PRIVACY POLICY 

Thank you for visiting TheCommuniKey.com. This website, the mobile site(s), the mobile app(s), and The CommuniKey™ discount card are part of The CommuniKey™ discount program, which is owned and operated by Millennial Connections, LLC.  Your privacy is important to us. To better protect your privacy, we provide this notice explaining our information gathering and dissemination practices and the choices you can make about the way your information is collected and used by Millennial Connections, LLC.

We collect information in order to serve our discount program members and online/mobile users better.  This information allows us to provide better information and services, including discounts and other opportunities for our members, and to create a valuable community in which to discuss thoughts, issues and experiences.  Millennial Connections, LLC will use the information we collect to provide you with valuable services and we will not sell or provide your information to third parties without your consent, unless required by law.

The Information We Collect
Through Millennial Connections, LLC website(s), mobile site(s), mobile app(s), and other media (collectively, the “Site”) you can engage in various activities like membership in The CommuniKey™ discount program, registration of your CommuniKey™ discount card, installing the mobile app(s), entering contests or sweepstakes, playing games, taking quizzes, voting in polls or otherwise expressing an opinion, or participating in one of our online forums or communities. Your personally identifiable information may be required to engage in these activities as well as to receive products and services that you may have requested. The types of personally identifiable information that may be collected at these pages and elsewhere include but are not limited to: name, address, gender, e-mail address, telephone number, fax number and credit or debit card information.

We may also collect information about your personal or professional interests and your use of or opinions about various products, programs and services. This may involve information about your usage of our Site, your usage of your The CommuniKey™ discount card/mobile app, and/or the various participants that you visit using your CommuniKey™ discount card/mobile app.

We may also collect certain non-personally identifiable information when you visit our web pages or use our applications, such as the type of browser and operating system you are using, your IP Address, your Internet service provider and your mobile service provider.

We may collect location information that you provide. Certain devices and browsers contain unique identifiers that can be used to identify the geographical location of the device.  When you use such a device or browser to access our Site, your device and/or browser may automatically collect and/or transmit your location information.  We also may collect GPS information from the device if the device transmits it.  Additionally, if you download our mobile app, we may collect your location information in order to deliver our mobile app services. If you choose to enable certain features in our mobile app(s) that require your geographic location, then we will collect and store that information.

In addition, to enhance your online/mobile experience we may use cookies. Cookies are text files that are stored on your computer’s browser or mobile device to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering at our Site.  However, once you choose to furnish personally identifiable information, this information may be linked to the data stored in the cookie.  We use cookies to understand Site usage and to improve our content, offerings and advertisements. For example, we may use cookies to personalize your experience at our Site, to save your password in password-protected areas so you don’t have to re-enter it each time you visit our Site or to track the performance of contests, promotions or other offerings on our Site. We also may use cookies to provide you with certain offerings. Similarly, as part of an arrangement with our participants or other business partners (including, without limitation, those who provide the advertisements that you see on our Site) we may also access cookies placed by others and allow others to access certain cookies placed by us.  We do not use cookies to retrieve personal information from your computer or mobile device.

We may also collect and store information through the use of other automatic technologies, such as browser and flash cookies, pixels and web beacons about your use of our Site, including device identifying information such as IP addresses, MAC address or other device-specific alphanumerical ID numbers, the make and model of your device, the wireless provider associated with your device, whether you downloaded the app, the source of the download of the app, when the app is launched, how many times a particular page within the Site is visited, which features the users interact with, and your device or computer’s connection to the Internet.  If you choose to connect to our Site through a social network such as Facebook, we may automatically collect your profile information.  These things allow us, among other things, to improve the delivery of our services to you and to measure traffic on the Site.  The information we collect may be collected directly by us, or it may be collected by a third-party website hosting provider, or another third-party service provider, on our behalf.

How We Use the Information
We may use the information we collect to deliver personalized services, content and advertisements and to provide you with better information, discounts and other offerings from The CommuniKey™ discount program.  In addition, we may use the information you provide about yourself to fulfill requests for our products or services, to respond to inquiries about offerings or advertisements and to offer other products or offerings that may be of interest.  We may also use your information to send you information about our company and promotional material on behalf of our participants, to notify winners of sweepstakes or contests and to contact you when necessary.

