Privacy Policy

Effective date: June 10, 2025

Thank you for using The Millennium Alliance website. The Millennium Alliance (“Millennium”, “us”, “we”, or “our”) is committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the Millennium services (including the https://mill-all.com/ website, and mobile and web-based applications, and any other tools, products, or services provided by Millennium that link to or reference this Privacy Policy) (collectively, the “Services”).

If you reside in the State of California, please click here to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for California Residents, the Privacy Notice for California Residents will prevail with respect to California Residents (as defined below) only.

If you reside in a country in the European Economic Area, the United Kingdom or Switzerland, please click here to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for European Residents, the Privacy Notice for European Residents will prevail with respect to European Residents (as defined below) only.

This Privacy Policy applies to information Millennium collects through the Services, as well as other information provided to us online or offline by third parties, when we associate that information with customers or users of the Services; however, it does not apply to information collected from our employees, contractors, or vendors. It also does not apply to information that you ask us to share with third parties or that is collected by certain other third parties whose software or services are featured or included in the Services (as further described below).

This Privacy Policy describes, among other things:

Personal and other information we collect about you;
How we use your information;
How we may share your information with third parties; and
Your choices regarding the personal information we collect about you.

By providing your phone number, you consent to receive SMS messages from us. You can opt-out at any time by replying “STOP” to any message you receive from us. You may also contact our customer service to be removed from our SMS list.

We use your data to provide and improve the Services, as set forth in this Privacy Policy.

1. Consent

By accessing or using the Services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services. Information gathered through the Services may be transferred, used, and stored in the United States, United Kingdom, or in other countries where our service providers or we are located. If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States, United Kingdom and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or Millennium are deemed to occur in the United States or United Kingdom, as applicable, where our servers are located.

2. Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Services to you.

We do not collect or use Personal Information (as defined below) for any purpose other than for our high-end conferences and events (“Assemblies”) or promoting our latest services & member content.
If we wish to use your Personal Information for new purposes, we will notify you via email or by phone before such use occurs, and we offer you the means to consent to those new purposes before such use occurs:

Types of Data Collected

a. Personal Information

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (collectively, “Personal Information”). Personal Information may include, but is not limited to:

Email address;
First name;
Last name;
Company name;
Title;
Phone number;
Credit card or debit card information (which you submit for payment purposes and which is collected by our third party payment gateway service provider (Stripe)); and
Information contained in any image, photograph or profile you submit to us.

Our Services may link with social media platforms, including LinkedIn, Meta, X, YouTube, TikTok, and Instagram. When you connect a social media account to our Services, then we may collect information about that social media account and share information with that social media account as described in the connection process. This collected information may include, but is not limited to, your name, email address, demographic information from your profile, friend lists, postings or other content, and your profile picture. You acknowledge and agree that Millennium is not responsible for the data collection or use practices of any such connected social media platform. You should read each social media platform’s privacy policy before connecting that social media account.

b. Usage Data

We may also collect non-Personal Information about how the Service is accessed and used (collectively, “Usage Data”), which is information that does not personally identify an individual. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We will not use Usage Data to try to identify you, and if we associate any Usage Data with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather Personal Information and Usage Data.

Information collected by the Services may be collected by us or one of the third parties we utilize in providing the Services (as further described below).

c. Tracking & Cookies Data

Every time you use the Services (e.g., access a Service webpage), we collect Personal Information and Usage Data (as discussed above in Sections 2 and 3) regarding that use. For example, to improve our Services, we collect how, when, and which parts of the Services or their features you use, and which social media platforms you link to the Services. Also, we may use your device’s unique identifier (UDID) or other unique identifiers to assist us in collecting and analyzing this data.

To assist us in collecting and storing this Usage Data, we may employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags.” We use Cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with a small amount of data, which may include an anonymous unique identifier, that a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used on our website are web beacons, pixels, tags, and scripts to collect and track information and to improve and analyze our Service. A web beacon, pixel or tag is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie. Your operating system and web browser may allow you to erase information stored in Cookies and local browser storage.. However, if you do so, you may be forced to login to the Services again, and you may lose some preferences or settings, or you may not be able to use some portions of our Service. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our Services may not function properly without it. We may use Cookies to keep you logged in, save your preferences for the Services, and to collect information about how you use our Services.

