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Privacy Policy


Last Updated:  January 2020


References herein to the “Company,”
“we,” “us,” “our”, means 
You may contact us by email at with respect to
any notice required by these privacy practices or with respect to any questions
you have regarding these Privacy Practices.

References herein to “you” or “your”
means the individual using our Services and any entity on behalf of whom the
Services are accessed.

We have
developed these Privacy Practices to disclose and explain to you how we may collect, retain, process, share and transfer information
collected from you when you use our Services. 
By referring to these Privacy Practices and our rights herein, you may
make an informed decision about how you will use and interact with our
Services.  By accessing our Services, you
are agreeing to these Privacy Practices. 

Section 1. Our Privacy Practices Generally

purposes of these Privacy Practices, “Personal Information” means information
that you provide to us that personally identifies you, such as your first and
last name, email address, physical address, telephone number and billing

For purposes of these Privacy Practices, “Non-Personal Information” means information that does not specifically identify you.

Our Privacy Practices can be summarized as

Section 2. Information We Collect

We may
collect information from you based on information collected resulting from your
use of our Services and information that you provide to us.  The information collected may include both
Non-Personal Information and Personal Information.

The information we
collect about you may include the following:

3. Our Use of Your Information 

We use your information to
provide our Services, including personalizing and improving such Services, such
as by using this information to better understand how you utilize and interact
with our Services.  Specifically, we use
your information to:

When performing the foregoing functions, your
Personal Information may be combined with information we obtain about you from
other sources.  To the extent we combine
your Personal Information with Non-Personal Information, we will treat such
combined information as Personal Information for so long as it remains

Our Information
Sharing Practices

Unless you have provided
your consent to do so, we do not share your Personal Information with any third
party for their own marketing purposes. We may share your information in the
following ways:

Except as set forth above, we
do not share information that individually identifies our users, including you,
with companies, organizations or individuals outside of the Company and its
affiliated entities.

When transferring your
information, we do comply with all applicable privacy laws.  In accordance with our EULA, we disclaim and
shall have no liability or obligation in connection with any third party
actions or omissions concerning your information, even if such information was
obtained from us in accordance with these Privacy Practices.  Please contact
the applicable third party if you experience any issues with respect to such
third party’s use of your information.   The Section below titled Third Party Practices
provides additional information regarding our interaction with and sharing of
information with third parties. 

Section 5. Cookies and Tracking Technologies

When you
use our Services, we may send your computer or mobile device a cookie that
uniquely identifies your browser. A “cookie” is a small file containing your
preferences that is sent to your browser and sent back by your browser each
time your browser accesses our servers.  As used in these Privacy Practices, we use the
term “cookies” to refer to cookies and all such similar technologies that
collect information automatically when you are using our Services.  We use cookies and the data derived from such cookies to
improve the quality of our Services and your use of those Services, such as to
deliver our Services and Service content in your language of choice, to filter
results and deliver the Services in accordance with your preferences, as well
as to analyze the interaction of our user with our Services.  For example, we track user trends and
patterns of how people search.  The
cookies we use can only be read by the server that placed them there.  Many browsers are set up to accept cookies
unless the user changes the settings for cookies.  By properly setting your
preferences in your browser, you can control which and what types of cookies
are downloaded from the Services. Be advised that, while you can choose to opt
out of receiving cookies, our Services may not function correctly without
cookies.  You can review more information
about cookies and how to control and delete cookies in various browsers, such
as Chrome, Safari, Internet Explorer and others, please visit

We use web analytics companies to assist us
in measuring the effectiveness of our Services. 
In order to do so, we also allow these to include their own Web beacons
and cookies on the Services. Information collected by these web analytics
companies from Web beacons and cookies includes click-throughs by users and
other similar information. This information is used by us to improve our
Services, including by understanding overall user preferences, click-through
rates, means to improve our Services, and the types of offers that are of most
interest to our users. Although this information is collected by third parties,
it is done on our behalf and we retain control over the use of such information.