We may share certain of your information with third parties who issue or manufacture The CommuniKey™ discount cards/mobile app(s) and/or with our participants. We will not provide your personally identifiable information to other third parties or mass marketers without your consent.  Unless you consent to the disclosure of your personally identifiable information, only we, our participants, the manufacturers of our discount cards/mobile app(s), our affiliates, our technical consultants, our third party auditors and any other third party representatives that are involved with maintaining our Site or providing associated services or who need the information to assist us in providing you with the best service possible have access to your personally identifiable information.

If you choose to submit content (e.g., a blog post), we may publish your name, screen name and other information you have provided to us.  We reserve the right to use any content you post in blogs, chat rooms, discussions or any other public section of our Site for promotional purposes, in e-mail newsletters, in promotional collateral, or elsewhere, both on its own and aggregated with any other information you provide, and by purchasing, registering or using The CommuniKey™ discount card/mobile app and/or using any part of our Site, you agree that we may use your information for these purposes.  You should exercise caution when deciding to disclose your personal information in these areas, since anyone, not just Millennial Connections, LLC, may use publicly posted information.

The information we collect in connection with our online/mobile forums and communities is used to provide an interactive experience. We use this information to facilitate participation in these online forums and communities and, from time to time, to offer you products, programs or services.

We sometimes use the non-personally identifiable information that we collect to improve the design and content of our advertisements, publications, offerings, and the Site, and to enable us to customize your experience with the Site. We also may use this information to analyze usage of the Site, as well as to provide you with certain offerings.

We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request. We may also transfer or disclose such information where necessary for the establishment, exercise or defense of legal claims.

Agents and contractors of Millennial Connections, LLC that have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for Millennial Connections, LLC.

We may use location information, either information provided by you or in information automatically collected, in order to provide you with content, services and advertising that are relevant to your geographic area.

We reserve the right to use the information you provide to offer you additional products and services from The CommuniKey™, our participants and/or other third parties that we think will be of interest to you. If you respond to such an offer and contact a third party directly, that third party’s privacy policy will apply to any information you provide and/or that is collected by such third party and we are not responsible for that party’s use of your information.

We also do disclose aggregated data to our advertisers, participants and other third parties to generate reports, marketing and technical research and for related business purposes. Our advertisers and participants enable us to provide our discount program and other services to you.  In return, they need to know how to effectively place their ads to potential customers.  For example, we may tell advertisers or participants how many people saw or clicked on an ad and additionally, how many people saw or clicked on ads in different portions of our Site.  Where available, we may offer additional information about viewer characteristics.

We may use third-party service providers to target and serve some of the advertisements you see on the Site. We may share technical or aggregate information, such as type of pages viewed and categories of interest, from our Site with these service providers and advertisers for their use in displaying ads on our Site. These third party providers and advertisers may use their own browser or flash cookies, web beacons and similar technologies to collect technical information (such as device unique identifier, IP address, MAC address, browser type, pages visited, and location information) from users of the Site that is generated automatically as a user views or interacts with an ad. These service providers may use that information, sometimes in conjunction with similar information gathered through other websites and other sources, to deliver advertisements on this Site, and on other websites.

Unless you affirmatively provide information within an ad, the data collected in connection with any ads, ad serving and ad targeting on our Site does not include your name, address, email address or telephone number, but it may include the device unique identifier, IP address, MAC address and location information of your computer or device. The use and collection of information by third-party advertising service providers is governed by the relevant third party’s privacy policy and is not covered by our Privacy Notice.

You may have the option to subscribe to receive various e-mail, mail and/or mobile phone updates when you register on our Site. We will use these updates to provide you with additional discounts, special offers, site upgrades, new features, events, promotions, and much more.

Please note that if Millennial Connections, LLC or any of its subsidiaries or lines of business is sold or otherwise disposed of, including through merger of, consolidation or sale of assets, the relevant customer database, including personally identifiable information we may possess about you, may, in whole or in part, be sold, disposed of, transferred or otherwise disclosed as part of that transaction.

