MINI CITY INC.
PRIVACY POLICY
Effective Date: 2022
Mini City Inc. (“Mini City”, “we”, “us” or “our”) is committed to protecting your (“you” or “your”) privacy and empowering you with this privacy policy (this “Privacy Policy”). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use or access our online website (https://www.minicityatl.com/), products, services, or applications that link to this Privacy Policy (collectively, the “Services”).
By using the Services or interacting with us, you are agreeing to this Privacy Policy. Please read the following carefully to understand how we collect, use, disclose, and maintain information that can be used to identify you. In addition, this Privacy Policy describes your choices for use, access, and correction of your personal data. If you do not agree to be bound by this Privacy Policy, please stop using the Services.
1. Changes to this Privacy Policy. We may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our Services. We will post the changes to this page and encourage you to review this Privacy Policy to stay informed of ways you can protect your privacy. If we make changes that materially alter your privacy rights, we may provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your profile and stop using the Services.
2. Information We Collect and Receive. We collect your information in a variety of ways and from a variety of sources when you interact with the Services. More information about the categories and sources of information is provided below.
2.1 Information You Provided to Us. We collect information that you decide to share with us. At times, we may require you to provide certain information in order to use certain parts of our Services, fulfill your requests, or provide you with certain Services.
2.1.1 User Information. If you establish a profile with us, we may require you to provide your name, email address, phone number, physical address, age, gender, profile picture, demographic information (such as race and ethnicity), information about your parents, siblings, and birth/adoption status, and information about your employment, education, and related qualifications, and any other information you disclose in your profile. As needed and when necessary to perform the Services, we may require support identification such as state identification, school identification, licenses for homeless citizens, and/or work badges.
2.1.2 Content Information. We may collect the content that you submit to the Services, including comments, messages, supporting identification documents, and other information or materials that you choose to provide or upload to the Services. We may collect additional information that you provide to facilitate communications between you and other users through the Services. These communications may allow, for example, a homeless citizen to communicate with their case worker, or allow case workers to communicate and collaborate with one another and attach comments to case files.
2.1.3 Contacting Us. You also may choose to send us information about yourself in an email containing inquiries about the Services and we use this information in order to help us respond to your inquiry. You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, or (iii) in connection with an actual or potential business relationship with us.
2.1.4 Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal data.
2.2 Information We Obtain from Others. Sometimes other users of the Services may provide us with information about you. We may also collect information about you from publicly available information systems and government sources.
2.3 Information We Automatically Collect. We automatically collect certain information from you when you use the Services, including internet or other network activity information such as your IP address, geolocation-related data, unique device identifiers, browsing and search history (including content you have viewed in the Services), and cookies and other technologies.
2.3.1 Log and Usage information. We retain information about you when you access and use the Services. This information can include the following: Internet Protocol (“IP”) address, timestamps, browser information, Internet Service Provider “ISP”, webpages visited, and the URL of the webpage you visited before navigating to our Services. We monitor user activity in connection with the Services and may collect information about the applications and features you use, websites you visit, as well as types and amount of the Services you use. We may also collect location information from devices in accordance with the consent process provided by your device.
2.3.2 Crash and Error Information. If the Services crash or return an error, we may collect data to determine the cause of the error using first or third party services. The crash or error information collected may include the following: Device IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.
2.3.3 Cookies. Like many online services, we use “cookies” to collect technical information. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. We may use cookies to collect information about your IP address, browser type, operating system, device type and identifiers, platform type, as well as your usage of and activity on and the performance of our Services. These types of information are collected to make the Services more useful to you and to tailor your online experience to meet your interests and expectations.
2.3.4 Pixel Tags. In addition, we use “pixel tags” (also referred to as clear gifs, web beacons, or web bugs). Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of web users. In contrast to cookies, which are stored on a computer’s hard drive or web browser, pixel tags are embedded invisibly in web pages. Pixel tags are often used in combination with cookies, trigger the placing of cookies, and transmit information to us or our service providers. This enables two websites to share information. The resulting connection can include information such as a device’s IP address, the time a person viewed the pixel, an identifier associated with the browser or device, the type of browser being used and the URL of the web page from which the pixel was viewed. Pixel tags also allow us to send email messages in a format that users can read, tell us whether emails have been opened, and help to ensure we are sending only messages that may be of interest to our users.
2.3.5 Third Party Analytics. We use a number of service providers, such as Google Analytics, to help analyze how people use our Services (“Analytics Companies”). Analytics Companies use cookies and similar technologies to collect information pertaining to how people use our Services, visitor behavior on our Services, and visitor demographics on our Services. We use the information we get from Analytics Companies to improve and optimize our Services.
