Privacy Policy

Where This Privacy Policy Applies

This Privacy Policy applies to websites, apps, events and other services we operate under the MyNIL corporation. MyNIL universe of services includes but is not limited to NIL brand building resources to position for beneficial marketing opportunities for businesses. For simplicity, we just refer to all of these as our “service” in this Privacy Policy. If for some reason, one of our services requires its own separate privacy policy, then that policy will be made available to you and that policy will apply.

Data We Collect

Categories of Data
The categories of data shared will vary based on the specific circumstances surrounding each obligation, compelling interest or dispute. The data we collect and use fall within the following categories, including but not limited to:
· Account Data
· Profile Data
· Content
· Purchase Data
· Marketing, Survey and Research Data
· Third Party Data
· Customer Support Data
· Social Media Data
· Usage Data
· Technical Data
· Geolocation Data
· Face Geometry Data
· ID Data
· Academic Transcript
Data You Give Us
Categories
Description
Account Data
When you create an account, you give us basic information for your account to be set up such as your email address, date of birth, password.
Profile Data
When you complete your profile, you share additional details about you, such as your gender, interests, preferences, approximate location, etc. Some of this data may be considered sensitive or special in certain countries, such as details about sexual orientation, racial or ethnic origins, or political affiliations. If you choose to provide this data, you consent to us using it as laid out in this Privacy Policy.
Content
When you use our service, you may post photos, videos, audio, text and other types of content, such as your chats with other users.
Purchase Data
When you make a purchase, we keep the details of the transaction (e.g., what you purchased, the date of the transaction, and the price). The exact data depends on the payment method you choose. When you pay directly with us (rather than through a platform such as iOS or Android), you provide your debit or credit card number or other financial info.
Marketing, Survey and Research Data
We sometimes run (i) surveys, focus groups, or market studies for research purposes and (ii) promotions, events or contests for marketing purposes. When you choose to participate, you give us information to process your entry and participation, as well as your responses to our questions and your feedback.
Third-Party Data
When you choose to share with us information about other people (for example, if you use the contact details of someone you know for a given feature or if you submit a query or report involving a user), we process this data on your behalf to complete your request.
Customer Support Data
When you contact us, you provide us with information that may be necessary to help address your inquiry. Other people may also submit queries or reports involving you. Finally, our moderation tools and teams can collect additional data as part of their investigations.Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.
Social Media Data
When you choose to share with us information about other people (for example, if you use the contact details of someone you know for a given feature or if you submit a query or report involving a user), we process this data on your behalf to complete your request.
Academic Transcript
When you provide your academic transcript, you share details about your educational background, such as courses taken, grades received, and degree progress. This data helps us personalize your experience and offer relevant opportunities. We handle this information with strict confidentiality and only use it as outlined in our Privacy Policy.
Data Generated or Automatically Collected
Categories
Description
Usage Data
Using the service generates data about your activity, including how you use it (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages, ads you interacted with) and how you interact with others (e.g., searching, matching, communicating). We may also receive data related to interactions you had with our ads on third party’s websites or apps.
Technical Data
Using the service involves the collection of data from and about the device(s) you use to access our service, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs and identifiers associated with cookies or other technologies that may uniquely identify a device or browser.
Geolocation Data
If you give us permission, we can collect your geolocation (latitude and longitude) from your device. If you decline permission, features that rely on precise geolocation may not be available to you.
Face Geometry Data
This service uses a set of measurements taken from a user’s facial features, such as the distance between the eyes, the length of the nose, and the shape of the jawline, capturing the geometric structure of a face for facial recognition.
ID Data
You may provide us with a copy of your government-issued ID to help us check that you’re who you say you are.
Data Insights
MyNIL will use data collected from the platform and its related sites to provide both AI insights to enhance the platform's operations overall as well as for user experience. MyNIL may also use data collected for third-party company use but only for those third-party companies that provide benefits to both the user and the platform as we hope to limit the data usage of student athletes' information.
