Privacy Policy
Welcome to Milan Cleaning Company and our website at www.milan-cleaning.com. This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Information we collect from you when you visit our website, or use our social media profiles and services.
General Information
What law applies?
In principle, we will only use your Personal Information in accordance with the applicable data protection laws, in particular California`s California Consumer Privacy Act (“CCPA”) and the subsequent amendments from the California Privacy Rights and Enforcement Act (“CPRA”).
What is Personal Information?
Personal Information is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party within the meaning of the CCPA/CPRA is Milan Cleaning Company of Oakland, CA, United States, California (“Milan Cleaning Company”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, please email milancleaningco@gmail.com, or call +1 510-759-6310.
What are the legal bases of processing?
In accordance with the above laws, we have to have at least one of the following legal bases to process your Personal Information:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Contract – This is where we process your information to fulfill a contractual arrangement we have made with you or reply to your messages, e-mails, posts, calls, etc.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for archiving or the investigation of crime.
Data we collect automatically
Our website collects a series of general data and information every time you visit. This general data and information is stored in the log files of the server. The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which you accesses our website (so-called referrer), (4) the sub-pages you visit, (5) the date and time you access to our website, (6) your Internet protocol address (IP address), (7) your Internet service provider and (8) other similar data and information that serve to avert danger in the event of attacks on our website and systems.
When using this general data and information, we do not draw any conclusions about you. Rather, this information is needed (1) to deliver the contents of our website, (2) to optimize the contents of our website, (3) to ensure the long-term operability of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
Thus we analyze anonymously collected data and information on one hand for statistical purposes, and on the other hand for the purpose of increasing the data protection and data security and ultimately ensuring an optimal level of protection for the Personal Information we process.
Pixel Cookies and Tags
We use so-called Pixel Cookies and Tags (“Pixel Cookies”) on our website. A Pixel Cookie is an advertising tool and typically consists of a JavaScript code snippet that allows us to understand and track visitors’ activity on our website. For this purpose, Pixel Cookies collect and process information about visitors of our website and the device used (so-called event data).
Event data collected through Pixel Cookies is used for targeting our advertisements and improving ad delivery and personalized advertising. For this purpose, the event data collected on our website by means of Pixel Cookies is transmitted to the relevant operator of the Pixel Cookie and in part, also stored on your device. However, this only happens with your consent, and we and the relevant operator of the Pixel Cookie are considered joint controllers. Nonetheless, for the subsequent processing of the transmitted Event Data, the relevant operator of the Pixel Cookie is the sole controller.
For more information about how the relevant operator of the Pixel Cookie processes Personal Information, including the legal basis on which they rely on and how you can exercise your rights against, please refer to the following Privacy Policies: Instagram, Facebook, Twitter, TikTok, YouTube.
If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, and AdChoices.
Google Analytics
We use Google Analytics provided by Google LLC, on our website. Google Analytics uses cookies to enable our website to analyze how users use our website across multiple devices. The information generated by the cookies about your use of our website is transmitted to and stored by Google, including transmission to the United States. The following data is processed through the use of Google Analytics: (1) 3 bytes of the IP address of the called system of the website visitor (anonymized IP address), (2) the website called up, (3) the website from which the user reached the accessed page of my website (referrer), (4) the subpages accessed from the website, e) the time spent on the website, and iv) the frequency with which the website is accessed. Google states that it will not associate your IP address with any other data held by Google. You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link http://tools.google.com/dlpage/gaoptout?hl=en. The legal basis for processing is our legitimate interest and your consent.
When you watch our videos
On our website, we implement videos of the video portal “YouTube” of the company Google LLC.
When you call up a page that has an embedded video, a connection is established to Google’s servers and in the process the content is displayed on the website by notifying your browser. According to Google’s information, in “extended data protection mode” your data – in particular which of our Internet pages you have visited as well as device-specific information including the IP address – is only transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission.
Data we collect directly
Contacting us
If you contact us, the data you provide will be stored so that your message can be forwarded to the correct contact person. This is done to process your request and your data will not be used for any other purposes, in particular not for advertising. The legal basis for the data processing is contract.
We are present on social media. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
Bookings
We process your first name, last name, e-mail address, and phone number and the data related to your contract and booking with us data to handle the contractual relationship between you and us. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as consent.
When you use our services
The protection of your Personal Information is particularly important to us in the performance of our services. We therefore only want to process as much Personal Information (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Information, to fulfill our contractual obligations to you or to carry out pre-contractual measures and in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving.
Marketing
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
We may also use remarketing and retargeting services to advertise. If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, and AdChoices.
Social Media
When you visit our Social Profiles (currently, Instagram, Facebook, Twitter, TikTok, YouTube) we, as the operator of the relevant Social Profile, process your actions and interactions with our Social Profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our Social Profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture).
Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your account.
Please generally take care not to transmit or share sensitive data or confidential information (e.g., application documents, bank or payment data) via social media platforms; we recommend that you use a more secure means of transmission (e.g., letter post, e-mail).
