Published on 4 April, 2022 | 82 views | 21 minutes read
Effective Date: December 9th, 2022
Information We Collect
When You Register for a Midley Account
When you create an Account, we may collect personal information from you, such as your name, phone number, company name, industry, job title, company size, email address, and sign-in information. If you create an Account using your login information from a third-party account, such as Google, Facebook, Apple, or Twitter, we will access and collect the personal information about you that the third-party account provides (which is based on your privacy settings with the third-party account), so that you can log into your Account with us. We use your contact information to send you information about our Services and communicate with you about your Account, your activities on our Site and Services and policy changes. You may unsubscribe from receiving certain types of these messages through your Account settings, although Midley reserves the right to contact you when we believe it is necessary, such as for administrative and account management purposes.
When You Create a Midley Link
One feature of the Services is the ability to create shortened uniform resource locators (URLs) of websites (“Midley Links” or “Bitlinks”). Users can create Midley Links without registering for an account. When you create a Midley Link, Midley collects and stores both the original URL and the shortened URL and, if you are logged in to your Account, we will associate that information with your Account. Midley also collects and stores your IP address, your geolocation data (which we derive from your IP address), the time and date on which you shortened the original URL, and if you share a Midley Link on a social networking platform, the name of the platform and your username on that platform.
When You Interact With a Midley Link
Other Information We Automatically Collect
When you visit the Site, we automatically collect (i) your IP address and location derived from the IP address; (ii) internet or other electronic network activity information, like the referring websites or services; (iii) the time and date of each access; (iv) device settings, such as browser type, operating system, and language; and (v) cookie information. This type of data enables us and third parties authorized by us to ﬁgure out how often individuals use parts of the Site so that we can analyze and improve them.
We may receive a conﬁrmation when you open an email from us. We use this conﬁrmation to improve our customer service.
Midley may use third-party APIs and software development kits (“SDKs”) to provide certain functions in our Services.
Third Party Services
Some features of the Services allow you to share your content and Midley Links through your accounts with Third Party Services such as Twitter. If you choose to connect Midley to such Third Party Services, we may collect information related to your use of those Third Party Services, such as authentication tokens that allow us to connect to your Third Party Service accounts. We will ask you for permission before you authorize our collection of this information. We will only use that information for the speciﬁc reason for which it was provided to us. We may also collect information about how you are using the Services to interact with those connected Third Party Services. Note that Third Party Services may have the ability to restrict the information that is provided to us based on your privacy settings of that account.
To enable us to infer the location from the IP addresses of computers or devices that visit our website or click, view or interact with Midley links as described in this policy, we receive IP-derived location information from our third-party service provider. We also receive business contact information of our business customer contacts and prospects from our third party service provider.
Cookies and Other Similar Technologies
Midley cookies also allow Midley to track when you have clicked on a Midley Link. Each click of a Midley Link is tracked using a unique identiﬁer assigned to you in one or more cookies stored by your web browser and associated with Midley. We may associate the unique identiﬁer in our cookies with the other information we automatically collect when you use the Services, as described above, including your IP address, Midley Links you click, Midley Links you create, and information with your Account if you have one.
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. If you disable cookies, you will not be able to use some features of the Services. We do not currently recognize do-not-track signals.
You may ask Midley not to associate your web browser or IP address with visits to the Midley.com website or Midley Links that you create or click by clicking on the appropriate links below. If you would like to opt-out of the Midley Links, please click on the opt-out choice for Midley Links below. This will install a cookie on your browser that instructs our servers not to associate your IP address and browser with Midley Links you create, click, or view. If you clear your cookies in your browser, you will need to click on the opt- out choice again after each time you clear your cookies. To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. Cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may limit tracking via their device settings. Please note that if you use these opt-out mechanisms, we will still automatically collect the IP addresses of computers or mobile devices that click on or create Midley Links; we just won’t associate them with your browser or Midley account.
Note Regarding Children
We do not knowingly collect personal information from children. If we learn that we have collected personal information of a child under 13 (or older as required by applicable law), we will take steps to delete such information from our ﬁles as soon as possible.
How We Use Information
We use the personal information we collect for a variety of administrative and business purposes to:
- operate our Site and provide the Services, process and complete any transactions, verify individual identity,
- respond to inquiries, questions and comments and provide customer and technical support, provide access to certain functionalities of our Services,
- personalize and improve the Services and develop new products and services,
- communicate with our current and prospective customers concerning our services, measure interest and engagement in our Site and Services,
- monitor and analyze usage and trends of the Site and Services,
- provide services to our customers to allow them to understand how you interact with our Services and to help detect, deter and prevent malicious, fraudulent or unlawful activity,
- comply with any legal obligations, and
Usage Across Devices
We may use the information we collect to make inferences that a unique individual has created or interacted with Midley links on different devices so that we can detect, deter and prevent malicious, fraudulent or unlawful activity and analyze how users use our Services. For example, if you created a Midley link on a computer connected to your residential WiFi network, and you soon thereafter clicked on a Midley link on a mobile device connected to the same WiFi network, we may infer that a single individual created and clicked on the Midley links because both events were associated with the same IP address in the same time period.
Other Legitimate Interests
We also may use personal information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, prevention of fraudulent, malicious and unlawful activities, or any other purpose disclosed to you at the time you provide personal information or allowed by law.
Information We Share
The Services are designed to help you share information with others. In addition, we provide Services to our Customers that use Midley Link Metrics. As a result, the following categories of personal information generated through your use of the Services are shared publicly or with the following categories of third parties for the business purposes described below.