Why and How We Use Your Data
The main reason we process your data is to provide our service to you and improve it over time. That includes personalizing your experience, and just helping you make the most of our service. We also process your data to keep you and all of our users safe and secure while using our service. We take this responsibility very seriously and we’re always working to improve our systems and processes to help protect you.
Purposes for Processing Your Data
Grounds for Processing Your Data
To enable you to use our service, including:
· Creating and maintaining your account and profile on our service
· Operating and maintaining the various features on our service
· Recommending other users to you and recommending you to them
· Recommending actions to improve user brand score
· Generating brand score
· Organizing sweepstakes and contests
· Responding to your requests and questions
· Monitoring the well functioning of our service and troubleshooting and fixing issues as needed
· Performance of our contract with you
· Your consent (where sensitive data or other type of data that requires consent is processed)
To enable your purchases on our service, including:
· Processing payments
· Offering discounts and promotions, customizing prices
· Performance of our contract with you
· Your consent (where sensitive data or other type of data that requires consent is processed)
To operate advertising and marketing campaigns, including:
· Performing and measuring the effectiveness of advertising campaigns run on our service
· Performing and measuring the effectiveness of marketing campaigns promoting our own service on third-party platforms
· Communicating with you about products and services we believe may interest you
· Consent (where required under applicable law) and otherwise our legitimate interest. It is in our legitimate interest to promote our service and to show ads to our users which are tailored to their interests, as a way to improve their experience and help fund the parts of our service which are free
To improve our service and create new features and services, including:
· Running focus groups, market studies and surveys
· Analyzing how our service is used
· Reviewing interactions with customer care teams to improve service quality
· Developing and improving new features and services, including through machine learning and other technologies, and testing them out
· Conducting research and publishing research papers
· Performance of our contract with you
· Our legitimate interest: It is in our legitimate interest and that of our users to keep them safe
· Protection of your vital interests and that of other users
· Compliance with legal obligations that apply to us such as taking down illicit content
· Your consent (where sensitive data or other type of data that requires consent is processed)
To comply with applicable law, establish, exercise and defend legal claims & rights, including:
· Preserving data to comply – and evidence compliance – with applicable law
· Supporting investigations and defending potential or ongoing litigation, regulatory action or dispute
· Responding to lawful requests from law enforcement, courts, regulators, and other third parties
· Reporting illegal or infringing content to law enforcement, government or other authorities
· Establishing, exercising, or defending ongoing or threatened claims
· Sharing data with law enforcement or partners to combat abusive or illegal behavior
· Our legitimate interest: It is in our legitimate interest to comply with applicable law and protect ourselves, our users and others, including as part of investigations, legal proceedings and other disputes
· Protection of your vital interests and that of other users
· Compliance with legal obligations applying to us such as responding to law enforcement requests for information
How We Share Data
Recipients
Reasons for Sharing
Other users
You share data with other users when you voluntarily disclose information on the service for others to see (e.g., your public profile).If someone submits a report involving you (such as a claim you violated our Terms of Use), we may let the reporter know what actions we took, if any, as a result of their report. The same applies if you submit a report involving another user.
Service Providers/Partners
We share data with vendors and partners who help us operate, promote and improve our service. They provide us services such as data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, legal support, and security operations.
Advertising Partners
We may publish ads about third-party advertisers’ products and services on our service, and publish ads promoting our own service on third-party sites and apps. To help improve the relevance of these ads, we provide certain info about you to third parties, including advertising partners, or allow them to collect such data from our services (such as via cookies, or similar technologies). Some of our advertising partners enable us to transform your email address, advertising identifiers or phone number into an identifier that can’t be used to identify you personally and then use that unique identifier to either exclude you from our marketing campaigns, or to target our ads at an audience that is similar to you in terms of background, interests or app usage.