More information about managing Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

d. Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

4. Transparency and Choice; Do Not Track Signals

You may request access to your Personal Information by sending an email to [email protected]. We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to the Services using the deletion or removal options within the Services. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Services.

If you need further assistance with removing any content you posted through the Services, you can email us at [email protected]. Removal of your posted content may not ensure complete or comprehensive removal from our computer systems.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We may also require you to verify your identity to our satisfaction before providing you with access to Personal Information.

Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Services. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

We may use third-party service providers that collect information for interest-based advertising purposes (advertisements that are tailored to your likely interests, based on categories in which you have shown an interest). To learn more about these third parties and the choices they offer users, please visit the Network Advertising Initiative’s choices page or the Digital Advertising Alliance’s choices page. If you are reading this Privacy Policy from a mobile device, you can learn more about the DAA’s mobile choices program here.

We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we intend to adhere to the browser settings accordingly.

You can opt out of receiving marketing e-mails from us by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

5. Use of Data

Millennium Alliance uses the collected data for various purposes:

To provide and maintain the Services;
To notify you about changes to our Services;
To allow you to participate in interactive features of our Services when you choose to do so;
To provide you customer care and support;
To provide you analysis or valuable information so that we can improve the Services;
To monitor the usage of the Services; and
To detect, prevent and address technical issues.

6. Data Sharing

We do not pass any individual’s consent to receive SMS from Millennium to any third party. We do not share phone numbers with third parties to allow those third parties to send SMS.
We will never disclose any Personal Information, such as Phone numbers and SMS consent, with any third parties for marketing purposes.

7. Transfer Of Data

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States or United Kingdom, and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example, via email or by posting notice on our website.

Millennium will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

8. Disclosure Of Data

a. Legal Requirements

Millennium may disclose your Personal Information in the good faith belief that such action is necessary to:

To comply with a legal obligation;
To protect and defend the rights or property of Millennium;
To prevent or investigate possible wrongdoing in connection with the Services;
To protect the personal safety of users of the Services or the public; or
To protect against legal liability.

9. Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We utilize reasonable information security measures to safeguard your Personal Information against unauthorized access, modification, or destruction. For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to protect your Personal Information, we cannot guarantee its absolute security.

We restrict access to Personal Information in our possession to our employees, Service Providers (as defined below), and Online Tool Providers (as defined below) who need to know that information in order to operate, develop, improve or support our Services.

10. Service Providers and Online Tool Providers

We may employ third party companies and individuals (companies, agents, contractors, service providers, or others) to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services, to assist us in analyzing how our Service is used, or to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, and conducting audits). We may also disclose Personal Information and Usage Data to Service Providers. When we use a Service Provider, we require that the Service Provider use and disclose the Personal Information received from us only to provide their services to us or as required by applicable law.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We may also disclose Personal Information and Usage Data to Online Tool Providers. By “Online Tool Provider” we mean a licensor of software that we include in, or use with, the Services, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of Personal Information and/or Usage Data to the Online Tool Provider. Online Tool Providers may have the right to use Personal Information and Usage Data about you for their own business purposes. Use and disclosure of Personal Information and Usage Data by an Online Tool Provider is described in its privacy policy.

An Online Tool Provider may collect information automatically, in which case Personal Information and Usage Data it receives are subject to the Online Tool Provider’s privacy policy. The Online Tool Provider whose services we use may place Cookies on web browsers in order to serve ads based on past visits to our website. Online Tool Providers, including Google, use Cookies to serve ads based on a user’s prior visits to your website. This allows us to make special offers and continue to market our services to those who have shown interest in our service. If you wish to not have the information these technologies collect for the purpose of serving you ads, you may opt-out here, or if located in the European Union, click here. SMS consent is not shared with any third parties.

Some Online Tool Providers may allow you to opt out of certain collection and/or uses of your information. You can read more here:

11. Links To Other Sites

Our Services may contain links or integrate with other third-party sites, services or apps that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

12. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take steps to remove that information from our servers.

13. SMS Terms of Service

a. Introduction

By accessing or using our services, including receiving SMS communications, you agree to comply with and be bound by these terms and conditions in this section. If you do not agree with these terms, please do not engage with our Services.

b. Consent for SMS Communication

The information (Phone Numbers) obtained as part of the SMS consent process will not be shared with third parties for marketing purposes.

