Your privacy is important to Mi9 Retail, Inc. and our subsidiaries and affiliates (“Mi9 Retail” or “we”).  We respect your preferences concerning the treatment of Personal Information that we may collect. This policy explains how we collect and use your Personal Information, how you can control its use, and describes our practices regarding information collected from Mi9 Retail sites that link or refer to this policy (such as our websites, software applications, social media pages and HTML-formatted e-mail messages), as well as through offline sales and marketing activities (collectively, the “Content”).

By using the Site, you consent to the collection and use of your Personal Information by Mi9 Retail consistent with applicable data protection law and this Privacy Policy Statement.

What Information We Collect

Through your interaction with and use of the Content, Mi9 Retail may collect personal information, which is information that identifies an individual or relates to an identifiable individual. Personal Information may include, but is not limited to, your name, physical address, telephone number, e-mail address, company affiliation and associated interests (“Personal Information”).

Mi9 Retail may also collect other information through your interaction with and use of the Content, which does not reveal your specific identity or does not directly relate to an individual (“Other Information”). Other Information may include, but is not limited to, data collected through automated electronic interactions, browser and device information, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information.

Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. We may also combine Other Information with Personal Information in which case we will treat the combined information as Personal Information.

How We Share and Use Your Information

Personal Information

Mi9 Retail uses Personal Information to operate and improve Content, to fulfill your requests for information, to register your products, to process your job application, to provide you promotional materials, to allow you to participate in contests and surveys, to provide service and support, to engage in and process transactions you have requested, tailor marketing to your needs and respond to your requests, obtain third party services and comply with legal requirements and corporate transactions . These uses may include providing you with more effective customer service; making websites or services easier to use by eliminating the need for you repeatedly to enter the same information; performing research and analysis aimed at improving our products, services and solutions; and displaying content and advertising that are customized to your interests and preferences.

We also use your Personal Information to communicate with you. We may send certain mandatory service communications such as welcome letters, billing reminders, information on technical service issues, and support announcements. Some Mi9 Retail services may send periodic member letters that are considered part of the service. We may also contact you to inform you of products or services available from Mi9 Retail.

If you have not chosen not to receive promotional materials from us we may also use (but will not disclose) your Personal Information to promote and market additional products, services and special offers from Mi9 Retail that may be of interest to you. You can choose not to allow us to use your Personal Information for the above-described marketing purposes by indicating your preference at the time of collection of your Personal Information or by contacting us as set out below.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent, please contact us in writing. We will inform you of the implications of withdrawing consent.

Other Information

We may use, transfer, and disclose Other Information we collect for any purpose, except where applicable law requires otherwise. If we are required to treat Other Information as Personal Information under applicable law, then we will only use it in the same way that we are permitted to use and disclose Personal Information.

How We Collect Information

Mi9 Retail and our third party service providers may collect both Personal Information and Other Information from a variety of sources that generally fall into three categories:

  1. Publicly Available Data / Data from Third Parties: Data that you may have made publicly available, such as social media posts, or data provided by third party sources, such as marketing opt-in lists, or data aggregators.
  2. Direct Interactions: Data obtained from your use of and interaction with us through the Content and other activities such as account creation, submission of registrations and forms, or sales inquiries and transactions.
  3. Automated Interactions: Data obtained from the use of technologies such as electronic communication protocols, cookies, embedded URLs or pixels, or widgets, buttons and tools.

Although Mi9 Retail’s use of automated interactions may change over time as technology evolves, the following descriptions are designed to provide you with additional detail about Mi9 Retail’s current approach to information collected from automated interactions.

Electronic Communications Protocols: Mi9 Retail may automatically receive information from you as part of the communication connection, which often consists of network routing information, equipment information, your IP address, time and date.

Mi9 Retail may also automatically receive and record information about your interaction with the Content, such as clickstream information or general geo-location data.

Cookies: A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone browser from a website’s computer and is stored on your device. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Cookies record information about your online preferences and allow us to tailor the websites to your interests.