You can “opt-out”
of receiving cookies from certain of our ad serving partners.  For more information on how to do so, please

Section 6. Data Protection

The protection of your Personal Information is
of great concern to us. Except as otherwise provided for in these Privacy Practices, we restrict access to your Personal Information to our
employees, contractors, affiliates, service providers, and agents. In
furtherance of our efforts protect your personal data against loss, misuse,
unauthorized access, disclosure, and alteration, we maintain technical,
physical, and administrative security measures designed to provide reasonable.
The security measures include firewalls, data encryption, physical access
controls to data centers we use, and information access authorization controls.
Notwithstanding our dedication to securing our systems and Services, you remain
responsible for securing and maintaining the privacy of your password, if any,
used in connection with your use of our Services. Even given the precautions
against possible breaches in our Services and databases, we cannot guarantee
that it is completely secure. We can make no assurances you that unauthorized
hacking, access, data loss, or other breaches will never occur and disclaim all
liability in connection with any such activities.  Accordingly, as set forth in our EULA, your
use of our Services is at your own risk. You are encouraged to protect your
Personal Information when you are on the Internet, including making sure you
use a secure Internet browser.

Section 7. Third Party Practices

In connection with the provision of our
Services, you may be requested or required by our service providers to provide
information, including Personal Information, to them or to download certain
software. We assume no responsibility for the privacy practices of our service providers, including Third Party Service
providers, or the contents of any software downloaded from them.  To the extent our Services are linked to
Third Party Services, we have no control over such Third Party Services, as set
forth in our EULA.  While applicable law
obligates our service providers to protect the privacy of certain types of
data, we assume no responsibility for the actions or omissions of our services
providers, even as relates to information they receive directly from us.  Under no circumstances are we responsible for
the privacy practices or
the content of such Third Party Services, including their information
collection, storage, usage and sharing practices.  We recommend you contact such Third Party
Service providers directly in connection with any questions or concerns you
have about their protection of your information and their overall privacy practices.  You may also
notify us by emailing us at, though we maintain no responsibility to reply to such
correspondence or to take any action in connection with such correspondence.

Section 8. Information Retention

Unless a longer retention
period is required to comply with law or a legal request, we generally retain
information collected about you only as long as is necessary for us to fulfill
our business purposes.  Nevertheless, we
may, in certain circumstances, choose to anonymize certain information you
provide to us so that it can no longer be attributed to you if we would like to
retain it for longer periods of time.

Section 9.  Age Restriction

Children under the age of
13 are prohibited from using our Services. 
Our Services are not directed to children under the age of 13.  While we do not knowingly collect information,
including Personal Information, from children under the age of 13, in the event
that we obtain actual knowledge that we have collected Personal Information
from a child under the age of 13, we will promptly delete it, unless we are
legally obligated to retain such data. We request that you contact us
immediately if you believe that we have mistakenly or unintentionally collected
information from a child under the age of 13. 
Additionally, we comply with the Children’s Online Privacy Protection Act;
for more information the Act and children’s privacy, please visit

Section 10. International Data Transfers

If you live outside the
United States, be advised that the Company may transfer your Personal
Information to countries other than the one in which you live. In particular,
your Personal Information will be transferred to and processed in the United
States where many of our central databases operate. By using our
Services, you are consenting to such cross-border data transfers of your
Personal Data, as set forth in these Privacy Practices. By using the Services, you consent to your Personal
Information being collected, processed and transferred as set forth in these Privacy Practices and U.S. law and you acknowledge that the data protection
and other laws of other countries, such as the United States, may provide a
less comprehensive or protective standard of protection than those in your
country. The Company has entered into European Union Model Clauses, also known
as Standard Contractual Clauses, to meet the adequacy and security requirements
for our users in the European Union.

We do not represent or warrant
that our Services are appropriate or available for use in any particular
jurisdiction. Those who choose to access the Services do so on their own
initiative and at their own risk, and are responsible for complying with all
local laws, rules and regulations. We may limit access to our Services, in
whole or in part, to any person, geographic area or jurisdiction we choose, at
any time and in our sole discretion.

