Privacy Policy

1 Definitions

2 Information We Collect, Categories of Sources, and Purposes

Set forth below are the categories of Personal Information we collect and that have been collected in the preceding 12 months, the categories of sources from which the Personal Information was collected, and the business or commercial purpose for such collection. We may not collect all information referenced below, nor use your Personal Information for all purposes listed.

3 Cookies & Tracking Technologies

A cookie is a small file of letters and numbers stored on your browser or computer hard drive. Cookies contain information transferred to your computer. We use cookies and similar technologies — such as web beacons and tracking pixels — to analyze trends, administer our website, personalize content and ads, track user movements, provide relevant browsing experiences, and gather demographic information about our user base.

You can control cookies at the individual browser level, but disabling cookies may limit certain features or functions of our website.

Types of Cookies We Use

If you want to remove existing cookies, use your browser options. To block future cookies, change your browser settings accordingly. Please note that deleting and blocking cookies may impact your user experience, as some site features may not function properly.

We also use web beacons, pixels, and tracking pixels (transparent 1×1 graphic images or JavaScript tags) placed on web pages and some forms of email to collect information about your use of the site and to trigger ads on participating websites.

By using our website and services you affirmatively agree to the use of cookies disclosed in this Privacy Policy.

4 Third-Party Advertising & Analytics Platforms

We work with a number of third-party advertising, analytics, and social media platforms that may collect or receive information about your interactions with our website and ads. These platforms place their own cookies or pixels on your browser and use that data to serve you relevant advertising on our website and across the internet.

5 Personal Information We Disclose, Share for Targeted Advertising, or Sell

Disclosure to Service Providers

We disclose and have disclosed in the preceding 12 months Personal Information to our service providers and contractors for the following business purposes:

• Auditing of Ad Impressions: For counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• Short-Term / Transient Use: Including non-personalized advertising shown as part of a consumer's current interaction, where data is not used to build a profile beyond the current interaction.
• Services on Our Behalf: Maintaining or servicing accounts, customer service, processing orders/transactions, verifying customer information, processing payments, providing financing, analytic services, storage, and similar services.
• Advertising and Marketing Services: To provide advertising or marketing services on our behalf.

As Necessary: We may also disclose Personal Information as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations, rights, privacy, safety or property; and (e) to allow us to pursue available remedies or limit damages. We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of our business, assets, or stock.

Selling and Sharing for Targeted Advertising

We may sell for monetary or other consideration certain Personal Information we have collected from you. "Sale" includes situations where another company can use your Personal Information for its own purposes. We may also share with others certain Personal Information for cross-context behavioral advertising (targeted advertising).

6 Our Retention Policy

We will retain each category of your Personal Information for an amount of time reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention pursuant to any applicable contract, law, or regulation. To determine the appropriate retention period, we consider: the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the information; whether we can achieve those purposes through other means; and applicable legal requirements.

7 Data Security & Information Security

We implement technical, organizational, administrative, and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process, and disclose. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to help ensure the security of processing.

Information Security Management System

Michelli maintains an Information Security Management System (ISMS) to help manage safeguards designed to protect the confidentiality, integrity, and availability of company, customer, and business information. The ISMS provides a framework for identifying and addressing information security risks across Michelli's operations on an ongoing basis.

Cybersecurity Standards

Michelli has implemented cybersecurity practices aligned with recognized federal frameworks to support the protection of sensitive information in applicable business contexts.

• CMMC Level 1 v2.0: Michelli's cybersecurity program includes practices consistent with Cybersecurity Maturity Model Certification (CMMC) Level 1, Version 2.0, which addresses basic safeguarding requirements for Federal Contract Information (FCI) as defined in Federal Acquisition Regulation (FAR) 52.204-21.
• NIST SP 800-171 Rev. 2: Michelli's information security practices are informed by the National Institute of Standards and Technology Special Publication 800-171, Revision 2, which provides recommended requirements for protecting the confidentiality of Controlled Unclassified Information (CUI) in nonfederal systems and organizations.

8 Children

We do not direct our websites or applications to children under thirteen (13) years of age. We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever. We do not knowingly allow persons known to be under 13 years of age to receive direct marketing communications from us. No information should be submitted to our websites or applications by persons under 13 years of age. When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein.

9 Video Content

Our website may include content governed by the Video Privacy Protection Act ("VPPA"). Some of the cookies and other tracking technologies disclosed above may provide others access to your personal information (or personally identifiable information as that term is used under the VPPA). To the extent that the VPPA applies to our website or any content on our website, by using our site you explicitly consent to our practices, including those relating to video content or otherwise governed by the VPPA.