If you live in the United States, some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under applicable laws. You have the right to opt-out.
Affiliates
We may share data with affiliates or receive data from them for the purposes laid out in Section 6 of this policy.
Law Enforcement Authorities
We may disclose your data to: (i) comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) assist in the prevention or detection of crime; (iii) protect the safety of any person; and (iv) establish, exercise or defend legal claims.
In the context of merger and acquisition, with our Affiliates or new owner(s)
We may transfer your data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

Your Rights

We want you to be in control of your data, so we want to remind you of the following rights, options and tools available to you. Depending on where you live, you may not have the same rights or they may be named differently. If you have any questions on your rights and how to exercise them, please contact us at legal@mynilbrand.com.
Your Rights
How to Exercise It
Access, Portability or To Know Right to be informed of the personal data we process about you and/or ask for a copy of it
You can access and review some data directly by logging into your account. You can also retrieve a copy of your data by contacting us here.
Rectification or CorrectionRight to amend or update your personal data where it’s inaccurate or incomplete
You can update your data directly within the service by simply updating your profile. If you wish to rectify other data, please contact us here.
Deletion or ErasureRight to delete personal data
You can delete some of the data you provided us directly within the service. You can also close your account as explained here and we’ll delete your data as laid out in this Privacy Policy. In any event, you can always contact us here.
Objection (Opt-out) or RestrictionRight to object to us processing personal data or to request that we temporarily or permanently stop processing personal data
You can directly opt-out from certain of your personal data processing in your account settings. Otherwise you can contact us here should you wish to object to or restrict a data processing we’ve listed throughout this Privacy Policy.
Consent WithdrawalRight to withdraw a consent you’ve given us to process your personal data for a specific purpose
You can directly withdraw consent you’ve given us either by updating your account setting or removing Device Permissions you’ve agreed to in your device settings (e.g., access to specific types of device data such as phone contacts, pictures, advertising identifiers and location services or consent to receive push notifications). When you withdraw consent, certain services may lose functionality. You can always contact us here for more information.
Opt-out of Targeted Advertising, “Sales” and “Sharing.”If you live in the United States, you may opt out of activities that may fall under the legal definitions of “targeted advertising,” “sales,” or “sharing” under applicable laws
To opt out, please visit the “Your Privacy Choices” link in the footer of our website and in the Settings menu of the app and adjust the “Sale or Sharing of Personal Information” toggle accordingly. Authorized agents may submit opt-out requests on behalf of consumers here.
Independent Data Review
If you disagree with your MyNIL Brand Score and would like to appeal the calculation, you must first request a review process.

To request a review process, access your profiles settings and select Brand Score. Click more options, then if you see the option, click Request review. During busy periods, we may not be able to review all requests, but we’ll keep you updated about the status of your request.

We reserve the right to change or update information and to correct errors, inaccuracies, or omissions at any time without prior notice.

AI Usage Policy

AI Insight
We anticipate that we will use the data collected from MyNIL’s platform and its related sites to provide various AI insights to use in MyNIL’s operations. Although AI technologies are still being refined and can produce inaccurate or distorted information on rare occasion, MyNIL has created guidelines for responsibility using AI in a way that protects MyNIL users’ data, proprietary information and ensures compliance with applicable laws, regulations, ethical standards, and upholds the MyNIL’s values.
AI Insights Opt-Out
Out of respect for your privacy, you may choose to opt out and MyNIL will not be permitted to use your data in the AI insights process. Please following the instructions to complete the opt out on the preferences tab in your account settings page or you can contact us at Admin@MyNILBrand.com.

For your protection and the protection of all of our users, we may ask you for information to verify your identity or authority to act on behalf of a user before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else.

If you are a resident of Virginia, Colorado, or Connecticut, USA, if we deny your privacy request, you may be able to appeal by contacting us, and explicitly referencing “Privacy Request Appeal.” If you have concerns about the result of your appeal, you may contact the attorney general for your state.
How Long We Retain Your Data
We want the connections you make through our service to last forever, but we keep your personal data only as long as necessary for legitimate business reasons (as laid out in Section 3) and as permitted by applicable law.

If you decide to stop using our service, you can close your account and your profile will no longer be visible to other users. Note that we will close your account automatically if you are inactive for two years.

Following account closure, we delete your data as laid out below:

1. To protect the safety and security of our users, we implement a safety retention window of three months following account closure. During this period, we keep your data to investigate unlawful or harmful conducts. The retention of data during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.

2. We maintain limited data on the basis of our legitimate interest: to support our safety efforts, to support our customer care decisions, and enable us to defend ourselves in the event of a claim, profile data for one year in anticipation of potential litigation, for the establishment, exercise or defense of legal claims, and data necessary to prevent users who were banned from opening a new account for as long as necessary to ensure the safety and vital interests of our users.

3. Finally, we maintain data on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep data in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings.

