MiTu Community Service Data Privacy Policy and Terms



Date of Last Revision: November 13, 2013


Data Received by the MiTu Community Service and how the Service Uses that Data


I. Information the MiTu Community Service receives about users

The MiTu Community Service receives different types of data about users, including:


    a.   User’s Data

User’s Data is the information that’s required when a user signs up for a MiTu Community Account, as well as the information a user chooses to share when a subscriber is in a group.

- Account Registration Data: When a user signs up for a MiTu Community Account, users are required to provide their name, email address, birthday, and gender. The MiTu Service will also hold the user's mailing address to send payments if they are a group owner.

- Persona Data: When a user generates a Persona (one or more), users are required to provide a name, general information on that persona, determination to inherit data from the user’s account and indicating information about their work, activities, books, movies, etc.

- Data that a user chooses to share when in a group: User Data also includes the information a user chooses to share in a MiTu Community Group, such as when a user posts to a group update scroll page, uploads a photo, comments on a Blog Post, or comments on a group subscriber’s post.

- Data that a subscriber provides as content submitted to an owner for a blog post, calendar post and library post: User Data provided to the owner of a group regarding blogs will be considered ownership of the Owner of the Group once the user submits their suggested blog. This specifically covers ONLY the written text for the blog. The Subscriber cannot claim copyright infringement once the owner of the group posts their suggested blog in part or in whole. The owner of the group MAY NOT lay claim to any photos or videos that accompany the blog post. It is upto the subscriber to properly mark their intellectual property on their photos and videos to ensure that the followers and subscribers of the group understand whom the owner is of the intellectual property.

It also includes the data a user chooses to share when they take actions, such as when a user requests a friend to follow a group, like a post, determine a post is important, generate a group, find groups using the group search button, or indicate their status/information in their Persona.


It is critical to note that the MiTu Community Service in not like other services that see any information as pertaining to information that is made public. The MiTu Community Service was generated to be a highly secure site FIRST and then users determine how they reveal their information to whom through their Personas.


If a user chooses to keep their entire account information private, but generates a unique persona that does not indicate any personal information, that user has a right to keep their information private.


If a user makes their Account Information accessible through their Persona, their persona name, persona picture, group subscriber network are treated just like information a user would choose to make public.


To ensure Group Owner's have the tools necessary for managing their accounts, the group owner will have access to their subscriber's account name. Group owners are always encouraged to NOT reveal subscriber's names to their group subscribers. If users report such a violation, the MiTu Community Service Team may need to freeze the offending group or account. (Blind View of subscribers in the MiTu Community Service, where the Group Owner cannot see the Account name, is scheduled to be added at a later date.)


Additionally, the user should keep in mind, there is a third level of security that does not exist in most other sites, that is a level of security that can be driven to the group level. A user can generate a group that is not “Public”, this group then can only be viewed by subscribers of the group. As such, a user then could generate an account, which could be held private, participate in a non-public group and the only people that would have access to their information is those whom are within that group’s subscribers.


The MiTu Service does utilize some of a user’s data in the following way to best deliver content that is relevant to a user’s needs. The user’s birthday allows the MiTu Service to determine age-appropriate content and advertisements that would be accessible to the user when the user is a member of a group and not a subscriber. The MiTu Service also utilizes location information and a user’s area of interests to drive read-only member based advertisements to ensure that the user will see only what is relevant to the user’s entire experience while using the MiTu Service.

Information other users share about a user
The MiTu Community Service can receive information about a user from other group subscribers within a group, such as when they comment to a post a user has made.


The MiTu Community Service may also receive information about a user from the websites a user connects with and uses (like Facebook and Twitter), but the MiTu Community Service will only connect to these sites if the user has granted the proper permissions.


Other information the MiTu Community Service receives about users
The MiTu Community Service also receives other types of information about users:

- The MiTu Community Service will also capture data about users as they interact with their community, such as when a user Views another user's persona's profile, sends the group a message, searches for a group or a persona, view an ad, or upgrade your subscription level in a group.