Privacy Options
If you prefer not to receive traditional mail, e-mail, mobile phone or other messages or promotions from Millennial Connections, LLC, you may change your account preferences, if applicable, or contact Millennial Connections, LLC via e-mail (see Contact Info below).

Collection of Information by Third-Party Sites and Sponsors
Our Site may contain external links to other sites whose privacy practices may be different from ours. We are not responsible for the privacy practices of such sites, we have no control over the information you may provide to such sites and any information you provide to such sites will be governed by the privacy policies of the particular site.  You should always review a websites’ privacy policy before giving out any personal information.

We sometimes may offer contests, sweepstakes, promotions, or other activities or offerings that are sponsored or co-sponsored by or presented with identified third parties. By virtue of your participation in such activities or offerings, your device identifying information and the personally identifiable information that you voluntarily submit may be provided to both our Site and the third parties.  We have no control over the third parties’ use of this information.

We may use reputable third parties to present or serve advertisements, including online behavioral advertisements, that you may see on our Site and to conduct research about the advertisements. This privacy policy does not cover any use of information that such third parties may collect or may have collected from you (e.g., type of browser, operating system, domain name, day and time of visit, page(s) visited) or the methods used by the third-parties to collect that information (e.g., cookies, etc.).

Improper Conduct

The restrictions set forth herein will not apply in the event that you engage in certain improper conduct.  Specifically, Millennial Connections, LLC shall have the right to itself use or release to third parties personally identifiable information regarding users who are suspected of having used our Site or any other service provided by Millennial Connections, LLC for any fraudulent or inappropriate purposes, for having otherwise violated any law, rule, regulation, or the rights of third parties, or for having engaged in any conduct Millennial Connections, LLC deems improper.  By purchasing, registering or using The CommuniKey™ discount card/mobile app and/or using our Site, you are agreeing to our use or release of any information you provide in any manner we deem appropriate or necessary if you are suspected of having engaged in any conduct that Millennial Connections, LLC deems improper or inappropriate.

Our Commitment to Security
We have put in place appropriate physical, electronic and managerial procedures to safeguard and help prevent unauthorized access, maintain data security and correctly use the information we collect.   Notwithstanding anything herein to the contrary, although we take appropriate measures to safeguard against unauthorized disclosures of personally identifiable information, we cannot assure you that the personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy. No data transmission over the Internet is 100% secure.  Inadvertent disclosures may result, for example, when third parties misrepresent their identities in asking the site for access to personally identifiable information about themselves for purposes of correcting possible factual errors in the data.

Protection for Children
The site you are visiting is not intended for use by children. We have no intention of collecting personally identifiable information from children.  If a child has provided us with personally identifiable information, that child’s parent or guardian should contact Millennial Connections, LLC (see Contact Info below) if they would like the information submitted by the child deleted from our database.  We will use all reasonable efforts to delete such information from our database.

Changes to this Policy

This Privacy Policy may be changed by Millennial Connections, LLC at any time.  The revised Privacy Policy will be posted to this page so that you are aware of the information we collect, how we use it and under what circumstances we may disclose it.  By continuing to use the Site after we post any such changes, you accept the Privacy Notice as modified.

Your Consent

By purchasing, registering or using The CommuniKey™ discount card/mobile app and/or using our Site,you consent to the collection, use and storage of your personal and non-personal information as described herein.  You also authorize the export of personal information and its storage and use as specified above when you provide any such information to us.  The headquarters of Millennial Connections, LLC are located in Broome County, New York.  This policy and our legal obligations hereunder are subject to the laws of the State of New York and the United States of America, without respect to conflict of laws principles, regardless of the location of the user.   Any claims or complaints must be filed in the state and/or federal courts located in Broome County, New York.

How to Contact Us
If you have any questions or concerns about this Privacy Policy or its implementation please contact us via email at Binghamton@thecommunikey.com or at the following address:

Millennial Connections, LLC

P.O. Box 3401

Binghamton, NY 13902-3401

hhtp://www.thecommunikey.com
This Privacy Policy was revised August 17, 2014