

       

      9. HOW DO WE PROTECT YOUR PERSONAL DATA?
      9.1. Your Personal Data are processed responsibly, securely and is protected from loss, unauthorized use, and alteration. We have put in place physical and technical measures to protect the information we collect from accidental or unlawful destruction, damage, alteration, loss, disclosure, as well as from any other unlawful processing. Security measures for personal data shall be determined considering the risks arising from the processing of Personal Data. 
      9.2. Although we will do our best to protect Your Personal Data, we cannot guarantee the full security of Personal Data shared or transmitted to the Website or App. However, once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
      9.3.Our employees have made a written commitment not to disclose or distribute your Personal Data to third parties.

       

      10. HOW DO WE USE ANALYTICAL DATA, COOKIES AND OTHER TRACKING TECHNOLOGIES?
      10.1. We always improve our Website, App and user experience. Therefore, we must know what information is most relevant to the Website and the App visitors, how often they connect, what browser and device they use, what content is mostly read, what region visitors come from, and similar demographics and statistics. For this, we use Google Analytics tool, which lets us collect and analyse the relevant data. You can learn more about how Google Analytics works and the information it allows us to collect and analyse here. You may opt out from collection of data by Google Analytics, as described here. You, also, can change your browser settings to prevent Google Analytics from analysing information.
      10.2. Cookies are small files that are stored in the browser of a Website visitor’s device when you browse websites. Other technologies, such as pixels, local storage, etc. may be used for similar purposes. Cookies are widely used to make websites work or to function better and more efficiently. In this policy, all the above technologies are referred to as “cookies”.
      10.3. We use cookies to analyse information flows and user behaviour, to promote trust and ensure security, as well as to ensure the proper functioning of the Website, the App its improvement, memorization of your chosen settings, to personalize the content displayed to you, to link the Website, the App or to Social Accounts.
      10.4. You can choose whether you want to accept cookies. If you do not agree to cookies being stored on the browser of your computer or other device, you can mark it in the cookie acceptance bar, change the settings of the browser you are using and disable cookies (all at once or one by one or in groups). To opt out of cookies on your mobile device, you must follow the official instructions for that device. You can control and/or delete cookies as you wish – for details, see http://www.youronlinechoices.com/  and http://www.AllAboutCookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. But if you do this you may have to manually adjust some preferences every time you visit the Website or the App while some services and functionalities may not work. 
      10.5. You may opt out of the use of third-party cookies for advertising purposes by visiting the Network Advertising opt-out page at http://www.networkadvertising.org/managing/opt_out.asp.
      10.6. We may use mandatory cookies that are necessary for the operation of the Website, analytical cookies, functional cookies to analyse Website traffic, memorize user preferences and adapt them to the Website so that we can provide enhanced features, performance cookies, third-party cookies that use third parties, advertising cookies to display personalized and general advertising to you.
      10.7. We also use the following Google Inc. products:
      10.7.1. Google AdSense – allows to evaluate your use of the Website and the App in relation to the advertisements displayed and to provide information-based reports. Data collected by Google AdSense is typically transmitted and stored on a Google server in the United States. If you do not want to receive customized ads, you can change your settings at https://www.google.com/settings/ads as needed. In this case, you will be given an opt-out cookie. However, if you delete all cookies, the opt-out cookie may also be deleted.
      10.7.2. Google Remarketing – allows to repeatedly show ads on sites in the Google Inc. partner network. If you do not want to receive customized ads, you can change your settings at https://www.google.com/settings/ads as needed. In this case, you will be given an opt-out cookie. However, if you delete all cookies, the opt-out cookie may also be deleted.
      10.7.3. Google Analytics for Firebase - allows us to analyse the use of the App. It collects information about the use of the App, transfers it to Google and stores it there. Google uses advertising ID, application instance ID and special analytics App instance ID to identify the end device. For this purpose, it records further usage data such as the number of users and sessions, the duration of the session and data on the actions taken. For an overview of data collection in Google Analytics for Firebase, please visit https://support.google.com/firebase/answer/6318039#perfmon. Data related to advertising ID is stored for 60 days. Google uses this information on our behalf to evaluate how users use our App, to compile reports on the performance of the App, and to provide us with other services related to the use of the App.
      10.7.4. Google Firebase Crashlytics - allows us to ensure the stability and improvement of the App. If the App crashes, information is collected about the devices used and the use of our application (e. g. timestamp, when the App was running and when the crash occurred), which allows diagnosis and troubleshooting of the problems. App instance ID is used to estimate the number of users affected by the crash. App crash data is stored for 180 days. Please check for more information: https://firebase.google.com/docs/crashlytics/?gclid=CjwKCAjwsMzzBRACEiwAx4lLG_aUf_FKpzAqHOGQ1cBnaVx7y_CwXqowLX_BNXufJNBaTfcpF1CaiBoC3AUQAvD_BwE. 

       


      11. CONTACT US
      11.1.If you have any questions about the information provided in this Privacy Policy, please contact:
      E-mail: hello@getmillo.com ;
      Address: Mokyklos g. 36, LT-14182 Bukiškis, Vilnius, Lithuania;
      Phone: +370 614 48285.
      11.2.If you wish to make a complaint about our processing of Personal Data, please provide it to us in writing, providing as much information as possible. We will cooperate with you and try to resolve any issues immediately.
      11.3.If you think that in accordance with the GDPR your rights have been violated, you can submit a complaint to our supervisory authority – the State Data Protection Inspectorate, more information and contact details can be found on the Inspectorate’s website (https://vdai.lrv.lt/). We strive to resolve all disputes promptly and peacefully, so we invite you to contact us first.

       

      12. FINAL PROVISIONS
      12.1.We may change this Privacy Policy. We will notify you of any changes on the Website by posting an updated Privacy Policy or by other usual means of communication. Amendments or modifications to the Privacy Policy will be effective from the updating date specified in the Privacy Policy unless a different effective date is specified.
      12.2.If you continue to use the App, the Website, order services from us, contact us after we have changed the terms of the Privacy Policy, you will be deemed to have agreed to the changed terms of the Privacy Policy.