- When a user posts things like photos on the MiTu Community, the MiTu Community Service may receive additional related data (called metadata), such as the time, date, and place the user loaded the photo.

- The MiTu Community Service receives data from the user's computer, mobile phone or other device a user uses to access the MiTu Community Service. This can include a user's IP address, location, the type of browser the user is using, as well as the groups, posts and blogs the user may visit.

- Sometimes the MiTu Community Service will receive data from advertising partners, customers and other third parties that work to help the MiTu Community Service deliver ads, understand online activity, and assist in generating the best online private business network experience. For example, a partner may tell the MiTu Community Service how users are responding to an ad on the MiTu Service in order to statistically analyze the effectiveness of those ads to best improve the user's experience.

If and when the MiTu Community determines it should provide data to advertising partners or customers the MiTu Community will remove the user's account name, persona name or any other personally traceable information from the data being shared. The MiTu Community Service may also combine the data with other user's data in a way that it is no longer associated with the users. Similarly, when the MiTu Community Service receives data about users from advertising partners or customers, the MiTu Community Service will keep the data for 360 days. After that, the MiTu Community Service will combine the data with other user's data in a way that it is no longer associated with the user.


    b.   Public data


When the MiTu Community Service refers to the use of "public data" we mean the information users choose to make public, as well as information that is always publicly available to users on the MiTu Community Service.


Information users choose to make public
Users that choose to make their information public (Persona or Group) includes the universe of people: anyone in the world, including users that do not have an account with a MiTu Community, is able to see the user's data (Persona and Group).


Users that choose to make their information public also intend that this information:

- is associated with the user publishing the data (i.e., The user's persona name, persona picture, Persona profile, Persona User ID, etc.) even off of the MiTu Community Service


- can show up when another user does a search on a MiTu Community or on a public search engine


Users in a MiTu Community can have a choice to make their groups Public or Private, at this time all groups are changeable from private to public and once private CANNOT be changed to public. These two options should be considered when following any MiTu Community Group such that if a user follows a Public group, the user should expect their information to be shared on that Group to be Public in nature. Users should also expect to have their information treated as private within a group's  subscribers when a group is "Private" and where the owner of the group has committed to never make the group public.


Information that is always publicly available
Due to the nature of the security model with the MiTu Community Service, a user can configure their account, personas and interactions with the groups in a fully secure environment such that no users, without prior knowledge of the links, can use search tools to find users in a MiTu Community or in a publicly available search engine.


Information that is public once identified as such

There is some information that is considered public once the user determines that is should be public. The type of information listed below is treated just like public information:

- Persona Name: This helps other users find you. If a user determines they are uncomfortable sharing their real name, they can always deactivate or delete their persona and generate one with a pseudo name.


- Persona Profile Pictures
: This helps other users recognize a user. Some users may not be uncomfortable making their picture public, they can always upload a pseudo picture or delete the photo.

- Profile and Group URL: This link allows the user to send their persona URL or group URL to other users in sharing their information. If the Persona or Group has been marked as Public the receiving user will be able to click on the link and see the user's persona information or group site (including all posts and blogs).


    c.   How the MiTu Community Service uses the information that is received

The MiTu Community Service uses the information received about users in connection with the services and features we provide to you and other users like your friends, the advertisers, and the customers that build the applications that users use. For example, the MiTu Community Service may use the information received about users:

- as part of the MiTu Community Service Team’s efforts to keep the MiTu Community Service safe and secure;


- to measure or understand the effectiveness of ads users see;


Granting the MiTu Community Service this permission not only allows the MiTu Community Service Team to provide the MiTu Community Service as it exists today, but the MiTu Community Service Team will have the information to create additional innovative features and services for the future. While users allow the MiTu Community Service to use the information received about you, users always own all of their own information.


