Privacy Policy

The Millard Group, LLC (“Millard”, "Company", "we", "us" or "our") is committed to respecting the privacy of our clients, website visitors and their employees and/or users. This Privacy Policy describes how our website operates and how we collect, use, and share Personal Information, as defined herein. This Privacy Policy ("Policy" or "Privacy Policy") applies to http://themillardgroup.com and other linked Millard websites, services or products that reference or link to this Privacy Policy (collectively, the “Site”).

By accessing and utilizing our Site, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by this Policy and our Terms of Use.  Please note, if you elect not to share your Personal Information with us, we may be unable to provide you with certain items, services, and functionalities we offer through our Site.

1. Categories of Personal Information We Collect and How We Collect It

To provide you with access to certain services or data within our Site, we may require that you provide certain Personal Information. The term "Personal Information" as used in this Policy means any information that identifies an individual either alone or in combination with other data. We may also collect information that does not, on its own, identify an individual person. When non-identifying information is combined with other information so that it does identify an individual person, we treat the combination as Personal Information.

We collect the following Categories of Personal Information:

  •           Contact Information

What we collect: name, address, email address, telephone number, and account credentials (if you provide it to us and/or create an account to access the Site).

How we collect it:                                                                                                                                                                                                                        We only collect Contact Information when you provide it to us. For example, by submitting your email address or other contact information through the “Contact” page and/or to receive news and other information from us.

  •           Communications

What we collect: communications, reviews, or other messages you send us containing Personal Information.

 

How we collect it:

We only collect information from Communications when you provide it to us by submitting an inquiry, signing up to receive emails or text messages from us, or otherwise communicating with us through our Site.

 

  •           Browser & Site Access Information (“Clickstream” Information):

This includes information which may include the name of the domain and host from which you access the Internet; the browser software you use and your operating system; the internet address of the website from which you linked to the Site; the internet address of the device you used to access the Site (i.e., IP Address) and device identifiers, referral URLs, pages viewed, clicks and session activity, the general location from which such access occurred, and the times when you accessed the Site.

How we collect it:

We collect this information automatically when you browse or download content from our Site using certain data collection tools described more fully under “Cookies and Tracking Activity” below.

 

The Site does not collect sensitive personal information, such as Social Security numbers, race or ethnic origin, religious or philosophical beliefs, political affiliations or opinions, genetic or biometric data, health information, information about sexual orientation or history, precise geolocation data, or other information considered to be “sensitive” under applicable privacy laws. AT NO TIME SHOULD YOU SUBMIT ANY SENSITIVE PERSONAL INFORMATION TO THE SITE.

2. How We Use Personal Information

Our legal basis for processing your Personal Information is your consent, which you provide by using our Site and providing us with Personal Information. We use Personal Information collected on our Site to process requests and transactions you make through the Site and deliver the content or services you may request. To do this, it may be necessary to share Personal Information with carefully selected vendors and business partners we work with. We also may use Personal Information, together with preferences you indicate, to customize your online experience and to provide you with more relevant information and updates.

We may use or process (or disclose to a service provider to use or process on our behalf) the Personal Information we collect for one or more of the following business purposes:

  •          To fulfill or satisfy the reason for which the information was provided, including without limitation processing requests, providing services, responding to complaints/inquiries, or fulfilling our other obligations to you.
  •          To provide you with information, products or services that you request from us.
  •          To maintain and improve our services, and the Site.
  •          To provide you with email alerts, event registrations and other notices concerning our services, events or news that may be of interest to you.
  •          To administer marketing and email campaigns.
  •          To communicate with you and provide you with user support.
  •          To improve our Site and for testing, research, analysis and product development.
  •          To track and measure advertising on the Site.
  •          To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including this Policy and our Site Terms of Use.
  •          As necessary or appropriate to protect the rights, property, health, or safety of Millard or others, including without limitation in the detection and prevention of fraud, and the exercise or establishment of our legal rights or defenses.
  •          To comply with our legal, tax, accounting, regulatory, or contractual obligations.
  •          To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  •          As described to you when collecting your Personal Information or as otherwise set forth in this Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different or unrelated purposes without updating this Policy.

Protection of Personal Information. We maintain reasonable administrative, technical, and physical safeguards to protect the Personal Information we collect and process.

Retention of Personal Information. We retain Personal Information for a reasonable period after we no longer need it for the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose), taking into account legal requirements that apply to us as well as our legitimate interests. When you provide us your Contact Information to receive information about our services or our commercial offers, we will retain the information until you withdraw your consent by unsubscribing or as described below under “Your Individual Rights.”