By providing your consent to receive SMS communications, you acknowledge and agree to receive text messages from Millennium Alliance at the phone number you provide.

c. Types of SMS Communications

If you have consented to receive text messages, you may receive SMS communications related to the following:

Appointment reminders;
Follow-up messages;
Event Invitations; and
Event reminders.

Example: This is Reilly from the Millennium Alliance. We’re hosting a CTO Dinner on Thursday February 20th from 5:30-8:30pm at Sepia in Chicago, and I am reaching out to personally invite you to attend. We are bringing together 15 executives for an evening of networking and roundtable discussions. Attendance is free, includes transportation to the event, and the dinner is CPE-accredited (3 hours). Are you interested in joining? Reply STOP to opt-out of SMS Messaging

Example: We’re just 2 weeks away from seeing you for our Transformational CMO Assembly on February 11-12th at the Omni in Charlotte. Please reply if you need anything between now and then. Reply STOP to opt-out of SMS Messaging.

Example: This is Ben from Millennium. Hoping my name rings a bell from when we connected a few months ago about a dinner in NYC. We are putting together another CISO Dinner on August 14th at Manhatta, and it would be great to get you involved. Reply STOP to opt-out of SMS Messaging.

d. Messaging frequency may vary.

Message frequency may vary depending on the type of communication.

Example:

“Message frequency may vary. You may receive up to 2 SMS messages per week regarding your appointments or follow-up messages.”

e. Potential Fees for SMS Messaging:

Please note that standard message and data rates may apply, depending on your carrier’s pricing plan. These fees may vary if the message is sent domestically or internationally.

f. Opt-In Method:

You may opt-in to receive SMS messages from Millennium Alliance in the following ways:

By submitting an online form.

g. Opt-Out Method:

You can opt out of receiving SMS messages at any time. To do so, simply reply “STOP” to any SMS message you receive. Alternatively, you can contact us directly to request removal from our SMS list.

h. Help:

If you are experiencing any issues, you can reply with the keyword HELP. Or you can get help directly from us at our contact website or email address: [email protected]

Additional Options:

If you do not wish to receive SMS messages, you can choose not to check the SMS consent box on our forms.

i. Standard Messaging Disclosures:

Message and data rates may apply.
You can opt-out at any time by texting “STOP.”
For assistance, text “HELP” or visit our Privacy Policy. Message frequency may vary.

14. Certain State Residents

You may be aware that certain states in the United States have enacted mandatory privacy laws that provide residents of those states with certain rights regarding their personal information. As of the date this Privacy Policy was last updated, such states include California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, and New Jersey.

If you reside in the State of California, please click here to learn more about your privacy rights. Our Services are not currently subject to the laws in Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, and New Jersey. However, we do provide notice and transparency about our collection and use of Personal Information as described in this Privacy Policy.

15. Residents of Canada

If you have an objection to the use of your Personal Information as described in this Privacy Policy, you may file a complaint by sending an email to [email protected]. We will attempt to accommodate your objection or complaint, but you understand that, to the extent you object to our processing of Personal Information that is necessary for us to provide the Services to you, certain features and functionalities of the Services may no longer be available to you. Nothing in this Privacy Policy prejudices your rights to file a complaint with the Office of the Privacy Commissioner of Canada, and/or with any other applicable data protection authorities.

16. Residents of Nevada

We do not sell your Personal Information. However, you may contact us at [email protected] with questions.

17. Changes To This Privacy Policy

We may modify or update our Privacy Policy from time to time with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our website. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. IF YOU DO NOT AGREE TO CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE OF THIS PRIVACY POLICY).

18. Contact Us

If you have any questions about this Privacy Policy please contact [email protected].

Privacy Notice for California Residents

This Privacy Notice for California Residents (the “Notice”) supplements the information contained in our Privacy Policy and applies only if you reside in the State of California (you are a “California Consumer”).

For purposes of this Notice “Sell,” “Selling,” “Sale,” or “Sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to another business or a third party for monetary or other valuable consideration.

“Share”, “Shared,” or “Sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to a third party for Cross-context Behavioral Advertising, whether or not for monetary or other valuable consideration.