The MiTu Community Service Team is challenged to meet user needs in Data Privacy and Security to ensure a user’s trust. With the focus first on a secure environment and the use of Personas as a representation of a user’s interaction with a Group, the users can entrust their most important information and relationships within the MiTu Community Service. Since a user’s trust is critical to our success, a MiTu Community does not share information received about users with others unless the MiTu Community Service Team has:


- received the user’s permission;

- given the user notice, such as by telling them about the need to share their data; or


- removed the user’s name or any other personally identifiable information from the data.

    d.   Deleting and deactivating your account

If users want to stop using their account, they can delete it.


Deletion
When a user deletes an account, it is permanently deleted from the MiTu Community Service 30 days after the user indicates that they would like the account deleted. After the initial deletion some information may remain on the the MiTu Community Service’s backup copies and logs for up to 120 days. Users should delete their account if they are sure they never want to reactivate their account again.



II. Sharing and finding Groups and Personas on the MiTu Community Service


    a.   Controlling Posts


Since the manner in which the MiTu Community Service works, the MiTu Community Service does not provide a specific means to control the people that can view a user’s posts. The expectation is that if the user is a subscriber of the group, any posting on the group should be relevant to the group as a whole. If the user is not wanting some subscribers of the group to see their posting, then that user might consider following a different group. Additionally, if the owner of a group is looking to post to one portion of their subscribers vs. another portion of their subscribers, the owner might consider splitting the group such that the right people can see the right information.


    b.   User control over their Persona


Whenever a user changes their Persona data, only those subscribers in groups the Persona is participating will see the changes. Again, since the security is built into the notion of Persona tied to Groups, there is no need to filter the data based on any generalized grouping that a user might have.


To make it easier for users to find you, the MiTu Community Service allows anyone with a users contact information (such as their email address or mobile number), to find them through the MiTu Community Service search as long as that user has indicated that they have a public Persona that they would like people to find.


    c.   What user subscribers share about other subscribers


Photo Tags

At this time the MiTu Community Service does not have any tagging available since the purpose of the MiTu Community Service is to facilitate the purpose of group suscribers, not tagging friends in photos.


Groups
Users can only be invited to be in a group by the Group Owner for Private or Super Groups, or if the Group is a public group, subscribers of that group can invite other potential users. But there is no way that a subscriber can place another subscriber into a Group. This action would not satisfy the notion of security for the MiTu Community Service’s purpose which is to create a shared secure environment that users feel safe to be able to participate and then be able to decide not to participate in a group without the need to remove them from the MiTu Community Service.



III. Sharing with other websites, applications and government


   a.    Logging in to other sites using the MiTu Community Service


The MiTu Community Service lets a user log into other websites, such as Facebook and Twitter, using your MiTu Community Service Group. When you log in to Facebook and Twitter using the MiTu Community Service, the MiTu Community Service gives the site an id that is used to track the relationship to the owner’s group, but MiTu Community Service will not share a user’s MiTu Community email address or password with that website.


    b.   Public search engines


With the MiTu Community Service, if a user generates a Persona that is Public, there is a chance that public persona will be viewed by any one of the many search engines on the world wide web. In doing so, there is that chance that a user’s persona could appear in the listing for that user’s information when doing a search.


