# Privacy Policy #### 1. Our Commitment to Your Privacy This Privacy Policy explains how the corporation organized under the laws of the State of Delaware, USA, that operates the MIRAI service (referred to as "the Company," "we," "us," or "our") processes your personal information. We believe in your right to privacy and are committed to being transparent about our data practices. This policy applies globally to all personal information we collect and use through our websites, mobile applications, marketing activities, and all other related services (collectively, the "Services"). We may update this policy from time to time. Please review it regularly to stay informed of any changes. #### 2. What Personal Information We Process We collect personal information in several ways: information you provide, information from third parties, and information we collect automatically. **2.1. Information You Directly Provide** * Account and Contact Data: Your first and last name, email address, phone number, billing and mailing address, professional title, and company name. * User Content: Any information, prompts, files, images, or audio you provide or upload when using the Services. This content may be used to provide, maintain, and improve the Services as described in Section 3 * Communications and Feedback: Information you provide when you contact us for support, participate in surveys, or give us feedback, including your name, contact details, and the content of your message. * Payment and Transactional Data: Payment card details or bank account information for billing, along with your transaction and payment history. * Marketing Preferences: Your preferences for receiving marketing communications and your engagement with them. * Demographic and Preference Information: Details such as your city, country, age, marital status, or hobbies, if you choose to provide them. * Event-Related Information: This may include dietary preferences or other information related for events you register for. * Professional Information: Information you may provide, such as your work history or education. **2.2. Information from Third-Party Sources** We may receive personal information about you from other sources, including: * Other Users: Another user (like your employer or spouse) may provide information about you, for example, when using our Services or in a referral program. * Linked Services: If you connect a third-party account (like a social media or bank account) to our Services, we will receive information from that service according to your settings. * Data and Verification Providers: We may use third parties to verify your identity, supplement your information (like your contact details), or provide us with business details. * Public and Private Sources: We may obtain information from publicly available records (e.g., government agencies, social media) or from private data providers. * Partners: We may receive information from joint marketing partners, event co-sponsors, or non-profit organizations we work with. **2.3. Information Collected Automatically** We and our partners may automatically log information about you, your device, and your interaction with our Services: * Device Data: Your IP address, device type, unique device identifiers, and log information (including error messages). * Internet Activity Data: Information about your interaction with our Services, such as pages viewed, links clicked, time spent on pages, and navigation paths. * Location Data: We may collect your precise location information if you grant us permission through your device settings. * Locally Stored Information: Some of our desktop services may sync with your computer and collect data like product usage or error reports. We may also store information locally on your device. * Communication Interaction Data: We may use technologies like pixel tags to collect data on how you interact with our email or text communications (e.g., whether you opened an email). * Online Behavioral Data: We may collect information about your use of our websites, social media, or marketing campaigns, including page views, links clicked, and campaign engagement. **2.4. Cookies and Similar Technologies** We use cookies and similar technologies for some of our automatic data collection. *** #### 3. How We Use Your Personal Information We use the personal information we collect for the following purposes: * To Provide and Manage the Services: This includes creating your account, operating our business, providing platform features (like personalized recommendations), processing payments, and managing our relationship with you. * For Research and Development: We use data to analyze and improve our Services, develop new products, create aggregated and anonymized statistics, and to train our artificial intelligence (AI) and machine learning (ML) models. * For Marketing and Advertising: We may use your information to market our products, personalize your experience, and display advertisements on our Services or on third-party platforms. * For Safety, Security, and Compliance: We use data to protect against misuse of our Services, enforce our Terms of Service, protect our rights and security, prevent fraud, and comply with legal and regulatory obligations. * Whistleblower Reporting: If you report concerns about unethical conduct, we will process your information as part of the investigation while maintaining confidentiality as appropriate. * With Your Consent: For any other purpose for which we ask for your explicit consent. *** #### 4. How We Share Your Personal Information We may disclose your personal information to the following categories of third parties: * Affiliates: We may share information with other companies within our corporate group, who will use it consistent with this Privacy Policy. * Service Providers: We share information with third-party vendors and partners who perform services on our behalf, such as IT, marketing, payment processing, event management, and security. * Third Parties You Designate: We will share your data with third parties when you instruct us or consent to do so. This includes: * Platform Partners: If you choose to use a third-party integration or service. * Social Media: If you connect your social media account or share content. * Wireless Carriers: To verify your identity and prevent fraud. * Joint Marketing and Event Co-Sponsors: With your consent, we may share information with third parties who are jointly offering a promotion, feature, or event with us. * Professional Advisors: We may share information with our lawyers, auditors, bankers, and insurers as necessary in the course of their professional services. * Authorities and Others for Legal Reasons: We may disclose information to law enforcement, government authorities, or other private parties as we believe necessary for the compliance and protection purposes described above. * Business Transferees: Your information may be shared in connection with a merger, asset sale, financing, bankruptcy, or acquisition of all or part of our business. * Public Postings: If you post a review, comment, or other content in a public forum on our Services, that information will be public. * Research: We may share aggregated, de-identified, or anonymized information with third parties for research purposes, with appropriate controls. *** #### 5. Our Legal Grounds for Using Information If you are in a region that requires it (like the EEA or UK), we rely on the following legal bases to process your personal information: * Performance of a Contract: To provide the Services you requested and fulfill our contractual obligations to you. * Legitimate Interests: For our legitimate business interests (like improving our Services, marketing, and ensuring security) where these interests are not overridden by your rights. * Legal Obligations: To comply with our legal and regulatory requirements. * Consent: Where required by