De-Identified, Anonymous, or Aggregate Data. We may de-identify your Personal Information by removing data elements that specifically identify you or can be reasonably linked to you and/or used to identify you. We may also use anonymous data, which does not identify you on its own or when combined with data from other parties. Examples of anonymous data include analytics or information collected from cookies. Aggregate Data is data that have been collected from multiple sources and combined into summary format, often for statistical analysis or reporting. Aggregate Data does not identify you personally. We use Aggregate Data for product and service development, market analysis, and to understand how to improve the quality of our Site. Data that are de-identified, anonymous, or aggregated as described above are not considered Personal Information and are not subject to this Policy. We may use or share De-Identified, Anonymous, or Aggregate Data for any lawful purpose.

3. How We Share Personal Information

We will not sell your Personal Information. We will process your Personal Information for the purpose it was collected and as described in this Privacy Policy, including as follows:

  •          With third parties to whom you authorize us to disclose your Personal Information;
  •          With our trusted service providers to process Personal Information on our behalf, including without limitation (i) service providers that support website hosting, payments, fraud prevention, marketing, analytics, accessibility, customer support, and accounting, and (ii) as described above under “How We Use Personal Information”;
  •          With affiliated entities under common control with us;
  •          With businesses we partner with to provide services to you or our clients;
  •          With our auditors, legal advisors, and similar third-party professionals; 
  •          For marketing campaigns conducted by us or a third-party service provider to offer products or services we believe may be of interest to our clients;
  •          In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business; 

Our service providers and our affiliates are required to keep confidential and secure the Personal Information received from us substantially in accordance with this Privacy Policy, and they may not use Personal Information for any other purpose other than for the purpose for which we provided it.  When we share your Personal Information with service providers we engage to process data on our behalf, including our affiliates, we will ensure those third parties are contractually bound to provide the same levels of privacy protection and confidentiality observed by Millard when handling your Personal Information, and as required under applicable laws.

Our Site currently uses the following third-party service providers:

Google Analytics: This service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics. For more information, please refer to Section 5 “Cookies & Tracking Activity” below.

In addition to the above, we may share your Personal Information with certain service providers as described in Section 5 (Cookies and Tracking Activity). For more information about your rights to decide how we share your Personal Information, please refer to “Your Individual Rights and Choices” below.

We may also share information with third parties in the following unique circumstances:

  •          when required by law or to otherwise cooperate with law enforcement activity; or
  •          when it is necessary to protect our rights or property from fraudulent, abusive, or unlawful activity, to the extent permitted by law, including sharing Personal Information in connection with credit risk reduction and fraud protection.

 

4. Your Individual Rights and Choices

You may access, verify, update, or correct your Personal Information, or have any of your Personal Information deleted as more fully described below. You may also ask us to change your preferences regarding how we use or disclose your information or let us know that you do not wish to receive any further communication from us.

Access to Specific Information and Data Portability Rights. You have the right to request that we disclose 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, we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting your Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you.
  • If requested, we will provide you with a copy of your personal information in a machine-readable format.

You may contact us for such information or to opt out of the sharing of your personal information with third parties for marketing purposes at any time by contacting us as described below under “How to Exercise Your Rights”.

Correction Request Rights. You have the right to request that we correct any inaccurate Personal Information that we collected and retained about you, subject to certain exceptions. You may be able to correct certain information yourself by logging in and updating your online profile if our Site includes such functionality. With respect to any Personal Information unavailable for editing within your online profile, once we receive and confirm your verifiable consumer request, we will update (and direct our service providers to update) your Personal Information within our records, unless an exception applies. We may deny your correction request if we cannot verify your identity, or if we determine, under the totality of the circumstances, that the contested Personal Information in our possession is more likely than not to be accurate.

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. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise a right provided for by law;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it and applicable law.

Non-Discrimination.  We will not discriminate against you for exercising any of your rights described in this Privacy Policy. Unless otherwise permitted by applicable law, we will not:

  • Deny you services;
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of services; or
  • Suggest that you may receive a different price or rate for items or services or a different level or quality of items or services.

How to Exercise Your Rights: To exercise the access, data portability, correction, deletion, and other rights described in this Privacy Policy, please submit a verifiable consumer request to us via email to michael@themillardgroup.com.

Only you or a person that you authorize to act on your behalf, as evidenced by registration with the Secretary of State in which you reside, 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 verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • 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.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not generally charge a fee to respond to your verifiable consumer request.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Cookies & Tracking Activity

Our Site uses cookies to provide you with a personalized user experience. Other information we collect with cookies allows us to statistically analyze usage of our Site, and to improve and customize our content and other offerings.