3. How We Use Your Information.
(a) We may use the personal data that we collect for our legitimate interests and the limited purpose of providing the Services and related functionality and services, as described in this Privacy Policy and as permitted by applicable laws. These purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent including but not limited to pre-filling government forms, obtaining birth certificates, signing waivers and liability statements, storing job history and narrative yearly goals across multiple devices. We may use your personal data to:
(i) provide the information, products and services you request;
(ii) assist you with obtaining your birth records and identification from the government;
(iii) provide you with a personalized experience when you use our Services;
(iv) contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
(v) contact you with information and notices related to your use of our products and services, including our Services;
(vi) invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
(vii) better understand your needs and interests;
(viii) improve our products and services and develop new products and services;
(ix) improve our marketing and promotional efforts;
(x) improve the content, functionality, and usability of the Services;
(xi) evaluate your interest in employment and contact you regarding possible employment with Mini City;
(xii) help you, if you are a Mini City employee, perform your job functions and to manage our workforce;
(xiii) enforce our websites’ terms of use;
(xiv) promote security; to protect against and prevent fraud, claims and other liabilities; and to manage corporate risk exposure;
(xv) meet our internal and external audit obligations; and
(xvi) use for any other purpose for which we provide notice at the time of collection.
(b) We may aggregate and/or de-identify information collected through the Services and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including, without limitation, supporting research and other initiatives for social good relating to homelessness. We may also use this information to help us, and our partners, understand and track their social impact, and as supporting evidence when looking to form new partnerships, access grant funding, and other marketing initiatives.
4. How We Share and Disclose Information. Information shared with third parties in accordance with this Privacy Policy includes some or all of the personal data we collect (as described and listed in this Privacy Policy). We do not sell or otherwise disclose personal data we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected. More information about how we share and disclose your personal data is provided below.
4.1 Service Providers. If you are performing services directly or indirectly for us and using an application provided by us, then we may collect information for the purpose of providing information to our carriers and customers. We may also share your personal data with third-party vendors that perform tasks on our behalf and under our instruction. These third-party vendors may use your personal data only in connection with the services they perform on our behalf and they are bound to protect your personal data in a manner consistent with our own policies and practices. On our Services, you may have an opportunity to post user-generated content. If you take advantage of this opportunity, remember that the user-generated content you post is available to others who you share it with on the Services and therefore you should have no expectation of privacy with respect to such content. In addition, you may choose to use certain features on our Services for which we partner with other entities. These features, which may include geographic location tools, are operated by third parties that are not affiliated with Mini City. These third parties may use personal data in accordance with their own privacy policies. On sites on which these features are offered, the relevant third parties are identified. We strongly suggest you review the third parties' privacy policies if you use the relevant features.
4.2 Your Consent. We may share your personal data for other purposes pursuant to your consent or with your further direction.
4.3 Aggregate/De-Identified Data. From time to time, we may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
4.4 Legal Reasons. We may also disclose information about you when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose information about you to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our website; to enforce or apply our websites' terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority.
4.5 Sale, Merger, or Other Business Transfer. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), personal data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, your personal data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
5. Your Choices.
(a) If you have registered for a profile, you may access, review, and update certain personal data that you have provided to us by logging into your account and using available features and functionalities or by contacting us in accordance with the “Contact Us” section below.
(b) You have a choice about the placement of cookies on our website. You can use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation. Guidance on how to control cookies in popular browsers is contained here: Microsoft Internet Explorer, MacOS Safari, Mozilla Firefox, and Google Chrome. You can also find additional information on cookie controls and advertisement here: Network Advertising Initiative and Digital Advertising Alliance.
(c) You have a choice at any time to stop us from sending you emails for marketing purposes by following the “unsubscribe” link included in these messages. Please note that despite any indicated email marketing preferences, we may continue to send you administrative emails regarding Mini City, including, for example, notices of updates to our Terms or this Privacy Policy, if we choose to provide such notices to you in this manner.
(d) If you do not provide the personal data that we need to provide the Services, we may not be able to provide with the Services or certain functionalities. We will tell you what personal data that you must provide in order to receive the Services.
(e) Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
6. Security. We take reasonable precautions intended to help protect your personal data that we collect. Unfortunately, no system or online transmission of data is completely secure, and we cannot guarantee the security of data transmitted across the Internet. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
7. Information Retention. We will retain information required to comply with privacy requests, manage active accounts, as required by law, in order to resolve disputes or enforce our agreements. We will retain personal data we process on behalf of our clients as directed by them. We may also retain copies of your information for disaster recovery purposes.
8. Data Processing and Data Transfers. The Services are hosted in the United States and are intended for and directed to users in the United States. If you are a user accessing the Services from the European Union or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Services, which are governed by U.S. law, this Privacy Policy, and our terms of use, you are transferring your personal data to the United States and you consent to that transfer. The Services are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
9. Links to Third-Party Websites. The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.
10. Children’s Privacy. The Services are directed to individuals at the age of 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we become aware of individuals who have provided us with personal data and are under the age of 18, we will take steps to deactivate the account and delete the personal data. If you become aware of information from individuals under the age of 18 which has been provided to us, please contact us in accordance with the “Contact Us” section below.
11. Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via email at hello@minicityatl.com.