“Cross-context Behavioral Advertising” means the targeting of advertising to a consumer based on that consumer’s Personal Information obtained from activity across businesses or distinctly-branded websites, applications, or services, other than the business or distinctly-branded website, application, or service with which the consumer intentionally interacts. (In other words, if we send you an ad based solely on your interaction with us or our Services, this is not Cross-context Behavioral Advertising.)

“Sensitive Personal Information” means Personal Information that is not publicly available and reveals one or more of the following:

A consumer’s Social Security, driver’s license, state identification card, or passport number;
A consumer’s account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
A consumer’s precise geolocation;
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
The contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication;
A consumer’s genetic or biometric data;
A consumer’s neural data; or
Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

“Verifiable Request” means that the identifying information provided by a consumer in connection with a request matches the Personal Information of the consumer already maintained by us. Identifying information you can submit in order to permit Millennium to verify your Verifiable Request may include your first and last name, the email address and phone number that is associated with your account, and a secure confirmation code that we provide to you via email.

1. Information We Collect

In the past twelve (12) months, Millennium has collected the following categories of Personal Information from California residents:

Identifiers (names, personal or business addresses, email addresses, and IP addresses).
Other information which is not required to use our Services but that you choose to provide to us through an online form.

In the past twelve (12) months, Millennium has not collected Sensitive Personal Information from California residents.

Millennium obtains this Personal Information from the following types of sources:

Directly from you. For example, from forms you complete or products and services that you purchase.
Indirectly from you. For example, from information automatically sent by your web browser or from analyzing data about your actions on our website.

2. Use of Personal Information

Millennium may use or disclose the Personal Information we collect for one or more of the following “Business Purpose(s):”

To fulfill or meet the reason you provided the information
To provide our website or online services;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
To respond to your requests under the California Consumer Privacy Act of 2018 (the “CCPA”), as amended
For any other purpose described to you when we collect your Personal Information; and
For any other acceptable purposes as set forth in the CCPA.

Unless we notify you otherwise, we will not collect additional categories of Personal Information, nor use the Personal Information we collect for any other materially different, unrelated, or incompatible purposes.

3. Retention of Personal Information

We retain each category of your Personal Information for no longer than is reasonably necessary for one or more Business Purposes, subject to your right to request we delete your Personal Information. Due to the nature of the Services, it is not possible to predict the length of time that we intend to retain your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your Personal Information for one or more disclosed Business Purpose(s):

Whether or not there is a retention period required by statute or regulations;
Pendency of any actual or threatened litigation for which we are required to preserve the information;
Generally accepted best practices in our industry; and/or
Pendency of applicable statutes of limitations for potential legal claims.

When we determine that it is no longer reasonably necessary to retain your Personal Information for one or more disclosed Business Purpose(s) based on the above criteria, we will delete your Personal Information.

4. Disclosure of Personal Information

Millennium may disclose Personal Information to our “service providers”, to our “contractors”, and to “third parties” (each as defined by the CCPA) for a Business Purpose. When we disclose Personal Information for a Business Purpose, we enter into an agreement with the receiving party that describes the purpose for sharing the Personal Information, and that requires the receiving party to keep that Personal Information confidential. In the case of disclosures to our “service providers,” our “service providers” are obligated not to use the Personal Information for any purpose other than performing the services according to their agreement with us. In the case of our “contractors”, our “contractors’ are obligated not to use the Personal Information for any purpose unrelated to the business purpose for which we’ve engaged them.

We may disclose your Personal Information with the following categories of entities: (i) “service providers”, (ii) “contractors”, and (iii) sponsors and attendees of our events.

In the past twelve (12) months, Millennium has not Sold or Shared any Personal Information about its California Consumers.

5. Your Rights and Choices

If you are a California Consumer, you may request information about our collection, use, disclosure and Sale of your Personal Information over the past twelve (12) months, whether or not it was collected electronically. If you submit a Verifiable Request, we will provide you with information regarding:

the categories of Personal Information we have collected about you; the categories of sources from which your Personal Information was collected; our Business Purpose for collecting, Selling, or Sharing your Personal Information; the categories of third parties with whom we disclose that Personal Information; and the specific pieces of Personal Information we collected about you; and
if we Sold, Shared, or disclosed your Personal Information for a Business Purpose: what categories of Personal Information we Sold or Shared, and to which categories of recipients we Sold or Shared it; and what categories of Personal Information we disclosed for a Business Purpose, and to which categories of recipients we disclosed it.