“Cookies” are small text files that are automatically placed on your computer or other device when you visit a website. The cookies are stored by the internet browser. The browser sends the cookies back to the website on each subsequent visit, allowing the website to recognize your computer or device. This recognition enables the website provider to observe your activity on the website, deliver a personalized, responsive service, and improve the website.

Cookies make the use of our Site easier by, among other things, saving your preferences. We may also use cookies to deliver content tailored to your interests. Our cookies may enable us to relate your use of our Site to Personal Information that you previously submitted.

Categories of Cookies We May Use.  To support our Site and our services, we may use one or more of the following cookies throughout our Site for the purposes set forth below:

  • Essential Cookies: These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. These cookies do not track your internet use or gather information about you that could be used for marketing purposes. Examples of how we may use essential cookies include:
    • Establishing unique identifiers for each unique visitor to our Site to track performance and utilization of the Site;
    • Optimizing user experience; and
    • Storing user consent data collection. 
  • Functionality or Customization Cookies: These cookies allow us to remember choices you make when you use our services. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site. These cookies do not track your internet use or gather information about you that could be used for marketing purposes. Examples of how we may use functional cookies include:
    • Gathering data about visits to our Site, including numbers of visitors and visits, length of time spent on the site, pages clicked on or referring URL;
    • Eliminating the need for returning users to re-enter their login details;
    • Confirming your browser’s language preference.
  • Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Site and how users use our Site and services. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Site, the website that referred them to our Site, the pages that they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information, and to monitor the level of activity on our Site. We use Google Analytics to improve how our Site operates, to help us understand general website traffic, and to improve our communications and outreach efforts. This feature may use your Google account information if you are signed in to Google and have enabled ads personalization, subject to Google’s settings and consent. Google Analytics uses its own cookies.
  • Behavioral Advertising Cookies: Behavioral advertising cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on the web more relevant to you.  Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify you personally. Examples of how we may use advertising cookies include:
    • to market to specific users across our Site, and third-party websites, so that we and third parties can target advertising to users that will be more relevant to users’ interests;
    • to facilitate social sharing features; and
    • to create a unique ID for each visitor to the Site to present relevant advertising.
  • Opting out of Behavioral Advertising Cookies: If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps or use the platform controls on your mobile device to opt out.

Web Beacons.  We may also use other similar technologies on our Site to recognize and track visitors to our Site. A web beacon (also known as a “tracking pixel” or “clear GIF“) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie. Certain email communications you receive from us may contain web beacons. Web beacons allow us, for example, to obtain information such as the IP address of the computer device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the browser type used to view the page and the information in cookies. We use web beacons for activities such as monitoring the effectiveness of our communications, to understand whether users have come to our Site from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve Site performance.

Third-Party Cookies.  Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) use third-party cookies in connection with your use of their Site and services, over which we have no control. These third-party cookies are likely to be analytical or performance cookies or targeting cookies. These companies may use information about your visits to our Site and other sites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements.

Additional Information About Cookies. For a current list of the cookies and tracking technologies used on our Site, including their purpose, provider, and duration, please review our Cookie Declaration https://www.themillardgroup.com/privacy-policy/cookie-declaration/. You can also find general information about cookies and how they work, and how to manage and delete them at http://www.allaboutcookies.org.

Managing Cookies.  You can adjust your computer browser settings so that you are informed when a cookie is being placed on your browser. You can also set your browser to decline or accept all cookies. When you first access our Site you may receive a message advising you that cookies and similar technologies are in use. By clicking “accept cookies,” you understand and agree to the use of the cookies and use of similar technologies described in this Policy.

Do Not Track.  Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the website you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Site does not currently respond to DNT signals. You can use the range of other tools we provide to control data collection and use, as described above. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

6. Advertising & Communications

Retargeting Ads:

Throughout the Site, Millard may utilize tools provided by Google AdWords to support Display Advertising, such as Remarketing (including cross-device remarketing functionality), Google Display Network Impression Reporting, data collection via advertising cookies and anonymous identifiers and/or Google Analytics Demographics and Interest Reporting. In general, this means that third-party vendors, including Google, may show Millard ads on sites across the Internet based upon visits to our Site.