Midley Links You Create
Much of your activity on and through the Services is public by default. For example, when you create a Midley Link, the original URLs you have shortened and the corresponding Midley Links are publicly available.
Where permitted by law, if you register a Midley Account with an email address on a domain owned by an organization, (for example, an employer or educational institution where you have an email account), we may share your email address and information about your Account, such as the number of links you have created, with that organization to explore the organization’s interest in creating or managing an enterprise account or for related purposes.
Information We Share With Customers
Information You Elect to Share
When creating a Midley Link, you can share that Midley Link through Third Party Services. Any information that you elect to distribute through Third Party Services, such as a social network post you create, may then become accessible to users of those services. You can also access other Third Party Services through the Services, for example by clicking on links in the Statistics page for a Midley Link. We recommend that you review the terms of services and privacy policies of such Third Party Services that you access through the Services since Midley does not control and is not responsible for the privacy practices of these Third Party Services.
Information Shared with Service Providers
We may employ and contract with third parties to perform certain tasks on our behalf and under our direction (our “Service Providers”). We may need to share information about you with our Service Providers in order to fulfill certain business purposes, like providing our product with research and analytics on user behavior and providing advertising products and services to users, processing payments, and providing email marketing and support services. Our agreements with these Service Providers authorize them to use your information only as necessary to provide services to us. Transfers to subsequent third parties are covered by our agreements with our service providers.
Information Disclosed Pursuant to Business Transfers
We may transfer and/or provide information about our users in connection with an acquisition, sale of company assets, or other situation where user information would be transferred as one of our business assets. You will be notiﬁed via email and/or a prominent notice on our website.
In such a case, the acquirer of Midley may continue to use your information as set forth in this policy or as otherwise allowed by law.
Information Disclosed for the Protection of Midley and Others
Information We Share With Your Consent
We will share information about you when you direct or otherwise instruct us to do so, such as when you share Midley Links or content with others through the Services, if you intentionally use or direct us or the Services to interact with third parties, or if we notify you that the information you provide will be shared in a particular manner and you provide such information (like sharing/posting it with a third-party Service).
EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD
Midley, Inc. participates in and has certiﬁed its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Economic Area (EEA) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certiﬁcation, visit the U.S. Department of Commerce’s Privacy Shield List. (https://www.privacyshield.gov/)
Midley, Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Midley, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Midley, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Please direct any inquiries or complaints regarding our compliance with the Principles to the point of contact listed in the “Questions” section below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider at https://www.jamsadr.com/eu-us-privacy-shield. JAMS is located in the United States and their services are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
The information you provide may be transferred, processed and/or accessed by us in the United States or another country where we (or our service providers) operate.
Your Account information is protected by a password for your privacy and security. You can help prevent unauthorized access to your Account by selecting and protecting your password appropriately, making use of two-factor authentication, and limiting access to your computer and browser by signing off after you have ﬁnished accessing your Account.
Midley endeavors to protect the information it collects about its users using reasonable security processes and controls, however, despite these efforts, no security measure is perfect or impenetrable and Midley does not guarantee or warrant that such measures will prevent unauthorized access to the information about you that is stored by Midley. In the event we experience a breach of security, we will promptly notify you if your personal information has been compromised, in accordance with applicable law. If you have any questions about the security of your personal information, you can contact us at privacy@Midley.com.
Choice and Access
You don’t need an Account to create Midley Links, and you can use many of the features of the Services without registering, thereby limiting the type of information that is collected about you individually. If you have a Midley Account, you may access, correct, or request deletion of your personal information by logging into your Account. Once logged in to your account, you will be able to view a history of the URLs you have shortened and the metrics pages for those URLs. You can request a complete copy of the personal information we store about your account by clicking the button to request a report in your Account Settings. For more information on how to request access to your information,
You can delete your Account at any time through your Account settings page. If you delete your Account, you will no longer be able to access or use the Services. If you have an Account but are unable to access it, you can contact us at support@Midley.com. We will respond to your request within a reasonable timeframe. If you are a resident of the EEA or Switzerland, you have the right to ask that your personal data be corrected, updated, or erased. You may also have the right to object to, or request that we restrict, certain processing.
For all other requests to exercise any of your rights, you may contact us as indicated in the “Questions” section below. Once we receive your request, we will ask that you verify your identity such as by authenticating through your account. If you do not have a Midley account, Midley has no way of identifying you or verifying that you created or clicked on a Midley link.
You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please provide a written attestation, declaration, or permission that has either been physically signed or provided electronically per applicable law. In certain circumstances, we may be required by law to retain your personal information.
Please note that in the interest of ensuring that existing Midley Links continue to function for all of our users, the Midley Links that you have created and shared cannot be deleted or disabled (even if your Account is deleted), and any shortening and sharing activity that has already occurred on your Account also cannot be deleted. If you have concerns about any unauthorized use of your Account, you can delete your account within your Account settings.
Please see the Cookies section above for additional choices you may have.
If you are a California Resident, you may request, subject to any applicable exceptions, access to and deletion of your information or more information about how we collect, use, and disclose personal information. You may submit a verifiable request to know and exercise any of your other rights as described in the “Choice and Access” section above. We will not discriminate against you for exercising your rights and choices.
The categories of personal information that we have collected in the preceding 12 months and their sources are provided in the “Information We Collect” section above. Our business purposes for collecting personal information are described in the “How We Use Information” section above.
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to: support@Midley.com. We will make every effort to resolve your concerns.
You may also contact us at DPT 5006, 601 W. 26th St., 3rd Floor, Suite 357, New York, NY 10001-1101.