You also have the right to request a copy of your Personal Information, and/or to request that we transmit your Personal Information to another entity. To the extent technically feasible, we will comply with your request and provide and/or transmit your Personal Information in a structured, commonly used, machine-readable format.

You also have the right to request that we delete any of your Personal Information that we collect or maintain by submitting a Verifiable Request. We may deny your deletion request if retaining your Personal Information is necessary for us or our “service providers” or “contractors” to:

Complete the transaction for which we collected your Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide goods or services that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Help to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the ability to complete such research, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information; or
Comply with a legal obligation.

You further have the right to request that we correct any of your Personal Information that is inaccurate by submitting a Verifiable Request. We will correct any inaccurate Personal Information pursuant to your request to the extent possible using commercially reasonable efforts. We may deny your correction request if the Personal Information is accurate. We may also delete your Personal Information instead of correcting it to the extent such deletion would not negatively impact you. If you choose to exercise a privacy right under the CCPA, you have the right not to receive discriminatory treatment.

You may submit a Verifiable Request for the information listed above, or exercise any of your rights enumerated under this Notice, by calling us at 1-888-491-5864, or by completing a form on our website, available here. You may also submit a Verifiable Request on behalf of your minor child.

After we receive your Verifiable Request, we will provide to you, in writing and free of charge (unless your request is excessive, repetitive, or manifestly unfounded), the requested information for the 12-month period preceding your request (unless you specifically request disclosure beyond such 12-month period, in which case, we will process your request with respect to Personal Information we have collected during the time period you specify, provided that (a) the earliest date that your request may apply to is January 1, 2022, and (b) processing your request does not require disproportionate effort). You can choose to have this information delivered to you by postal mail, or electronically. We will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. Please note that we are not required to comply with your request for information more than twice in any 12-month period. If applicable, our response will explain the reasons why we cannot comply with your request.

Millennium does not and will not, without first obtaining your consent, Sell or Share Personal Information.

Should you choose to exercise any of the rights enumerated under this Notice, we will not:

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

However, please be aware that it may be a functional necessity for our Services to have Personal Information about you in order to operate, and we may not be able to provide some or all of our Services to you if you direct us to delete your Personal Information.

PRIVACY NOTICE FOR EUROPEAN RESIDENTS

If you are a resident of a country in the European Economic Area (a “European Resident”), the United Kingdom (a “UK Resident”), or Switzerland (a “Swiss Resident”) then information we collect from you may be subject to (i) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “EU GDPR”), (ii) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), as implemented by the UK Data Protection Act of 2018, and as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of Section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”), or (iii) the Swiss Federal Act on Data Protection (the “FADP”) (collectively, “Data Protection Laws”), the following additional information is provided for your benefit. For purposes of this Privacy Notice for European Residents, in addition to the meaning set forth in the Privacy Policy, “Personal Information” shall also include “personal data” as that term is defined by the EU GPDR, UK GDPR, and FADP, as well as “personal data” or similar terminology as defined by other applicable Data Protection Laws.

The controller of the Personal Information collected through the Services is:

The Millennium Alliance
475 Park Avenue S, 31st Floor
New York, NY 10016

If you use the Services, you acknowledge that your Personal Information is being processed pursuant to the lawful bases described below, and you specifically consent to your Personal Information gathered through the Services being transferred, used, and stored in the United States or other third party countries which do not have local privacy laws that are equivalent to the Data Protection Laws. You acknowledge and agree that the local laws in such countries may be materially different from, and provide for a lesser degree of protection regarding your Personal Information (including, but not limited to, with respect to governmental and law enforcement agencies’ ability to access your Personal Information under certain conditions) than, Data Protection Laws.

1. Personal Information

If you use the Services, we may collect certain categories of Personal Information, as described in Section 5 of the Privacy Policy.