4. Where and as legally permitted, we may maintain and use data that, by itself, cannot identify or be attributed specifically to you for the purposes described in this Privacy Policy, including to improve our service, create new features, technologies and services, and keep MyNIL services safe.
Children’s Privacy
You must be at least 13 years old to use the Service, however if you are under the age of 18, you must represent that you have your parent or guardian’s permission to use the Service. Please have them read this Agreement with you.
Permission by Parent or Guardian
If you are a parent or legal guardian of a user under the age of 18, by allowing your child to use the Service, you are subject to the terms of this Agreement and responsible for your child’s activity on the Service. If your account has been determined to be in violation of MyNIL’s age requirements, the account will be immediately terminated and removed from the platform.
Privacy Policy Changes
This policy may change over time. We’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations of our data practices remain up-to-date. We will notify you before material changes take effect so that you have time to review the changes.
Contests, Sweepstakes and Promotions
Any contests, sweepstakes or other promotions (collectively, “Promotions”) made available through the Service may be governed by rules that are separate from these Terms. If you participate in any Promotions, please review the applicable rules as well as our Privacy Policy. If the rules for a Promotion conflict with these Terms and Conditions, the Promotion rules will apply. The terms and conditions of any other “Promotions” are independent of this agreement.
Waiver of Liability
Your use of the MyNIL Services is at your sole risk. The Services are provided on an “AS IS” and “AS AVAILABLE” basis. The Service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance. MyNIL and its affiliated parties shall not be liable for any loss, injury, claim, liability, or damage of any kind resulting in any way from any advising, recommendations, counseling under any circumstance.
Arbitration
Any legal controversy or legal claim arising out of the use of the MyNIL platform (excluding legal action taken by us or you to collect or recover damages for, or obtain any injunction relating to, intellectual property ownership or infringement), shall be settled solely by confidential binding arbitration in accordance with the commercial arbitration rules of JAMS. Any such controversy or claim shall be arbitrated on an individual basis, and shall not be consolidated in any arbitration with any claim or controversy of any other party. The arbitration shall be conducted in Pennsylvania. Each party shall bear one-half of the arbitration fees and costs incurred through JAMS, and each party shall bear its own attorneys’ fees.
California-Specific Disclosures
These California-specific disclosures apply solely to individual residents of the State of California, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”).

For purposes of this section, the term “Personal Information” has the meaning given to “personal data,” “Personal Information,” or other similar terms in the CCPA and does not include information exempted from the scope of the CCPA, such as publicly available information. “Sensitive Personal Information” has the meaning given to such term in the CCPA.

Your Privacy Rights. We do not “sell” or “share” Personal Information as those terms are defined in the CCPA (and have not done so during the prior 12 months). We do not engage in any “Profiling” (as such term is defined under the CCPA) in furtherance of decisions that produce legal or similarly significant effects about you, where regulated by the CCPA. We also do not use or disclose Sensitive Personal Information for purposes that California residents have a right to limit under the CCPA, and where required by applicable law, we obtain your consent before we collect Sensitive Personal Information from you.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can contact us as set forth in "Contact Us" below.

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the platform.

International Privacy Policies

Disclosure of Your Information
We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.

As part of our GDPR and BS10012:2017 compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection.  The use of non-disclosure agreements forms part of our third-party data sharing controls.

We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements; or to protect the rights, property or safety of MyNIL users or others.

MyNIL has risk assessed where personal information may be transferred outside the EEA.  As part of our own due diligence we have identified that personal data held for and by Thrive resides in the EU.  MyNIL will continue to monitor this for MyNIL considering any 3rd party provider changes in the future. Should a requirement for data to be transferred outside of the EU in future, MyNIL will implement controls and safeguards to ensure that equal to or greater data protection measures are enforced and records retained to evidence this.
Termination
We may terminate or suspend your account immediately, without prior notice or liability, for any reason whatsoever, including without limitation if you breach the Terms. Profiles that have been determined to be in violation of our Upon termination, your right to use the Service will immediately cease. If you wish to terminate your account, you may simply discontinue using the Service.

All provisions of the Terms which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.
Indemnification
You agree to defend, indemnify and hold harmless MyNIL and its licensee and licensors, and their employees, contractors, agents, officers and directors, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees), resulting from or arising out of a) your use and access of the Service, by you or any person using your account and password, or b) a breach of these Terms.
Limitation of Liability
In no event shall MyNIL, nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use the Service; (ii) any conduct or content of any third party on the Service; (iii) any content obtained from the Service; and (iv) unauthorized access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.