    c.   Government


With the MiTu Community Service, your data is safe from government intervention and prying. The official policy of the MiTu Community Service is to protect your data from anyone trolling to discover anything about you that intentionally or unintentionally implies a personal belief or personal interest as long as those personal beliefs or personal interests do not violate the terms of this service. If the government determines that the data that resides on the site is required to protect the nation or individual harm, the government has the responsibility to obtain a warrant for that said information. Within that warrant, the government is held responsible to provide the specific name and email address of the suspect in question. If properly identified, the MiTu Community Service Team is responsible for providing all information associated to that account, including all posts to other groups and all groups that account has ownership. The MiTu Community Service Team also has the responsibility of informing their targeted customers when such warrant has been presented. The MiTu Community Service is responsible for sending an email to the suspected MiTu Community Account owner at which time the warrant request has been fulfilled. Just as the police can arrive at your home with a warrant without prior notification, the same is true for online content. The MiTu Community Service Team commits to making a reasonable effort for any government that provides a warrant that is actionable (Correct email address and probable cause listed in the warrant.). The resulting content retrieved from the MiTu Community Service Database shall be obtained and packaged and submitted via email, snail mail or in person within 48 to 72 hours of the request being made and where at the moment of that content being handed over an email will be generated to the email address of that account in question a notification their data has been given to the government. That notification will only identify the government as local, state or federal (in the case of international requests "Interpol" will only be used).



IV. How Advertising Works on the MiTu Community Service


MiTu Community Service does not share any personal information of a user’s with any advertisers. The advertisers on the MiTu Community Service will only have access to the metadata that represents the users preferences in their Areas of Interests selected by the User as well as the Areas of Interest selected by the group owner. The MiTu Community Service may also capture the time a user spends in groups to define a weighting for the user's personal Areas of Interests vs the Group's Area of Interest, to display non-intrusive ads to the end user.


At this time all Private Groups and Super Groups will not serve ads and at some point we will may have ads running for Public Groups. This may change as our ability to filter ads improves and would allow us to protect group owners from ads they might find intrusive.


Currently, the MiTu Community Service uses a generic ad service called “Adbrite”, at this time there is no special targeted advertising initiatives. As the site grows in popularity this action may become more important to ensure that users, advertisers and customers have options that best server MiTu Community Service's customers whom are our users of the site.



V. The Safety of Minors on the MiTu Community Service


MiTu Community Service takes safety issues very seriously, especially with children, and we encourage parents to teach their children about safe internet practices. To protect minors, the MiTu Community Service may put special safeguards in place (such as placing restrictions on the ability of adults to share and connect with minors).


MiTu Community Service requires that ALL users be at a minimum 13 years of age and have received their guardian’s permission to use the MiTu Community Service as a subscriber of a group. If a minor would like to own a group on MiTu Community Service, the Guardian must provide the billing information and guide the minor in their efforts. Any issues resulting from the minor being an owner of a Group will be the responsibility of the Guardian.



VI. Additional items required by the MiTu Community Service


Responding to legal requests and preventing harm
The MiTu Community Service might need to share a user’s data in response to a legal request (like a search warrant, court order or subpoena) if the MiTu Community Service has a good faith belief that the law requires the MiTu Community Service to do so. This may include responding to legal requests from jurisdictions outside of the United States where the MiTu Community Service has a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. The MiTu Community Service may also share information when there is a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect the MiTu Community Service and its users from violations of our Terms and Conditions; and to prevent death or imminent bodily harm of anyone resulting from their use of the MiTu Community Service. See Section III - c. Government above for the details on how the MiTu Community Service intends to full-fill this requirement.


Data access requests
The MiTu Community Service will provide initial responses to access requests in a reasonable time period, with the goal of communicating to users making the request within 30 days. These requests will be limited to data downloads of a user’s account, identified Personas, any posts that the user has made and any Group data in which you are an owner in which the data will be emailed to you via your email address set in your Account.


Notifications and Other Messages
The MiTu Community Service will be able to send users notifications and other messages using the contact information that is located in the user’s account or persona. When a user follows a group with a persona, that user will have the ability to control their notifications through the group controls.


Invitations
When a user invites a friend to follow the MiTu Community Service, the MiTu Community Service will send a message on the behalf of the user using the user’s persona name. Currently, the invitation will NOT give the invited users the opportunity to opt out of receiving other invitations to follow that specific Account's request to follow their groups at this time, but the MiTu Community Service intends on providing this feature in the near future.