law, we will process your information based on your explicit consent, which you may withdraw at any time. *** #### 6. Data Storage and Security We retain personal information for as long as necessary to fulfill the purposes for which we collected it, or as required for legal, accounting, or reporting purposes. When data is no longer needed, we will delete, anonymize, or aggregate it. We implement security measures to protect your data, but no internet or email transmission is ever 100% secure or error-free. We cannot guarantee the absolute security of your data, and you assume this risk when using the Services. *** #### 7. Your Rights and Choices You have choices regarding the personal information we collect: * Opt-Out of Marketing: You can opt-out of marketing-related emails by following the instructions in the email or by contacting us at . You will still receive non-marketing (service-related) emails. * Cookies: You can manage your cookie preferences as described in our Cookie Policy. * Do Not Track: We do not currently respond to "Do Not Track" signals from browsers. * Declining Information: If you choose not to provide required information, you may not be able to use certain features of the Services. * Regional Rights: You may have additional rights depending on where you live. Please see Section 11 (Region and State-Specific Terms) below. *** #### 8. Third-Party Links and Services The Services may link to third-party websites or services that we do not control. We are not responsible for their content or privacy practices. We encourage you to review their policies. *** #### 9. Children's Privacy The Services are not directed to children under 13 (or 16 for EU/UK residents, or 14 for residents of South Korea), and we do not knowingly collect personal information from them. If you believe we have inadvertently collected such information, please contact us at so we can delete it. *** #### 10. International Data Transfer We are headquartered in the United States and use service providers globally. Your personal information will be transferred to and processed in the United States and other locations, where privacy laws may differ from and be less protective than those in your home country. *** #### 11. Changes to This Privacy Policy We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by posting the new policy, by email, or through a notice on our Service. Your continued use of the Services after a change indicates your acceptance. *** #### 12. Contact Information If you have questions, complaints, or requests regarding your personal information or this policy, please contact us at: . *** #### 13. Region and State-Specific Terms **A. Notice to Residents of US States with Privacy Laws** Scope and Rights If you are a resident of a US state with applicable privacy laws (such as the California Consumer Privacy Act (CCPA), Virginia VCDPA, etc.), this section applies to you. You may have some or all of the following rights, subject to legal limitations: * Right to Know/Information: To confirm if we are processing your personal information and to request details about the data we have collected, used, and disclosed. * Right to Access: To request a copy of the personal information we have collected about you. * Right to Correction: To ask us to correct inaccurate personal information. * Right to Deletion: To ask us to delete personal information we have collected from you. * Right to Appeal: To appeal our denial of a request. * Nondiscrimination: We will not discriminate against you for exercising these rights. We do not "sell" personal information as that term is traditionally defined. However, some laws define "sharing" broadly to include the use of tracking technologies for targeted advertising. You may have the right to opt-out of this "sharing." We do not use sensitive personal information for purposes that require a "right to limit" under the CCPA. How to Exercise Your Rights To exercise your rights, please contact us at . We will need to verify your identity and residency before processing your request. You may be able to use an authorized agent, but we will need to verify the agent's authority. Categories of Personal Information Processed Below is a summary of the personal information we collect, as defined by the CCPA. We use all categories for the purposes described in Section 3 of this policy. * Identifiers * Examples: Name, email, phone number, username, IP address. * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: We "share" this data (e.g., IP address, online identifiers) for targeted advertising. * California Customer Records (Cal. Civ. Code ยง 1798.80(e)) * Examples: Name, address, phone number, payment information, professional information. * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: Not "shared" for advertising. * Commercial Information * Examples: Transaction history, services considered, payment records. * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: We "share" this data (e.g., services considered) for targeted advertising. * Internet or Other Electronic Network Activity Information * Examples: Browsing history, page views, links clicked, interaction with our Services. * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: We "share" this data for targeted advertising. * Geolocation Data * Examples: Precise location (if permission is granted) or general location (from IP address). * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: Not "shared" for advertising. * Audio, Electronic, Visual, or Similar Information * Examples: Voice recordings (if you call support), photos or videos (if you upload them). * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: Not "shared" for advertising. * Professional or Employment-Related Information * Examples: Your job title, employer, or work history (if you provide it). * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: Not "shared" for advertising. * Inferences * Examples: Inferences drawn from your data to create a profile about your preferences or interests. * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: We "share" this data for targeted advertising. * Sensitive Personal Information * Examples: Account login/password, precise geolocation, dietary information. (Note: We only use this for permitted purposes, not for which you have a right to limit). * Shared with: Affiliates, Service Providers, Partners, Advisors, Authorities, Business Transferees. * "Share" Status: Not "shared" for advertising. **B. Notice to European Users (EEA & UK)** Controller and Data Protection Officer The "Company" (the Delaware corporation) is the data controller for your personal information. You can contact our data protection officer at . Your Rights If you are in the EEA or UK, you have the following rights, subject to legal exemptions: * Right of Access: To request access to your personal information. * Right to Rectification: To ask us to correct inaccurate or incomplete data. * Right to Erasure (Right to be Forgotten): To ask us to delete your personal information. * Right to Restrict Processing: To request that we limit our use of your data. * Right to Data Portability: To request a machine-readable copy of your data. * Right to Object: To object to our processing of your data, especially for marketing. * Right to Withdraw Consent: To withdraw your consent at any time. To exercise these rights, please contact us at . We may need to verify your identity. Right to Lodge a Complaint You have the right to lodge a complaint with your local data protection supervisory authority if you are unsatisfied with our response. Cross-Border Data Transfer As noted in Section 10, your personal information will be transferred to and processed in the United States, which may not offer the same level of data protection as your home country. We rely on appropriate safeguards, as required by law, for these transfers.
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