We operate our Social Profiles and process the aforementioned data for the purpose of providing information about us and our products and communicating with our followers and interested parties. This data processing is carried out on the basis of our legitimate interests and, where applicable, in order to respond to your messages, enquiries, contributions or comments that you send to us.
We also check whether comments or other interactions on our Social Profiles violate applicable law or the respective community guidelines and delete such comments if necessary. In the event that such comments occur frequently, we may process the user names involved for internal coordination and marketing and lead generation purposes. We base this processing on our legitimate interest in providing a reputable online presence and meeting legal requirements.
The relevant Social Media Platform also provides us with anonymous usage statistics (so-called analytics services or page insights data) based on the actions and interactions of our followers (e.g. likes, shares, comments, etc.), number of followers, views of individual page areas, reach of a post as well as statistics on followers according to age, language, origin or interests), which help us to get in touch with our followers and interested parties, to understand the use and reach of our posts, to evaluate content and to recognise usage preferences as well as to be able to design our Social Profiles to be as target group-oriented as possible.
We have no influence or access to the compilation and processing of these usage statistics and the underlying data; it is carried out under the sole responsibility of the relevant Social Media Platform and without us being able to view Personal Information of individual followers or users. This data processing is based on our legitimate interests.
We also use these anonymous usage statistics to display targeted interest-based advertisements. The display of interest-based advertisements or the highlighting of posts on the relevant Social Media Platform is carried out on the basis of an analysis of the user’s prior usage behavior by the relevant Social Media Platform without us being able to view Personal Information of individual users or merge it with any Personal Information we may process or obtain knowledge of the identity of the users to whom interest-based advertisements are displayed. This data processing is based on our legitimate interests. Insofar as, in the context of interest-based advertising, we would exceptionally carry out a so-called extended comparison with customer lists to be uploaded by us to the relevant Social Media Platform, and this would only be done on the basis of consent granted by you for this purpose.
We will process your Personal Information for as long as is necessary for the aforementioned purposes. In the event of an objection to processing based on our legitimate interests, we will delete Personal Information unless its further processing is permitted under the relevant legal provisions. We also delete Personal Information if we are obliged to do so for other legal reasons. Applying these general principles, we generally delete Personal Information immediately after the legal basis ceases to exist, if it is no longer required for the stated purposes or if the stated purposes cease to exist and if there is no other legal basis (e.g., retention periods under commercial and tax law), otherwise after the other legal basis ceases to exist.
As part of the provision of our Social Profiles, we also work with service providers (e.g., IT service providers or advertising and content agencies that support us in the creation of our posts and the provision and optimisation of our Social Profile). To the extent that these service providers process Personal Information on our behalf, we have concluded a processing agreement with these service providers and have agreed on appropriate guarantees to ensure the protection of Personal Information. We also carefully select our service providers, they process Personal Information exclusively for the performance of their tasks and are contractually bound to our instructions, have appropriate technical and organizational measures in place to protect Personal Information and are regularly monitored by us. We transmit your Personal Information to third parties only if you have given us your consent to do so or if this is absolutely necessary to fulfill a contract with you or to protect our legitimate interests..
Processing of your Personal Information by the relevant Social Media Platform
The relevant Social Media Platform is solely responsible for the processing of Personal Information on their respective platform itself. As a rule, the relevant Social Media Platform processes your Personal Information when you visit our Social Profile, irrespective of whether you have a user account or are logged in, and generally also uses cookies and other storage and (in some cases cross-device) tracking technologies. Further information on the processing of your Personal Information by the relevant Social Media Platforms can be found in their respective Privacy Policies (Instagram, Facebook, Twitter, TikTok, YouTube).
Principles of processing Personal Information
Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Information from you. We process and store your Personal Information only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures for example encryption or need to know access, to ensure the most complete protection of Personal Information processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Information may have been compromised as expeditiously as possible after which the breach was discovered.
Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
Do Not Sell
We do not sell your Personal Information.
Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Information to third parties unless this is i) necessary for the performance of our services including our shipping forwarders and order fulfillment service providers and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
International Transfer
We may transfer your Personal Information to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Information when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Information we transfer.
Your Rights and Privileges
Privacy rights
Under the CCPA and the CPRA amendment, you can exercise the following rights:
- Right to Know/Access
- Right to Delete
- Right to Opt-out of Sale
- Right to Non-Discrimination
- Right to Rectification
- Right to Limit Use and Disclosure of Sensitive Personal Information
Further, California’s “Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Information using the contact details provided.
If you have any questions about the nature of the Personal Information we hold about you, or if you wish to exercise any of your rights, please contact us.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.
Telephone Consumer Protection Act (TCPA)
If we process your Personal Information for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.
Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.
DO NOT SELL
We do not sell your Personal Information.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we will tell you why.
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Information to a supervisory authority responsible for data protection. The competent data protection authority in California is: The California Privacy Protection Agency (CCPA), 2101 Arena Blvd, Sacramento, CA 95834, www.cppa.ca.gov We would, however, appreciate the chance to deal with your concerns before you approach the CCPA.
Changes and Questions
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above. The Effective Date of this policy is Monday, July 17, 2023.