Section 11. Your Rights Generally

Individuals located in
certain countries, including the European Economic Area, have certain statutory
rights in relation to their Personal Information. Subject to any exemptions
provided by law, you may have the right to request access to your Personal Information
that we retain, as well as to seek to update, delete or correct this Personal Information.
If you wish to exercise any of these rights, please contact  While we may be
able to provide you access to your Personal Information in some cases, there is
no guarantee we will be able to provide access in all circumstances. In circumstances
where we are unable to verify your identity or are required to retain such
information in accordance with applicable laws, we may not be able to modify or
remove your Personal Information. We will remove your Personal Information in
accordance with applicable law.

To the extent that our
processing of your Personal Information is subject to the General Data
Protection Regulation (“GDPR”), the Company relies on your consent. If we have
collected and process your Personal Information with your consent, then you can
withdraw your consent at any time by contacting us at

Section 12.  EEA
Data Privacy Rights

Economic Area residents have the right to restrict the Company’s use of your Personal
Information and lodge a complaint with your local data protection authorities,
subject to applicable law. If you are a resident of the European Economic Area
and believe we maintain your Personal Information within the scope of the GDPR,
you may direct questions or complaints to us at .

Section 13. California Data Privacy Rights

Under California Civil Code Section 1798.83, which
is also known as the “Shine The Light” law, users who are California
residents may request from us a list of the Personal Information (if any) that we
have disclosed to third parties for direct marketing purposes during in the
preceding calendar year, this includes the names and addresses of such third
parties. Requests may be made only one time per year. These requests are free
of charge. To make a request, please contact us at and note that we are not
able to accept requests through the telephone, mail or by facsimile.  We cannot be responsible for notices that are
not labeled or sent properly or that do not have complete information. In the
body of such request, you must put the statement “Your California Privacy
Rights”, as well as your name, street address, city, state and zip code
and you must provide enough information for us to determine if this applies to
you. Additionally, you must attest to the fact that you are a California
resident and provide a current California address.

Additionally, California residents have additional rights under the California Consumer Privacy Act of 2018 (CCPA), such as:

You can submit a
request to exercise your rights above by mailing, emailing or calling us using
the following information: 


Seven Mile Technologies Ltd.
10 Market ST, #1073
Grand Cayman, KY1-9006
Cayman Islands

You must confirm
that you are a resident of the State of when asserting your rights under the
CCPA.  We reserve the right to request
that you provide further evidence as a resident of California before acting on
your request.

You can expect a
response to your request within 45 days of your submission of same.  When responding, we will include the
categories of third parties to which we have sold data about you.  For more information on why we have collected
data about you, please see the rest of this Privacy Policy and our EULA.

To opt-out of the
Company from selling any of the information it collects about you to third
parties and to delete all such information, we offer an “Opt-Out” Option, which
can be accessed by emailing us at

Section 14. More Information

If you have questions about these Privacy Practices,
or if you would like access to Personal Information we may have about you in
our files, to correct, update or to have us delete it, or if you would like to
notify us of your choice to opt-out of any sharing of your Personal Information,
please contact us at For additional information to assist with protecting
your data privacy, you may visit and

Section 15. Privacy Practices Updates

At any time and without notice to
you, we may update these Privacy
Practices by posting a revised version on the Services. Your continued
use of the Services constitutes your unconditional and binding acceptance of these
Privacy Practices, including any updates, amendments, revisions, alterations,
modifications and/or supplements that we make from time to time in accordance
with the provisions of hereof.

encourage you to periodically review these Privacy
Practices for
updates and to ensure that you are familiar with its terms.  If you do not agree to these Privacy Practices, you should immediately discontinue
accessing or using the Services. These Privacy
Practices are
not applicable to Third Party Services or Third Party Content that contain
other privacy practices. If you have any questions regarding these Privacy Practices, please contact us at