Inactive accounts due to critical health issues or death of a user
The MiTu Community Service will always respect the challenges people face in living their lives and understand that in time those lives sunset in different ways. To be sensitive to this fact, the MiTu Community Service allows Accounts to be transitioned to next of kin or guardians after a 6 month freeze. To begin this process of freezing an account to move it to the next of kin please email the MiTu Community Service at info@Mitusis.com with the following information (Please include the number 3010 so that we can best route your request):

    1. Subject Line: 3010 - CRITICAL HEALTH / DEATH OF THE MITU COMMUNITY SERVICE USER

    2. The Community and Account email address of the User of concern

    3. Description of the situation

    4. Scanned documents that show medical records or death certificate

    5. Mailing address and phone number of organization that can verify events

Once the event has been validated, the account is frozen, meaning that any paying subscribers in the group would be reduced to the “Free” level and any groups the account owned will be see any subscribers that have been at a paying subscriber level being reduced to “Free”.


As noted in the Payment Terms, if an account goes dormant for an extended period of time (See the Payment Terms for exact time periods), the payments as a subscriber to groups and as an owner of a group are reduced to the “Free” level to protect the group’s owner and the subscribers of the group.


Cookies
Cookies are small pieces of data that MiTu Community Service stores on a user’s computer to make the MiTu Community Service easier to use, make the MiTu Community Service advertising more focused, and to protect users (and the MiTu Community Service). For example, the MiTu Community Service may use cookies to know if a user is logged in to the MiTu Community Service. Most companies on the web use cookies (or similar technological methods), including the MiTu Community Service’s advertising partners. Users can always remove or block cookies (such as by using the settings in your browser), but doing so may cause some challenges in using the MiTu Community Service.


Service Providers Assisting the MiTu Community Service
The MiTu Community Service gives the user’s permission to utilize their data and information for the people and the companies that help the MiTu Community Service provide the services the MiTu Community Service offers. For example, the MiTu Community Service may use outside vendors to host the MiTu Community Service website, process payments, or provide search results. In all of these cases the MiTu Community Service partners must agree to only use a user’s data and information consistent with the agreement the MiTu Community Service enters into with them, as well as this data privacy policy and terms.


Security
Keeping users and the MiTu Community Service safe and secure is a team effort, please see the Security Section in the FAQ for the MiTu Community Service to see what users can do to limit the possibility of their accounts being compromised.


Change of Control for the MiTu Community Service 
If the ownership of the MiTu Community Service business changes, the MiTu Community Service will need to transfer the user’s data and information to the new owner so they can continue to operate the MiTu Community Service. The MiTu Community Service will ensure that the new company will honor the commitment the MiTu Community Service has made in this privacy policy for a minimum of 24 months.


Notice of Changes
If the MiTu Community Service Team makes changes to this Privacy Policy the MiTu Community Service Team will notify users by publication in the the MiTu Community Service Data Policy Group and through a notification sent to your account’s email address. If the changes are material, the MiTu Community Service will provide users additional, prominent notice as appropriate under the circumstances such as placing banners on the account page, persona page and group pages.


Opportunity to comment on the MiTu Community Service Data Privacy Terms
Unless the MiTu Community Service makes a change for legal or administrative reasons, or to correct an inaccurate statement, the MiTu Community Service will give users seven (7) days to provide the MiTu Community Service Team with comments on the change. If the MiTu Community Service receives more than 30% of the total registered the MiTu Community Service accounts with concerns regarding a given change, the MiTu Community Service will retract the change and establish a better policy that will have less impact to the user base. Please send the comments to info@mitusis.com with the following information (Please include the number 3020 so that we can best route your request):

      1. Subject Line: 3020 - DATA PRIVACY TERM CHANGE CONCERNS

      2. Your community and account email address

      3. Text of the concerning policy terms

      4. Description of the impact the changes have had on the ability to use the MiTu Community Service's Services

      5. Suggested changes that should be made to correct the situation