To implement these tools, Millard and third-party vendors, including Google, use first-party cookies and third-party cookies together to inform, optimize, and serve ads based on past visits to the Millard Site. You can find more information about how Google uses AdWords information by reading the Google AdWords Privacy Policy. Google users can control their ads experience (or opt out of personalized ads altogether) at My Account. For information about how to opt out, please click here: Opt-out of Google remarketing

Newsletters & Marketing Communications

On the Site, you may subscribe to newsletters and marketing communications, which may be used for advertising purposes. If you opt-in to receive marketing emails, we may send you updates, announcements, editorial content, or promotional communications. You can opt out at any time by clicking the unsubscribe link in the email or by contacting us.

All newsletters and marketing communications sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows us to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

SMS/RCS Communications

We may collect mobile phone numbers to communicate with you via SMS and/or RCS text messages. Your mobile number will not be sold or shared with third parties or affiliates for marketing or promotional purposes. We will not use your number for unrelated marketing without your express written consent.

Message frequency may vary. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. Text messages sent via SMS and RCS channels are not fully secure; however, we take reasonable precautions to safeguard your privacy by restricting the content of these messages to non-sensitive notifications. You may opt out of receiving text messages at any time by replying "STOP." You will receive a final confirmation text to verify you have opted out. No further messages will be sent. If you would like to rejoin, you can authorize us to restart by texting "START." For help, reply “HELP” or contact us at michael@themillardgroup.com.

7. Miscellaneous 

a.   Third-Party Sites.  Our Site may contain links to other websites that operate independently from Millard. Linked websites may have their own privacy policies or notices.  If you visit any linked websites, we strongly suggest you review their privacy policy.  Any information you provide when you visit a nonaffiliated website is subject to the privacy policies posted on those websites.  We are not responsible for the content of any websites that are not affiliated with or owned by Millard, any use of those websites, or the privacy practices of those websites. If you have an account or profile with a third-party website, and choose to use, follow, like, friend, or comment on a third-party website, certain Personal Information associated with your account may be made available to us based on the privacy policies of the third-party website and your privacy settings within that website. We do not share Personal Information made available through these websites, except with our employees, subcontractors or service providers as required to enable us to respond to inquiries or complaints. We may also provide social media features on our Site that enable you to share information with your social networks and to interact with us on various social media sites.  Your use of these features may result in the collection or sharing of information about you, depending on the feature.  We encourage you to review the privacy policies or notices and settings on the social media Site with which you interact to make sure you understand the information that could be shared by those sites. You may elect to not use Millard’s social media features and/or adjust your personal settings and preferences to protect your privacy.

 

b.   Advertisements Linking to our Site. We may hire other companies to place our banner ads on other websites and to perform tracking and reporting activities (“Third-party advertisement servers”). They do not collect personally identifiable information in doing this work for us, and we do not give any of your Personal Information to them. Third-party advertisement servers are subject to their own privacy policies. If you would like more information about the privacy policies of these third-party advertisement servers, including information on how to opt out of their tracking methods, we refer you to the privacy policies of their websites.

 

c.    Applicability to Children. Our Site is not intended for children. We do not knowingly solicit data online from or market online to children under the age of 13. IF YOU ARE UNDER THE AGE OF 13 AND WOULD LIKE TO CONTACT US PLEASE DO SO ONLY THROUGH YOUR PARENT OR LEGAL GUARDIAN.  IF YOU ARE UNDER THE AGE OF 13, PLEASE DO NOT SEND US ANY PERSONAL INFORMATION INCLUDING WITHOUT LIMITATION YOUR EMAIL ADDRESS, NAME AND/OR CONTACT INFORMATION. 

In the event we learn that we have collected Personal Information from a person under the age of 13, we will delete that information as soon as reasonably practicable. If you believe we might have information from or about a person under the age of 13, please contact us at michael@themillardgroup.com.

 

d.   Information for Users Outside the United States. Our Site is operated in the United States and Millard is not established in any other country, nor does it target citizens in other countries with respect to the Site.  If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the United States.  By using our Site or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. However, no system is completely secure or error-free. We do not, and cannot, guarantee the complete security of your information.

 

e.   Changes to this Policy. We may change this Privacy Policy from time to time at our discretion. We will indicate at the top of the Privacy Policy when it was most recently updated. We will not use your Personal Information in ways that differ materially from this Privacy Statement without prior notice to you, and in no event will we use your Personal Information in ways prohibited by law. We encourage you to check this page frequently for any changes to our Privacy Statement. Your continued use of the Website and/or continued provision of Personal Information to us will constitute your acceptance of such change and will be subject to the terms of the then-current Privacy Statement.

Contact Us.  To exercise any of your rights under this Privacy Policy or for any questions regarding this Policy, we encourage you to contact us by emailing michael@themillardgroup.com or regular mail at:

The Millard Group

109 Broad Street

Middletown, CT 06457