Privacy Policy

Last updated February 2nd, 2025

This privacy notice for Milnerva LLC ("Company", "we", "us", "our"), describes how and why we might collect, store, use and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Download and use our mobile application (Milnerva), use our web application, or any other application of ours that contains or links to this privacy notice
  • Engage with us in other related ways including any sales, marketing, or events

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@milnerva.com.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Milnerva LLC and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information. We allow the user to sign up with first name, last name, and email address in order to authenticate the user and provide the user with the requested service.

Do we receive any information from third parties? We do not receive any information about the user from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We will not share information and do not share information with third parties except as required to fulfill contractual obligations or comply with legal requirements.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with the applicable data protection laws.

Table of Contents

  1. What information do we collect?
  2. How do we process your information?
  3. What legal bases do we rely on to process your personal information?
  4. When and with whom do we share your personal information?
  5. How long do we keep your information?
  6. How do we keep your information safe?
  7. Do we collect information from minors?
  8. What are your privacy rights?
  9. Controls for do-not-track features
  10. Do California residents have specific privacy rights?
  11. Do we make updates to this notice?
  12. How can you contact us about this notice?
  13. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services such as first name, last name, and email address, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • email addresses
  • names
  • duty titles
  • passwords
  • contact preferences
  • debit/credit card numbers
  • billing addresses
  • contact or authentication data

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and other technical information.

Once you sign in, if you accept cookies, we use Heap Analytics (powered by Heap.io) to analyze how you interact with our Services. Heap Analytics sets cookies and collects usage data such as user interactions, session data, device information, and technical data (including IP address and browser details) for the purpose of understanding user behavior and improving our services. For more details on how Heap Analytics collects and processes data, please review Heap’s privacy policy on their website.

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of Services.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. This includes analyzing aggregated data collected via Heap Analytics.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In short: We only process your information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information to:
    • Analyze how our services are used so we can improve them to engage and retain users.
    • Diagnose problems and/or prevent fraudulent activities.
    • Understand how our users use our products and services so we can improve user experiences.
  • Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation.
  • Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
  • For investigations and fraud detection and prevention.
  • For business transactions provided certain conditions are met.
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
  • For identifying injured, ill, or deceased persons and communicating with next of kin.
  • If we have reasonable grounds to believe that an individual has been, is, or may be a victim of financial abuse.
  • If it is reasonable to expect that collection and use with consent would compromise the availability or accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or contravention of the laws.
  • If disclosure is required to comply with a subpoena, warrant, court order, or court rules.
  • If the information is publicly available and specified by applicable regulations.

4. When and with whom do we share your personal information?

In short: We may share your information in specific situations described in this section and with certain third parties.

We may share your personal information in connection with:

  • Business transfers. In connection with mergers, acquisitions, financing, or asset sales.

5. Do we use cookies and other tracking technologies?

In short: Yes, we use cookies and tracking technologies to enhance your experience, conduct internal analytics, and improve our Services.

Our Use of Cookies: We use first-party cookies in browser local storage to access or store information on your device as you interact with our application. In addition, if you accept cookies, once you sign in, we activate Heap Analytics from Heap.io to collect usage data such as user interactions, session details, device information, and technical data (including IP address and browser details). This data is used solely for understanding how our Services are used and for improving user experience. Heap Analytics may set cookies and use other tracking mechanisms, and by using our Services you consent to the processing of this information in accordance with this Privacy Policy and Heap’s privacy practices.

6. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this notice, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period in which you have an account with us.

When we no longer have an ongoing legitimate business need to process your personal information, we will delete or anonymize your information, or, if this is not possible (e.g., because your personal information has been stored in backup archives), we will securely store your information and isolate it from any further processing until deletion is possible.

7. How do we keep your information safe?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise that hackers, cybercriminals, or other unauthorized third parties will not defeat our security and improperly collect, access, or modify your information.

8. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from a child under 18 has been collected, we will promptly delete that data.

9. What are your privacy rights?

In short: Depending on your location (e.g., the EEA, UK, Canada), you have certain rights regarding your personal information.

In regions such as the EEA, UK, and Canada, you have rights to access, correct, delete, or restrict the processing of your personal information. You may also have the right to data portability and to object to the processing of your personal data. To exercise these rights, please contact us using the details provided in the section “How can you contact us about this notice?” below.

10. Controls for do-not-track features

Most browsers and mobile operating systems include a Do-Not-Track (“DNT”) feature that you can activate to signal your privacy preference not to have data about your online browsing activities collected. However, no uniform standard for DNT exists at this time, so we do not currently respond to DNT signals.

11. Do California residents have specific rights?

In short: Yes, if you are a resident of California, you are granted specific rights regarding your personal information.

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits California residents to request and obtain information about the categories of personal information we have disclosed to third parties for direct marketing. If you are a California resident and wish to make such a request, please submit your request in writing using the contact information below.

