Effective February 1, 2023
Your privacy is important to us. We provide this notice to you to explain what information we collect about you, how we collect it, the business purpose for our collection, what information is disclosed to other parties and the business purpose for such disclosure, our retention policy, and the choices you can make about your information.
“Milestone”, “us”, “our” or “we” means Milestone Equipment Holdings, LLC and its subsidiaries.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal information” does not include: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregate consumer information.
“Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication; and (f) genetic data. Sensitive Personal Information includes the processing of biometric information for the purpose of uniquely identifying a consumer, Personal Information collected and analyzed concerning a consumer’s health and Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.
“Site” means the https://www.milecorp.com or mobile application together with the respective content available from these sites/applications or sub sites.
2. Personal Information We Collect About YouThe listlow outlines the categories of information about you that we collect and where we obtain that information.
- Contact Information. We collect and store names, email addresses and phone numbers from users who may provide their information on this Site to access myMilestone, subscribe to our newsletters, request a brochure or email us.
- Credit Applications. If you submit a credit application to Milestone through the Online Credit Application or make a payment via E-Bill Express, we collect and store information including, but not limited to, names, e-mail addresses, telephone numbers, addresses, social security numbers, driver’s license number, banking information and dates of birth.
- Other Information. We collect or store personal information about you when you voluntarily provide it through this Site, myMilestone, the Online Credit Application, E-Bill Express or submit via electronic communications to us, including information regarding products or services you purchase.
- Device Information and Identifiers. We collect IP addresses of devices accessing our services in our server logs, as well as information like internet domains, the date and time of a visit, and the pages accessed on the Site.
- Audio and Electronic Information. We collect voicemails and emails that we receive.
3. Business Purpose for our Collection of Your Personal InformationWe use your Personal Information in the following ways:
- To create and use your myMilestone account;
- To communicate with you about your credit application, myMilestone and equipment rental and leasing;
- To bill you and facilitate online payments;
- To notify you of new features or products;
- To provide you marketing communications about our new products and services;
- To provide you marketing communications about third-party products and services that we think may be of interest to you; and/or
- If applicable we, store your device information and verification of your acceptance of the terms and conditions of Milestone’s equipment rental and leasing agreements and related agreements and verification of online payments. This information is also used for diagnostic and analytic purposes in order to improve the services we provide.
4. Personal Information We Have Collected in the Preceding 12 Months, and WhySubject to the disclosures made above, set forth below in chart format are the categories of Personal Information we have collected in the preceding 12 months, the categories of sources from which the Personal Information was collected and the business purpose for the collection.
|Category of Personal Information||Examples||Categories of Sources from which Personal Information Collected||Business Purpose for the Collection|
|Identifiers||See Sections 2.A., 2.B., 2.C. and 2.D. above.||Directly from you. Automatically when you visit our Sites, including cookies* and tracking technologies. Our affiliates. Analytics providers.||See Sections 3.A., 3.B., 3.C., 3.D. and 3.E., 3.F. and 3.H. above.|
|California Civil Code Section 1798.80 Identifiers Not Included in Other Rows||See section 2.B. and 2.C. above.||Directly from you. Our service providers.||See Sections 3.A., 3.B., and 3.C. above.|
|Commercial Information||See Section 2.C. above.||Directly from you.||See Section 3.D, 3.E. and 3.F. above.|
|Internet Information||See Section 2.D. above.||Directly from you. Automatically when you visit our Sites, including cookies and tracking technologies. Analytics providers.||See Section 3.H. above.|
|Geolocation Information||See Section 2.D. above.||Directly from you. Automatically when you visit our Sites, including cookies and tracking technologies.||See Section 3.H. above.|
|Audio and Electronic Information.||See Section 2.E. above.||Directly from you. Automatically||See Sections 3.B., 3.E., 3.F., 3.G., and 3.H. above.|
|SENSITIVE PERSONAL INFORMATION|
|Sensitive Identifiers||See section 2.B. and 2.C. above.||Directly from you.||See Sections 3.A., 3.B. and 3.C. above.|
5. Personal Information We Sell, Share or Disclose.
- Sale/Share of Personal Information. We do not sell or share Personal Information as defined under California law, with a proviso regarding Google Analytics, next described.
- Service Providers and Contractors.
We disclose Personal Information to our service providers and contractors for the business purposes identified below (these entities are not permitted to disclose or use such information for any other purpose):
- Services on Our Behalf: We may disclose Personal Information in order to receive services performed on our behalf, including processing or fulfilling transactions and checking credit worthiness.
|Categories of Personal Information that We Disclose||Business Purposes for the Disclosure of Personal Information|
|Identifiers||Services on Our Behalf|
|Account Information||Services on Our Behalf|
|Commercial Information||Services on Our Behalf|
|Internet Information||Services on Our Behalf|
|SENSITIVE PERSONAL INFORMATION|
|Sensitive Identifiers||Services on Our Behalf|
6. How We Retain and Store Personal Information.
We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation and our record retention policy. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
7. Your Choices and Rights.
We endeavor to ensure that Personal Information is as accurate, complete and current as necessary for the purposes for which we use that information. We encourage you to visit Settings to review your Personal Information. You can access your Personal Information in My Account and update it or delete inaccuracies, as necessary. For example, you can change at any time your e-mail address or your preferences.
8. Protection of Personal Information.We employ the following data security tools to protect Personal Information:
- In certain areas of the Site, Milestone uses or may use industry standard SSL and TLS encryption to enhance the security of data transmissions.
- Account information is password protected.
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- We restrict access to Personal Information to select Milestone employees and third-party contractors who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
9. Your Rights Under California Law (For California Residents)
California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and related regulations. Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.
Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting Personal Information; (4) the categories of third parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you. You may submit a request by calling us at 1-866-706-1144 or emailing us at [email protected]
- Right to Know Personal Information Disclosed and to Whom. Since we disclose your Personal Information, as described above, you have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; and (2) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. You may submit a request by calling us at 1-866-706-1144 or emailing us at [email protected].
- Right to Request Deletion of Your Personal Information. You have the right to request that we delete your Personal Information. Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records. If we cannot delete all of your Personal Information, we will let you know the reason. You may submit a request by calling us at 1-866-706-1144 or emailing us at [email protected].
- Right to Correct Inaccurate Information. If you believe that any of the Personal Information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct. You may submit a request by calling us at 1-866-706-1144 or emailing us at [email protected].
- Right to Opt-Out of the Sale and Sharing of Your Personal Information. As noted above, we do not sell or share your Personal Information. As such, this right does not apply to you.
- Right to Limit the Use of Your Sensitive Personal Information. We only use your Sensitive Personal Information for services on our behalf and for fraud and security purposes. As such, this right does not apply to you.
- Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.
When you make a request to know, delete and/or correct, 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 or not and the request you are making. The following generally describes the verification processes we use:
- Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
- Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
- For requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
- For requests to know specific pieces of Personal Information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records.
- For requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete Personal Information, including an explanation of why we have no reasonable method to verify your identity.
If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130.
We will respond to requests to know, requests to delete and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.
10. Your Nevada Privacy Rights (For Nevada Residents)
We do not and will not sell your Personal Information to third parties. As such, there is no need to submit a request for us not to sell your Personal Information. If you have any questions, feel free to contact us at 1-866-706-1144 and [email protected].
11. Accessing and Correcting Your Personal Information
13. Contact Information