10 Consumer Rights

Your Rights if You Are a Resident of California

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2023 (CPRA), and related regulations. These rights are subject to certain exceptions and verification mechanisms.

• Right to Know: You have the right to know the categories of Personal Information we have collected about you, categories of sources, business or commercial purposes for collection, categories of third parties to whom we disclose it, and specific pieces of Personal Information collected about you. You also have the right to know all third parties to whom we disclosed Personal Information for third-party direct marketing purposes under California Civil Code Section 1798.83 (the "Shine the Light Law").
• Right to Know What Was Disclosed or Sold: You have the right to request categories of Personal Information sold or shared and the categories of third parties involved, by category of Personal Information.
• Right to Deletion: You have the right to request deletion of your Personal Information, subject to exceptions. We will inform you of any Personal Information we cannot delete and the reason.
• Right to Correct Inaccurate Information: If you believe Personal Information we maintain about you is inaccurate, you have the right to request correction. We will use commercially reasonable efforts to correct the information as directed.
• Right to Opt-Out of Sale and Sharing: You may opt-out of the sale or sharing of your Personal Information for cross-context behavioral advertising. You can also exercise this right using a browser that supports an opt-out preference signal (Global Privacy Control / GPC). You will need to enable it for each browser you use.
• Right to Limit Use of Sensitive Personal Information: Given our data governance practices, this right does not currently apply to you.
• Right to Non-Discrimination: If you choose to exercise any of your rights, you have the right not to receive discriminatory treatment by us.

Your Rights if You Are a Resident of Another State

Depending on your state of residency, you may have certain rights related to your Personal Information. Nevada residents should refer to the "Nevada Privacy Notice" section below. You may submit a request by calling us at (800) 903-8823 or emailing us at privacy@michelli.com. Please note that not all of these rights may be applicable to you, they are subject to certain exceptions, and certain rights are subject to verification mechanisms.

• Right to Know: Whether we are processing your Personal Information. Oregon residents also have the right to know categories processed and specific third parties to which we have disclosed it.
• Right of Access: Access to your Personal Information and a copy in a readily usable format, if feasible.
• Right to Correct Inaccuracies: Request correction of inaccuracies in your Personal Information.
• Right to Delete: Request deletion of your Personal Information, except where retention is required by law or contractual obligation.
• Right to Data Portability: Obtain a copy of your Personal Information in a portable and, if feasible, readily usable format.
• Right to Opt-Out: Prevent your Personal Information from being used in targeted advertising, sold, or used for automated decision-making or profiling that may produce legal or similarly significant effects.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your rights.

Furthermore, if we have actual knowledge or willfully disregard that you are 13 years of age and not older than 18, we will not without your consent process your Personal Information for targeted advertising, profile you for decisions with legal or significant effects, or sell your Personal Information.

Verification of Consumer Requests

For California residents seeking to opt-out of the sale or sharing of Personal Information, please use the opt-out link in the Consumer Rights section above or a Global Privacy Control (GPC) browser signal.

For all other requests, you may submit a request via phone at (800) 903-8823 or email at privacy@michelli.com. To help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us and the type of request.

• Password-Protected Accounts: We may use existing authentication practices but will require re-authentication before disclosing, correcting, or deleting data. If we suspect fraudulent or malicious activity, we will require further verification.
• Non-Accountholders:
  • For requests to know categories of Personal Information: we will verify your identity by matching at least two data points.
  • For requests to know specific pieces of Personal Information, right of access, and right to data portability: we will verify by matching at least three data points.
  • For requests to correct or delete: we will verify to a reasonable or reasonably high degree of certainty depending on sensitivity and risk of harm.

We may also require a declaration, signed under penalty of perjury, that the person requesting information is the person whose information is the subject of the request or that person's authorized representative. If you use an authorized agent, we may require proof of signed permission and direct verification with you.

There may be situations where we cannot grant your request — for example, if you ask us to delete Personal Information we are obligated to keep under applicable law, if our use serves a legitimate purpose such as security, or if the request compromises the privacy of others, is overly repetitive, or extremely burdensome.

We will respond to valid requests no later than 45 calendar days. If necessary, we may take up to an additional 45 days but will provide notice and an explanation. Valid requests under "Right of Access" and "Right to Data Portability" will be transmitted securely. If we cannot fulfill your request, we will notify you of the decision and reasons within 45 days, at which point you may have the right to submit an appeal or seek assistance from your state attorney general.

11 Nevada Privacy Notice

Nevada law provides that Nevada residents may opt-out of the "sale" of "covered information" to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your Personal Information include sales under Nevada law where the opt-out right applies. You may submit a request by calling us at (800) 903-8823 or emailing us at privacy@michelli.com.

12 How to Contact Us

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us: