At, we respect your privacy,
and we understand the importance of the information you entrust to us. This
Privacy Policy describes our practices concerning the information collected by
Mileup Solutions Ltd (“”, “we”, “us”, “our”)
through the use of (i) our website (the “Website”) and
(ii) our mobile applications (collectively, the

This Privacy Policy applies to all personal
information we collect or process about you. Personal information is
information, or a combination of pieces of information, that could reasonably
allow you to be identified.

Below we describe what information we collect when
you use our Services, how we protect that information, how long we retain it,
with whom we share it, and what your privacy options are. By using the
Services, you consent to our collection and use of your information as
described in this Privacy Policy. The Privacy Policy is incorporated by
reference into and is made a part of the Terms of Service.

We will continue to evaluate this Privacy Policy against
new technologies, business practices, and our users’ needs, and may make
changes to the Privacy Policy accordingly. Please check this page periodically
for updates. If we make any material changes to this Privacy Policy, we will
post the updated Privacy Policy here, along with its effective date, and for
material changes will notify you by email or by means of a notice on our
Website. Your continued use of the Services after our posting of changes to
this Privacy Policy means that you agree to be bound by such changes.

Information We Collect About You

We collect personal information about you from a
variety of sources, including from you directly (e.g. when you contact us or
sign up for an account), information we generate about you in the course of our
relationship with you (e.g. data collected from cookies and other similar
technologies which is described in our Cookie Policy, and information we
collect about you from other sources, including commercially available sources,
such as public databases (where permitted by law).

Information You Provide To Us:

You may provide personal information to us, if you
choose to:

Submit a help request, a customer services inquiry
or other inquiry to us, or fill in any other forms for the purposes of
receiving our Services;

Participate in some of the features accessible via
the Services (for example, message boards, games, surveys, polls, promotions,
contests, sweepstakes or other incentives);

Participate in any Services that require

Enroll in any of our Webinars and/or Courses;

Sign up to receive any information and/or services
from any third party provider or partner using our Website (If you submit
information to a third party provider or partner, please note that their use
and disclosure of your information is subject to their own privacy policy);

Contact us about employment opportunities;

Otherwise use the Services in a manner that you
have requested.

Depending on which of these or any other Services
you use, the personal information you provide may include:

Personal details (e.g. name, date of birth,
professional title, company name, and household income, investment interests,
retirement information, information about your educational background );

Contact details (e.g. phone number, email address,
postal address, or mobile number);

Account details (e.g. user name and password);

Transaction details (e.g. when you make a purchase
or respond to offers);

Communications (e.g. when you participate or post
material in message boards or forums, participate in polls or surveys, write a
review or provide a testimonial, or contact us with a question, comment, or
request); or

Professional information (e.g. if you are a
Financial Advisor participating in our Advisor Insights program, information
about your credentials, including, without limitation, broker CRD number,
professional website URL, biographical information, licenses and designations,
and profile picture).

Please be aware, that by posting information to
message boards, chat groups or social networking facilities available via the
Services, you will be making this information available to other users of these
Services to the public. You should be careful about revealing any sensitive
details about yourself.

If you purchase Courses through the
Academy, please note that we do not currently collect or retain credit card
numbers internally. We partner with third party payment providers. All direct
payment gateways are required to adhere to the standards set by PCI-DSS as
managed by the PCI Security Standards Council, which is a joint effort of
brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements
are intended to promote the secure handling of credit card information.

Email Referral:

We also have features that allow you to send an
email to yourself and/or others about an item on our site. If you choose to use
our email referral service, you will be required to provide the e-mail address
or addresses that will be used in the notification. Upon form submission an
email will be generated to your recipient(s) inviting them to visit the URL you
have recommended. We do not store this information other than for the sole
purpose of sending this one-time e-mail.

Information Collected Via Automated Technologies
and Interactions:

When you use the Services, we may automatically
collect information via automatic means about your computer or device, your preference
settings, your location, and your activities, including:

IP address of your computer;

Unique mobile device identifiers;

Technical information about your computer or mobile
device such as type of device, mobile device ID number, screen resolution, web
browser information, and operating system or platform;

Your preferences and settings (time zone, language,

Internet provider or mobile carrier name;

The URL of the last webpage you visited before
visiting the Website;

Information about your activity on the Services
(e.g., your search queries, mis-formatted DNS entries, search results selected,
clicks, pages viewed, search history, comments, forms filled out and submitted,
how often you use the Services);

Information we generate as a result of your use of
the Services (e.g. our understanding of your interests as a result of your use
of the Services and whether you are a regular or occasional user of the
Services); and

If you are using a mobile device, your mobile
device’s geographic location (specific geographic location if you’ve enabled
collection of that information, or general geographic location automatically).
Please see the section “Mobile Device Location Information” below for further

Third Parties

Third-parties who provide us with products and
services may also place cookies, ad tags and/or beacons that collect the
information outlined above in order to provide us with products and services

Analytics tools (e.g., Google Analytics) allowing
us to analyze the performance of our Services.

Service features and functionalities such as those
that enable videos to be played and you to connect to your social media

Advertisers and ad networks allowing the delivery
of targeted advertisements.

These third parties may also collect information
about you from other sources and combine it with other information collected
about you from third party websites not affiliated with us. For example,
advertiser and advertising networks, as well as data analytics companies who
service them, may participate in online behavioral advertising and track your
activity across various sites and/or devices where they display ads and record
your activities, so they can show ads that they consider relevant to you.

Do Not Track: Do Not Track (“DNT”) is an optional browser
setting that allows you to express your preferences regarding tracking by
advertisers and other third-parties. DNT is a way for users to inform websites
and services that they do not want certain information about their webpage
visits collected over time and across websites or online services.

We are committed to providing you with meaningful
choices about the information collected on our website for third party
purposes, and that is why we provide the Network Advertising Initiative and the
Digital Advertising Alliance opt-out links above. However, we do not recognize
or respond to browser-initiated DNT signals, as the Internet industry is
currently still working toward defining exactly what DNT means, what it means
to comply with DNT, and a common approach to responding to DNT. However, our
Cookie Policy provides information and opt-out links to help you control the
collection of information about you on our Website.

These third parties may also provide us with
information about your interactions with their products and services and/or
activities on third party websites. For example, use of Service functions that
connect to your social media account (e.g., Facebook Connect) may permit us
access to your social network profile information, including your first name,
last name, gender, birth date and email address, in accordance with your
settings on the social network. If you choose to post information to your
social media account via the Services, you will be making this information
available to other users of these Services. We encourage you to be careful
about revealing any sensitive details about yourself via our Services or

How We Use Your Personal Information and the Basis
on Which We Use It

We may use the information we collect from and
about you for the following purposes:

Identification and authentication: We use your identification information to verify
your identity and/or eligibility for our Services when you access and use our
Services and to ensure the security of your personal information. This is so we
can comply with our obligations to you.

Improving our Services: We analyze information about how you use our
Services to provide an improved experience for our customers, including product
testing, site analytics, and personalizing content to your interests. It is in
our legitimate business interests to use the information provided to us for
this purpose, so we can understand any issues with our Services and improve

Understanding our users: We also analyze information about our users in
order to understand our users (their demographics, what you do on our Services,
what features you like, how they use them etc.). It is in our legitimate
business interests to use the information provided to us for this purpose, so
we can understand our users and improve our Services.

Operating the Services: We process your personal information to
administer our Services, diagnose technical problems, provide customer support,
complete your transactions, and otherwise manage our business. This is so that
we can comply with our contractual obligations to you.

Communicating with you: We may use your personal information when we
communicate with you, for example if we are sending you communications that you
have requested, communications which relate to Services you have purchased or
enrolled in, which may be of interest to you in accordance with your
preferences, if we are providing information about changes to the terms and
conditions, if you contact us with questions, or to provide you with customer
support. It is in our legitimate interests that we are able to provide you with
appropriate information, responses and provide you with notices about our
Services. Please see the section “Reviewing, changing or deleting information”
for further information about how you can control these communications.

Marketing: We may use your personal information to build a profile about you and
place you into particular marketing segments in order to understand your
preferences better and to appropriately personalize the marketing messages we
send to you. It is in our legitimate interest to provide you with more relevant
and interesting advertising messages, and inform our marketing strategy. We may
use automated decision-making to deliver tailored advertisements based on your
personal information. Where necessary, we will obtain your consent before
sending such marketing messages.

Exercising our rights: We may use your personal information to exercise
our legal rights where it is necessary to do so, for example to detect,
prevent, and respond to fraud claims, intellectual property infringement claims
or violations of law or our Terms of Use.

Complying with our obligations: We may process your personal information in order
to, for example, carry out fraud prevention checks or comply with other legal
or regulatory requirements, where this is explicitly required by law.

Customizing your experience: When you use the Services, we may use your
personal information to improve your experience of the Services, such as by
providing interactive or personalized elements on the Services and providing
you with content based on your interests. We may use automated decision-making
to customize your experience based on your personal information.

Compensating our partners: We may process your personal information for
purposes of calculating compensation to be paid to our third party
product/service providers and distributors and to analyze usage across
products, services and distribution partner/channel. It is in our legitimate
interest to appropriately determine amounts to be paid to our partners and
inform our product roadmap and distribution strategy.

In Connection with Webinars and Courses: In addition to the uses described above, if you
are enrolled in and/or take any of our Webinars and/or Courses, we may use the
registration information you provide, including personally identifiable
information, to use through your Account for managing and processing purposes,
including but not limited to tracking attendance, progress and completion of
Course and/or Webinar. As part of our management and processing of each Course
and/or Webinar, we may use this information to proctor exams, projects, and
other assessments for each Course and/or Webinar. For example, as part of a
Webinar that provides CE credits, we will use certain information collected
from you in order to verify your identity, or to monitor your performance
during the exam to confirm that you are abiding by the rules or requirements
for obtaining CE credits. We may share such information that we collect from
you when you participate in a Course with the company (if any) and/or
lecturer(s) who provided, taught, managed, sponsored, or otherwise oversaw that
Webinar or Course, and, where applicable, you will be subject to such third
party’s privacy policies; and (ii) that third party may use the personally
identifiable information you provide for its own marketing purposes.

How We Share the Information We Collect

We will not share the personal information we
collect about you with any third party except as indicated below or when we
inform you and give you an opportunity to opt out of having your personal
information shared.

We reserve the right to share your information with
third party service providers. This includes Online Trading Brokerages whom we
have affiliate agreements with. Any contract they have with you thereafter is
on their own accord and has no connection to We are not
responsible for any activity that was done by you on the third party website
and any correspondence between you and third party websites is at your own risk
and is not connected to in any which way manner or form.

We will share your information in the following

Our suppliers, subcontractors and business partners: (“service providers”): We may share your data
with our services providers and business partners who perform marketing
services and other business operations for us for the purposes set forth above.
For example, we may partner with companies to process secure payments, fulfill
orders, optimize services, serve online behavioral advertising, send
newsletters and marketing messages, support email and messaging services, and
analyze information. These service providers are required to treat the data in
accordance with confidentiality requirements.

Business Affiliates: Once registered with our website as a client
you agree to your basic information to be shared with affiliate websites we
work with. You agree to be contacted by them and offered third party services.

Service requests: We enable you to request information and/or
services from third party service providers or partners by filling out a
registration, information request, or similar service request form for specific
services from them (e.g., filling in a sponsored partner’s form to identify
your retirement risk profile and/or submitting a request with such information
for more information from that partner or another party). When you fill out and
submit a service request form through our Website, you consent to our providing
your personal information and request to the third party provider and/or
partner. Sharing this information with the party provider and/or partner allows
them to contact you using the contact information you provided. Additionally,
we have other contractual partners that that utilize their own service provider
to supplement our offering, and we share your information with them in order to
attempt to provide the services requested.

Webinars/Courses: We may share certain information with third
parties that enable us to provide you the Webinars and/or Courses. For example,
but not as a limitation, our Webinar and Course platforms may be hosted by
third parties who will use your information to allow you to access the Webinar
and/or Course. We also use third party payment providers who will use your
information to process payment, subject to their own privacy policies.
Additionally, for any continuing education eligible Webinar, we will share
information provided to us as well as information regarding your completion of
such Webinar with the organization issuing continuing education certificates,
including without limitation, for the purpose of verifying your eligibility for
the continuing education credits. We may also use third party customer service
platform providers in order to help us provide customer service capabilities in
connection with your use of one or more of our Services, including without
limitation the Webinars and/or Courses.

Group Companies: We may share your information with our
affiliates, which are entities under common ownership or control of our
ultimate parent company, IAC/InterActiveCorp for marketing purposes, security,
optimization of products and services, and internal reporting. We do this for
the purposes set out above.

Where required by law: We may disclose your information with law
enforcement agencies, courts, other government authorities, or other third
parties when we believe in good faith that such disclosure is appropriate in
order to investigate, prevent, or take action regarding possible illegal
activities, suspected fraud, situations involving potential threats to the
physical safety of any person, violations of this Privacy Policy or the Terms
of Service for the Services you accessed, and/or to protect the rights and
property of, our employees, users and the public, or to
comply with a legal or regulatory obligations. This may involve the sharing of
your information with law enforcement, government agencies, courts, and/or other

In the context of a transaction: we may share your personal information with
potential transaction partners, service providers, advisors and other third
parties in connection with the consideration, negotiations, or completion of a
corporate transaction in which we are acquired by or merged with another
company or we sell or transfer or all or a portion of our assets or business.

Advertisers and advertising networks: Advertisers and advertising networks place ads on
our Website. These companies may collect information, such as your computer’s
IP address, browser information, and mobile device ID as you use our Website
and Services. These companies, as well as data analytics companies who service
them, may also use cookies, pixel tags, mobile device advertising IDs and other
similar technologies to collect this information when you visit our Website
(for example, web pages visited), as described in our Cookie Policy.  They
use the data to enable them to track your activity across various sites where
they display ads and record your activities, so they can show ads that they
consider relevant to you. We neither have access to, nor does this Privacy
Policy govern, the use of cookies or other tracking technologies that may be
placed on your computer, mobile phone, or other device you use to access the
Services by non-affiliated, third-party ad technology, ad servers, ad networks
or any other non-affiliated third parties.

In cases of onward transfer to third parties of
data of EU or Swiss individuals received
to the EU-US or the Swiss-US Privacy Shield, is
potentially liable.

Yous Rights and Your Privacy Choices 

You have certain rights regarding the personal
information we hold about you, subject to local law. These may include the
rights to access, correct, delete, restrict, or object to our use of, or
receive a portable copy in usable electronic format of your personal
information. You may also have a right to lodge a complaint with your local
data protection or privacy regulator.

You also have choices when it comes to the privacy
practices described in this Privacy Policy. A few of those choices are set
forth below and others are available in our Cookie Policy.

Choices relating to information we collect: We may be required by law to collect certain
personal information about you or as a consequence of any contractual
relationship we have with you. Failure to provide this information may prevent
us from providing certain Services or all of the Services to you.

Automated Decisions about You

When you use the Services, we may make automated
decisions about you based on your personal information in the following circumstances:

To deliver personalized offers, discounts, or
recommendations based on your shopping history, viewing history, and browsing
history, and

To serve you with ads based on various factors such
as the content of the page you are visiting, information you provide such as
your age or gender, your searches, demographic data, user-generated content and
other information that you provide to us. These ads may be based on your
current activity or your activity over time and may be tailored to your

Right to Access, Review, Change or Delete

To access, review, change or delete personal
information we have collected from you, please visit our Privacy Center page
and send a message to our Support team. To make changes to your account, you
may also login to your account and visit the Manage
Profile page.

Your specific rights regarding access, review,
revision, or deletion of your information is dictated by local laws.

Legal rights applicable to personal data collected
in the EEA
. Pursuant to
the EU General Data Protection Regulation (Regulation
 natural persons (called data subjects) are afforded
certain rights regarding their personal data, including the right access,
correct, delete, restrict or object to our use of, and receive a portable copy
in a usable electronic format of your personal information. You also have the
right withdraw any consent that you have previously provided to us and to lodge
a complaint with your local data protection or privacy regulator.