2. Your Rights

You have the following rights under applicable Data Protection Laws:

You have the right to know why we collect your Personal Information, how and why it is processed by us, and what our legal bases for such processing are.
Right of access: you have the right to access your Personal Information.
Right to rectification and deletion: you have the right to supplement or correct the Personal Information we’ve collected about you, or to direct us to delete your Personal Information.
If you give us your consent to process your Personal Information, you have the right to revoke that consent.
Right to data portability: you have the right to request that we transfer all your Personal Information to another controller in a reasonably understandable format.
Right to object: you may object to our processing of your Personal Information. We will make commercially reasonable efforts to comply with your objection, unless there are legally permissible reasons why we can or must continue to process your Personal Information.

3. Lawful Bases for Processing

Under European law, companies must have a legal basis to process data. You have particular rights available to you depending on which legal basis we use, and we’ve explained these above. You always have the right to request access to, rectification of, and erasure of your data under applicable Data Protection Laws. To exercise your rights, please email us at [email protected].

Pursuant to a contract with you:

We may process data as necessary to perform our contracts with you. We describe the contractual services for which this data processing is necessary throughout our Privacy Policy. The main uses of your data necessary to provide our contractual services are described in the Use of Your Information section of the Privacy Policy.

We’ll use the Personal Information we have to provide the Services and as otherwise described in our Privacy Policy if you choose not to provide certain data, the quality of your experience using the Services may be negatively impacted.

When we process data you provide to us as necessary to perform our contracts with you, you have the right to receive a portable copy of it (meaning to receive a copy of your data in a structured, commonly used and machine-readable format) under applicable Data Protection Laws. To exercise your rights, please email us at [email protected].

The other legal bases we rely on in certain instances when processing your data are:

Your Consent:

We may process your Personal Information on the lawful basis of consent.

When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time and to receive a portable copy of the data you provide to us, under applicable Data Protection Laws. To exercise your rights, please email us at [email protected].

Legitimate Interests:

We may process your Personal Information where our legitimate interests, or the legitimate interests of a third party, are not outweighed by your interests or fundamental rights and freedoms.

The legitimate interests for our processing of Personal Information are to:

Assist us in providing, maintaining, and protecting the Services;
Set up, maintain, and protect accounts to use the Services;
Improve our online operations;
Process transactions;
Provide customer service;
Communicate with you, such as provide you with account- or transaction-related communications, or other newsletters, RSS feeds, and/or other communications relating to the Services;
Send or display offers and other content that is customized to your interests or preferences;
Perform research and analysis aimed at improving our products and services and developing new products or services;
Manage and maintain the systems that provide the Services
Prevent and address fraud, unauthorized use of the Services, violations of our terms and policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or products), our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm; and
Operate of our day-to-day business and planning, including executing strategic corporate transactions, such as mergers.

You have the right to object to, and seek restriction of, such processing; to exercise your rights, please email us at [email protected].

We will consider several factors when assessing an objection to our processing in furtherance of Millennium’s legitimate interests, including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

Compliance with a legal obligation:

We need to process your Personal Information when applicable law requires it, including, for example, if there is a valid legal request for certain data.

4. Disclosures of Your Information

“Processors” means our Service Providers and their respective service providers.

We may also disclose your Personal Information, (as well as Usage Data, without the same restrictions that apply to your Personal Information) to our Processors who we engage to perform certain functions for us, or on our behalf (including, but not limited to, processing of payments, provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics). A list of our Processors and a description of the services that they perform for us follows. We establish data processing agreements that govern our Processors’ use of your Personal Information, but our Processors’ use of your Personal Information may also be subject to the Processors’ own privacy policies. See the following links to our Processors’ privacy policies: Google Ads; Zoom Information, Inc., HubSpot, Microsoft Corporation, LinkedIn, Beeswax Inc., and Meta Platforms, Inc.

5. Retention of Your Information

We retain each category of your Personal Information for no longer than is reasonably necessary for one or more of the above lawful bases for processing, subject to your right to request we delete your Personal Information. Due to the nature of the services, it is not possible to predict the length of time that we intend to retain your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your Personal Information for one or more disclosed lawful bases for processing:

When we determine that it is no longer reasonably necessary to retain your Personal Information for one or more disclosed lawful bases for processing based on the above criteria, we will delete your Personal Information.

6. Questions and Complaints

If you have any questions or complaints regarding our use of your Personal Information, please contact us at [email protected]. You also have the right to submit a complaint to your applicable Data Protection Authority.