Mi9 Retail electronic Content utilizes cookies. Some Mi9 Retail websites will not allow you to complete certain activities if cookies are disabled. We use multiple third parties to monitor web traffic, statistics, advertisement ‘click-through’, and other activities on Mi9 Retail’s Content. Where authorized by us, such third parties may use cookies, our web log files, web beacons, and other monitoring technologies to evaluate use of our website.

We also include web beacons in HTML-formatted e-mail newsletters in order to count how many newsletters (or particular articles, links, etc.) are being accessed.

Current versions of web browsers offer enhanced user controls regarding the placement and duration of both first and third party cookies. Search for “cookies” under your web browser’s Help menu for more information on cookie management features available to you.

Embedded URLs: Mi9 Retail may use a tracking technique that employs embedded URLs to allow use of the electronic Content without cookies. Embedded URLs allow limited information to follow you as you navigate the electronic Content, but are not associated with Personal Information and are not used beyond the session.

Embedded Pixels and Similar Technologies: On the electronic Content, Mi9 Retail and its service providers may use embedded pixel technologies for the purposes of identifying unique user visits (as opposed to aggregate hits), and for advertising purposes. In addition, embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient’s e-mail address.

Widgets, Buttons, and Tools: Our electronic Content may include widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g., links to bookmarked sites), along with buttons or other tools that link to other companies’ services (e.g., a “Like” button or third party map). The widget, button or tool may collect and automatically send Personal Information, such as your e-mail address, or Other Information (such as your browser information, or IP address), to a third party. Cookies may also be set or used by the widgets, buttons or tools to enable them to function properly or for other purposes, which may include advertising. Information collected or used by a widget, button or tool, including cookie settings and preferences, is governed by the privacy policy of the company that created it.

Physical Location: We may collect the physical location of your device and use it to provide you with personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content.

Retention

Mi9 Retail retains your Personal Information for as long as reasonably necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you.

Sensitive Information

We ask that you not send us, and you not share any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership).

How You Can Contact us, Access to Review and Correct Your Data

Mi9 Retail makes commercially reasonable efforts to keep your files complete, up-to-date, and accurate. If you wish to contact us, access, update or correct your Personal Information please contact us at any time at:

info@mi9retail.com

When you contact us please provide us with your name, address, any email address you have provided to Mi9 Retail and a description of the circumstances under which you provided the data (for example, to register a product, to receive a newsletter, etc.). We will make reasonable efforts to incorporate as soon as practicable the changes in Personal Information that we maintain. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections to data we maintain.

Consent and Agreement

By using the Mi9 Retail Content, you signify your agreement to the terms and conditions of this Privacy Statement. If you do not agree to these terms and conditions, please do not disclose any Personal Information to Mi9 Retail.

Enforcement

Mi9 Retail will regularly review its compliance with this privacy statement. Please feel free to direct any questions or concerns regarding this statement or Mi9 Retail’s treatment of Personal Information by contacting us at the link or address indicated below. When we receive written questions and concerns at this address, it is Mi9 Retail’s policy to contact the individual user regarding his or her concerns. We will investigate and attempt to resolve concerns regarding use and disclosure of Personal Information in accordance with the principles contained in this statement.

Any concern that cannot be resolved through our internal processes will be settled by arbitration administered by the American Arbitration Association (AAA) in accordance with its applicable commercial rules and, as applicable, the Safe Harbor Principles. The exclusive location for such arbitration shall be Miami, Florida. All decisions of the arbitrator(s) will be final and binding on the parties, which waive any right to further appeal the arbitration award, to the extent an appeal may be lawfully waived.

Changes to this Statement

If we change this statement, we will post the revised statement here, along with the date of revision. If we make significant changes to the statement, we may also post a notice on our home page.  Any changes will apply only from date of the revision.  Amended dispute resolution provisions will not apply to any dispute of which the parties had actual notice as of the date of the amendment.

Revised October 3, 2014