If you would like to exercise any of the rights
outlined above, and the law of your jurisdiction requires us to honor that request,
please send your request in writing to the address in the “Contact Us” section
below. To assist us in processing your request in timely manner, please make
your request in English if you are able to do so. Your request should include
any information relevant to your request, including, without limitation: (i)
your name, email and postal address; (ii) the specific right you are asserting
(e.g., removal); and (iii) if you are requesting removal, a brief explanation
of why you believe such information should be removed.

To help us prevent fraudulent removal requests,
please also include a legible copy of a document that verifies your identity.
You need not provide a government-issued document; a utility bill or similar
mailing will suffice. You may also obscure parts of the document such as
identifying numbers so long as the document continues to clearly identify you.
If you are making the request on behalf of another person, please indicate your
relationship to that person and provide evidence of your authority to make such
request. All requests for removal will be reviewed by’s
legal and compliance team and we reserve the right, in compliance with
applicable laws, to accept or reject, or make further inquiries regarding, any

You will not have to pay a fee to access your
personal data (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these

We try to respond to all legitimate requests within
one month. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.

How We Protect Your Information

We take the security of your information seriously,
and use appropriate technical and organizational measures to protect your
information against unauthorized or unlawful processing and against accidental
loss, destruction or damage. We also limit access to information about you t
employees who reasonably need access to it to provide products and services to
you, or in order to do their jobs. However, because no security can be 100%
effective, we cannot completely guarantee the security of any information we
have collected from you.

Retention of Your Information

We retain the information we collect about and from
you for as long as necessary to fulfill the purpose we collected it for and for
the purpose of satisfying any legal, accounting, or reporting requirements. To
determine the appropriate retention period for personal information we process,
we consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorized use or disclosure of your information,
the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, accounting, or
reporting requirements. In some circumstances we may choose to aggregate and
de-identify you information in such a way that you may not reasonably be
re-identified by us or any other company in which case we may use this
information indefinitely without further notice to you.

In some circumstances you can ask us to delete your
date: see Right to Access, Review, Change or Delete Your Information.

Linked Sites and Advertisements

The Services may contain links to third-party
websites. We are not responsible for the privacy practices or the content of
those third-party websites. We have relationships with third-party providers to
provide content, products, services, and functionality through the Services.
Such providers may collect information from you directly, in which case the
provider’s privacy policy (which may differ from this Privacy Policy) would
apply. If you have any questions regarding the privacy policy of any of our
providers, you should contact the provider directly for more information.


Cookie Policy

We use cookies, pixel tags, web beacons, mobile
device IDs and similar files or technologies to collect and store the
information we automatically collect about your computer, device, and Service
usage. We use the term “cookies” in this policy to refer to cookies and all
such similar technologies that collect information automatically when you are
using our Services.

If you do not accept the use of these cookies, please
disable them using the instructions in this cookie policy.

In this Cookies Policy, we use the term
(and “we”, “us” and “our”) to refer Mileup Solutions Ltd.

What is a cookie?

Cookies are text files containing small amounts of
information which are downloaded to your computer or mobile device when you
visit a website. Cookies are then sent back to the originating website on each
subsequent visit, or to another website that recognizes that cookie. Cookies
are widely used in order to make websites work, or to work more efficiently, as
well as to provide information to the owners of the site

Cookies do lots of different jobs, like letting you
navigate between pages efficiently, remembering your preferences, and generally
improving the user experience. Cookies may tell us, for example, whether you
have visited our Services before or whether you are a new visitor. They can
also help to ensure that adverts you see online are more relevant to you and
your interests.

There are two broad categories of cookies:

First party cookies, served directly by us to your computer or mobile

Third party cookies, which are served by a third party on our behalf.
We use third party cookies for functionality, performance / analytics,
advertising and social media purposes.

Cookies can remain on your computer or mobile
device for different periods of time. Some cookies are ‘session cookies’,
meaning that they exist only while your browser is open. These are deleted
automatically once you close your browser. Other cookies are ‘permanent
cookies’, meaning that they survive after your browser is closed. They can be
used by websites to recognize your computer when you open your browser and
browse the Internet again.