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

  1. Every individual who is in the State of California for other than a temporary or transitory purpose.
  2. Every individual who is domiciled in California but is outside the State for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

If you are a California resident, we must adhere to specific rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details such as your real name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, IP address, email address, and account name.YES
B. Personal information categories listed in the California Customer Records statuteName, contact information, education, employment, employment history, and financial information.YES
C. Protected classification characteristics under California or federal lawGender and date of birthNO
D. Commercial informationTransaction information, purchase history, financial details, and payment information.NO
E. Biometric InformationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our Services.NO
G. Geolocation dataDevice locationNO
H. Audio, electronic, visual, thermal, olfactory or similar informationImages, audio, video, or call recordings created in connection with our business activities.NO
I. Professional or employment-related informationBusiness contact details to provide you with our services at a business level or your job title, work history, and professional qualifications.NO
J. Education informationStudent records and directory informationNO
K. Inferences drawn from other personal informationInferences drawn from any of the collected personal information to create a profile or summary about, for example, an individual’s preferences and characteristics.NO

We may also collect other personal information outside of these categories when you interact with us in person, online, by phone, or via mail—for example, when you receive help through our customer support channels or participate in surveys or contests.

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication. We process your information so you can create and log in to your account and keep your account active.
  • To deliver our services. We process your information to provide you with the services you request.
  • To respond to inquiries and provide support. We may use your information to communicate with you about our products, services, and updates.
  • To manage orders and transactions. We process your information to fulfill and manage your orders, payments, returns, and exchanges.
  • To enable user-to-user communications. We may process your information if you choose to use any offerings that allow for communication with other users.
  • To request feedback. We process your information to collect feedback and improve our Services.
  • To protect our Services. We process your information as part of our efforts to keep our Services secure, including fraud monitoring and prevention.
  • To analyze usage trends. We use data—collected both automatically and via Heap Analytics—to understand how you use our Services and to improve your experience.
  • To safeguard vital interests. We may process your information when necessary to protect your vital interests or those of others.

3. What legal bases do we rely on to process your information?

In short: We process your information when we believe it is necessary and have a valid legal reason under applicable law, such as with your consent, to comply with legal obligations, provide our services, protect your rights, or for legitimate business interests.

Payment Processing

We use Stripe Checkout to process all subscription payments on our Services. When you subscribe, Stripe collects and securely stores your sensitive payment information—including credit card numbers and other payment methods—and processes your payment on our behalf. Milnerva LLC does not store or have direct access to your payment details. Instead, we only receive notifications via webhooks from Stripe about the status of your subscription, which we use solely to manage your account locally.

For more information about how Stripe processes and protects your payment data, please refer to Stripe's Privacy Policy.

If you are located in the EU or UK, this section applies to you.

  • Consent. We process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We process your personal information when necessary to fulfill our contractual obligations.
  • Legitimate Interests. We process your information when it is reasonably necessary for our legitimate business interests, provided that such interests do not override your fundamental rights.
  • Legal Obligations. We process your information as necessary to comply with legal requirements.
  • Vital Interests. We process your information when it is necessary to protect your vital interests or those of another person.

If you are located in Canada, this section applies to you. We may process your information based on express or implied consent, which you may withdraw at any time.

4. When and with whom do we share your personal information?

In short: We only share your information in specific situations described in this notice and with select third parties, such as service providers who help us operate our Services.

  • Business transfers. We may share or transfer your information in connection with mergers, acquisitions, financing, or asset sales.

5. Do we use cookies and other tracking technologies?

In short: Yes, we use cookies and tracking technologies to enhance your experience and for internal analytics.

Our Use of Cookies: We use cookies to store and access information on your device to support the functioning of our Services. Additionally, once you sign in, we activate Heap Analytics from Heap.io to collect data on your interactions with our Services. Heap Analytics may set cookies and other tracking mechanisms to gather information such as:

  • User interactions and events
  • Session data
  • Device and browser details, including IP address
  • Usage patterns and behavior

This data is used solely for understanding how our Services are used, which in turn helps us improve our offerings. For more detailed information on Heap’s data collection practices, please refer to Heap’s own privacy policy.

6. How long do we keep your information?

In short: We retain your information only as long as necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is required by law.

We retain personal information for as long as it is needed for the purposes described herein, or as required by applicable law (e.g., tax or accounting obligations). Once there is no legitimate business need to maintain your personal information, we will delete or anonymize it.

7. How do we keep your information safe?

In short: We aim to protect your personal information through a combination of organizational and technical security measures.

We have implemented measures designed to secure your personal information. However, no transmission over the Internet or storage technology can be completely secure, so we cannot guarantee absolute security.

8. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to individuals under 18. If we become aware that we have collected information from a child under 18, we will take steps to delete such data.

9. What are your privacy rights?

In short: Depending on your location, you may have rights to access, correct, or delete your personal information.

In regions such as the EEA, UK, and Canada, you have rights to request access to, correct, or delete your personal data, restrict its processing, and in some cases, data portability. You may exercise these rights by contacting us.

10. Controls for do-not-track features

Most browsers and mobile operating systems offer a Do-Not-Track (DNT) feature. Currently, no uniform standard for DNT exists, so we do not respond to DNT signals.

11. Do California residents have specific rights?

In short: Yes, California residents are granted specific rights regarding their personal information under the CCPA and CPRA.

If you are a California resident, you may request information about the categories of personal information we have disclosed for direct marketing purposes. To make such a request, please contact us in writing using the details provided below.

12. Do we make updates to this notice?

We may update this privacy notice from time to time. The updated version will be indicated by a new “Last updated” date and will be effective as soon as it is published. If we make material changes, we may notify you by posting a prominent notice or by sending you a direct notification.

13. How can you contact us about this notice?

If you have any questions or concerns about this notice, please contact us at support@milnerva.com or by mail at:

Milnerva LLC
5900 Balcones Drive, STE 100
Austin, TX 78731
United States

14. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to, correct, or delete your personal information. To do so, please submit your request by emailing us at support@milnerva.com.