Protecting your privacy is important to Minion Made LLC (“Minion Made”)
through the collection, use, retention, and disclosure of Personally Identifiable Information (“Personal Data”, as further described below) that you may provide while using Minion Made websites, apps, and services in connection
understand how we collect and process Personal Data in the course of providing the Services and your interaction with the Services.
Note to Residents of the European Union and California: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European users, and California Consumer Privacy
Personal Data is any information that would identify a person directly, or indirectly in combination with data from other sources. For example, a full name, home or work address, phone number, national identification number (SSN,
SIN, etc.), email address, banking details, IP address, biometric data, usage data, or any information that may individually identify a person.
Minion Made may collect Personal Data including without limitation your name, shipping and billing addresses, phone number, email address, payment information, IP address, and device identifiers and/or geolocation information, in
Minion Made may also create de-identified or anonymized data from Personal Data by excluding data components (such as your name, email address, etc.) that makes the data able to personally identify you, through obfuscation, or
through other means. In addition, Minion Made may collect and use aggregated, anonymous information to provide data about the Services to advertisers, potential business partners and other unaffiliated entities. As this information
Consent and Collection of Personal Data
If you use a Minion Made website, or conduct a transaction through a Minion Made Service where Personal Data is essential, your consent is implied to collect and use your Personal Data to facilitate that use or complete that
transaction requested or initiated by you only. Examples of instances in which Personal Data may be collected by Minion Made are, without limitation:
- When you install a Minion Made App,
- If you make or return a purchase through a merchant who uses a Minion Made App,
- When you access and navigate a Minion Made website, or engage in communication and/or business transactions with Minion Made Professional Services, Managed Services, Client Success, or any other Minion Made entity,
- If you knowingly submit Personal Data through a Minion Made website for the purpose of registering for a service, a contest, or authentication.
During these instances, we may collect data such as, but not restricted to: areas of the Services or Minion Made websites you visit, transaction type(s) you engage in or request (and amounts thereof), content you view, your IP
address, data downloaded or submitted by you, payment information provided by you, shipping and billing information entered by you, as well as the nature, quantity and price of the goods or services you exchange and the individuals
or entities with whom you communicate or transact business using the Services.
In the event Minion Made requests Personal Data for scenarios independent of the above, such as marketing-related questions via questionnaires, surveys, and profile data, it will include a specific consent request. The consent
request will include a clear purpose and goal for the collection of Personal Data, along with a means of withdrawing consent. In these scenarios, we may ask for data such as, but not limited to: your contact information (name,
telephone numbers, email address, mailing address), date of birth, product and/or cosmetic concerns, which brands and products you use, user authentication and security information (e.g. username and password).
be offered or provided to you if you disclose the Personal Data necessary to facilitate those Services, and therefore Minion Made may not be able to provide you with certain Services in the event that you choose not to disclose
that Personal Data to Minion Made.
Age of Consent
The Services offered by Minion Made are directed towards and designed for the use of persons above the age of majority in your province, state, or country. Persons under the age of majority are not permitted to use the Services on
their own, and Minion Made will not approve applications of, or establish, or maintain accounts or memberships for, any persons below their respective region’s age of majority.
Minion Made does not solicit or knowingly collect Personal Data from persons below the age of majority of their region. If we discover we have received Personal Data of a person below the age of majority, we will delete such
information from our systems. Additionally, if a parent or legal guardian believes that Personal Data regarding a minor in their care has been provided to Minion Made, they may request the minor’s information be corrected or
When you interact with a Minion Made Service, similar to most other websites, apps, and online services, certain anonymous technical information about your visit is automatically logged and collected by Minion Made. This may
include information about the type of browser you use, operating system, the date and time you access the Service, the links you accessed while using the Service, and the internet address of the website, if any, which linked
directly to the Minion Made Service. This information is used for system administration purposes such as diagnosing problems with Minion Made’s Services, servers and websites, compiling aggregated and statistical information, and
Personal Data Use
Minion Made may use collected Personal Data for such purposes as:
- Helping to establish and verify the identity of users, and to keep user accounts secure,
- Opening, maintaining, administering and servicing users’ accounts or memberships,
- Providing Services and support to users,
- Improving Minion Made’s websites, including tailoring its websites to users’ preferences,
- Providing users with product or Service updates, promotional notices and offers, and other information about Minion Made and its affiliates,
- Corresponding with you, and responding to your questions, inquiries, comments, and instructions,
- Maintaining the security and integrity of Minion Made systems, and,
- Complying with applicable laws.
Once collected, Minion Made will store and process your Personal Data in secure locations. Minion Made may transmit data outside of Canada for the purposes of processing and executing transactions related to the Services, or for
the purpose of executing transactions on behalf of merchants that have installed and make use of Minion Made Apps in connection with their online stores. Where this transmission occurs, the security measures outlined in this
Personal Data will only be retained by Minion Made for the length of time required to fulfill the purpose or complete the transaction for which it was collected, or as may be required by law. Beyond that point, Personal Data in
the possession or control of Minion Made will be anonymized or securely destroyed.
Legal Basis for Processing
This section addresses the legal basis for processing your Personal Data if you reside outside of Canada and in the European Economic Area (within Canada, you typically provide consent when you receive notice of this Privacy
Policy in (or via) a website link or mobile app).
Lawful Basis for Processing
Data protection law in the European Union requires a “lawful basis” for collecting and retaining Personal Data from citizens or residents of the European Economic Area. Minion Made collects and processes your Personal Data for a
- For the performance of a contract: To perform our contractual obligations to you, including account registration, fulfilling orders or purchases you have made (including processing of payment), contacting you in relation to any
issues with your order, in relation to the provision of the Services, where Minion Made needs to provide your Personal Data to our service providers to provide the Services, or to aggregate and centralize data for the performance
of the Services.
- To meet legal obligations: To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.
- For legitimate interests: To operate Minion Made’s business and provide the Services, other than in performing our contractual obligations to you, except where overridden by the interests or fundamental rights and freedoms that
require protection of Personal Data. For example, the following areas include processing permitted due to legitimate interests:
Made may send strictly necessary communications, including emails, even if you have opted out of receiving other Minion Made emails or communications. These types of communications do not require consent. Minion Made also
processes your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and Minion Made has not asked you for your consent in that regard.
- Respond to Your Requests. To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support
- Promotional Messages. Minion Made processes your non-sensitive Personal Data to provide you with promotional messages, including when you communicate with Minion Made or sign up for promotional materials, when you participate
in special activities, offers, or programs, when we aggregate and centralize data, and when we share Personal Data with our service providers and vendors.
- Surveys. To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given Minion Made your consent to receive marketing from us.
- Compliance with Law and Public Safety. To assist in the investigation of suspected illegal or wrongful activity, including sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and
defend Minion Made’s rights and property, or the rights or safety of third parties.
- Improvement and Development. To develop, provide, enhance, and improve Minion Made Services and your experience, including to enable you to use the full range of our Services. For internal purposes related to certain research,
analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
- Merger or Acquisition (Note that certain country/region-specific disclosures may also apply, depending upon the jurisdiction in which you reside). To support a contemplated reorganization or an actual reorganization of Minion
Made’s business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to
proceed with a transaction.
Consent as a Basis for Processing
In some cases, Minion Made will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as may be presented by Minion Made and permitted by law, ticking a box (or
equivalent action) to indicate your consent when providing us with your Personal Data through our Services or a form, or registering or creating an account with us. Note that certain country/region-specific rules regarding consent
may also apply, depending upon the jurisdiction in which you reside.
Minion Made maintains reasonable physical, technical, and administrative security measures to minimize the risk of unauthorized loss, theft, copying, misuse, access, disclosure, alteration, or destruction of your Personal Data.
If transactions are offered as part of a Minion Made Service, transaction information is transmitted to and from Minion Made in encrypted form using industry-standard Secure Socket Layer (SSL) connections to help protect such
information, including Personal Data transmitted in the course of these transactions, from interception.
Minion Made also restricts access to your Personal Information to only those persons who have a legitimate business need or legal requirement to view it in connection with the Services. You, as a Personal Data owner, may also
authorize any persons you may choose to have access to your Personal Data.
Although Minion Made does utilize security measures appropriate to the level of risk, no method of data transfer or storage on the internet is 100% secure and security risks cannot be eliminated entirely. As such, Minion Made
cannot guarantee perfect security, integrity, or confidentiality of Personal Data.
Minion Made maintains a security incident response protocol to be put in place in the event that the security of your Personal Data in the possession or control of Minion Made is compromised. In the event of a data breach or
security incident involving the Services, Minion Made will apply this protocol to enable Minion Made to effectively and efficiently respond to, and contain, the breach or incident. Minion Made may also seek to notify you in such an
event. If notification is appropriate or required, Minion Made may notify you by email, messaging to your device, or other reasonable means.
Disclosure of Personal Data
Minion Made does not provide Personal Data to unaffiliated third parties for their use in marketing directly to you. We may use unaffiliated companies, or trusted third party service providers, to help maintain and operate our
Services for reasons related to our business operations and to better serve you, and those companies may receive your Personal Data for that purpose. For example, Bold may use third party payment processor services in connection
with the Services and its websites, and the payment information that you provide to Minion Made may be disclosed to and used by these payment processors for the purposes of completing and executing transactions requested or
initiated by you. When Minion Made shares Personal Data with third-party services that support our delivery of the Services, we require that they use your Personal Data only for the purposes we’ve authorized, and that they protect
your Personal Data to at least the same standards used by Minion Made.
As part of agreements with merchants who have installed Minion Made Apps and the execution of transactions on behalf of merchants that make use of Minion Made Apps in connection with their online stores, we may disclose Personal
Data which has been collected by us that is specific to that merchant’s store and your transactions in connection therewith.
Minion Made may also disclose Personal Data about you in connection with legal requirements, such as in response to an authorized subpoena, governmental request or investigation, or as otherwise permitted by applicable law
(including, without limitation, to prevent fraud or abuse, or to protect Minion Made’s legal rights, property, or the safety of Minion Made, its employees, users or others).
Finally, as Minion Made’s business develops, it may sell or buy corporate assets, and in such transactions Personal Data may be one of the transferred business assets. If Minion Made, its internet businesses, or substantially all
of its shares or assets, is acquired or an acquisition is contemplated, Personal Data may be one of the assets assessed or transferred in connection with that transaction.
Transfers of Your Personal Data to Other Countries
The Personal Data Minion Made processes, and associated Services and systems, may be housed on servers in various locations where Minion Made maintains servers or facilities, including Canada, the United States, and the EU. Please
be aware that Personal Data we collect may be processed and stored in one or more of these locations. The data protection and privacy laws in these locations may offer a different level of protection than in your country/region,
with the standards of protection required under applicable law.
Where Personal Data is transferred from the European Economic Area to a country that has not received an adequacy decision by the European Commission, Minion Made relies on appropriate safeguards, such as for example the European
Commission-approved Standard Contractual Clauses and EU-U.S. Privacy Shield Frameworks, to transfer the Personal Data.
By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the locations contemplated above. Where and as required, we will seek your explicit consent as
“Cookies” and Advertisers
The Minion Made websites, or the third-party companies used to host, operate, or maintain these websites, may place a “cookie” on your computer in order to allow you to use these websites and to personalize your experience.
A “cookie” is a small piece of data, or an alphanumeric identifier, that can be sent by a web server to your computer or device, which then may be stored by your browser on your computer or device. Cookies allow Minion Made to
recognize your computer or device while you are on our websites and help customize your online experience and make it more convenient for you. Cookies are also useful in allowing more efficient log-in for users, tracking
transaction histories, and preserving information between browsing sessions. The information collected from cookies may also be used to improve website functionality.
users of our websites in order to present “personalized” advertisements or other messages that the user might find interesting. Minion Made is not responsible for any such cookies.
Most web browsers have features that can notify you when you receive a cookie or prevent cookies from being sent. If you disable cookies, however, you may not be able to use certain personalized functions of Minion Made websites.
Rights with Respect to Personal Data
Minion Made is committed to ensuring you retain full access to and control of your Personal Data. To that end, we endeavor to respect your right to be informed regarding the collection, use and disclosure of Personal Data, and
If you would like to access, correct, remove, request a copy of, withdraw consent to collection of your Personal Data, or are looking for any additional information on how your Personal Data may be collected, used or disclosed by
reasonable access to your Personal Data, and will be entitled to have it amended or corrected as appropriate.
In certain circumstances, you may have the right to have your Personal Data, or certain components of your Personal Data, erased by Minion Made, to have your Personal Data moved, copy or transmitted from Minion Made’s systems to
other systems, or to object to or restrict certain processing of your Personal Data by Minion Made. In the event that you wish to inquire about, or seek to exercise any of these rights (as they may be applicable), please contact
European Economic Area and the United Kingdom
Subject to applicable law, if you are a citizen or resident of the European Economic Area or the United Kingdom you have certain statutory rights in relation to your Personal Data. Subject to any
exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this by contacting Minion Made in accordance with the Contact
To the extent that Bold’s processing of your Personal Data is subject to the General Data Protection Regulation, (or applicable laws covering the processing of Personal Data in the United Kingdom), Bold relies on its legitimate
interests, described above, to process your data. Bold may also process other information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Bold’s use of your Personal Data for
this purpose at any time.
If you are a customer of a merchant who uses Bold’s Apps and wish to exercise these rights, please contact the merchants you interacted with directly – we serve as a processor on their behalf, and can only forward your request to
them to allow them to respond.
If you are unhappy with the response that you receive from us, we hope that you would contact us to resolve the issue but you also have the right to lodge a complaint with the relevant data protection authority in your
jurisdiction at any time.
California Privacy Rights
This section provides additional details about California consumers and the rights afforded to them under the California Consumer Privacy Act or (“CCPA”). If you need to access this notice in an alternative format, please contact
us via the method in Contact & Questions section below.
Under CCPA “Personal Information” is defined as anything that identifies, relates to, describes or is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California consumer of
household. For more details about the Personal Information we have collected over the last 12 months, including the categories of sources, please see the Personal Data and Consent and Collection of Personal Data section above. We
collect this information for the business and commercial purposes described in the Personal Data Use section above. We share this information with the categories of third parties described in there. Bold does not sell (as such term
is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we may use third-party cookies for our advertising purposes as further described in our
Cookies and Advertising section above.
The CCPA requires opt-in consent to information use for minors under the age of 16 and verified parental consent for children under the age of 13. We do not knowingly collect or process the information of children.
Subject to certain limitations, the CCPA provides California consumers the right to request, free of charge, to know more details about the categories or specific pieces of personal information we collect (including how we use and
disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at firstname.lastname@example.org. We will verify your request using the information
associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
Minion Made Services may contain links to other websites, apps, or services, including those of advertisers or third-party content providers who offer downloads as part of a Minion Made Service. Minion Made is not responsible for
the privacy practices or the content of other websites, apps, or services. We encourage you to read the Privacy Policies published by such third parties before divulging your Personal Data to them.