MCS Communications Consulting Co. (“MCS”) respects your privacy. In addition to providing numerous privacy features, MCS has created this Privacy Policy in order to demonstrate in writing our firm commitment to privacy. In particular, this Privacy Policy describes our privacy practices with regard to information about you that could reasonably be used to identify you personally or that is associated with information that identifies you (“Personal Information”).

Please take a moment to review the terms of this Privacy Policy. Please also review the Terms and Conditions, which govern your use of the MileagePlus Golf Website (the “Site”). Please note that certain features or services discussed in this Privacy Policy may not be offered on the Site at any particular time.

Scope of this Policy

This policy applies to the Site and any related sites operated by MCS that post a link to this Privacy Policy (collectively “the Sites”). It is MCS’ policy to comply with data protection legislation. This regulates the processing of information relating to you and grants you various rights in respect of your personal data. The Sites contain links to or permits you to order goods or services from other websites or third parties over which we have no control. MCS is not responsible for the privacy policies, content or practices of these third parties or other websites to which you choose to link from the Sites. We encourage you to review the privacy policies of those other websites and third parties so you can understand how they collect, use and share your information.

Type of Information We Collect

MCS collects information about you when you access the Site through the United MileagePlus API login. When you login into the Sites by using your United MileagePlus User ID and password, you authorize us to have access to and store certain information from your United MileagePlus account profile to allow you to efficiently utilize the Site and the services offered therein.

We collect the following general types of information about you when you visit our Sites: Personal Information, demographic information, behavioral information and indirect information. Sometimes we collect combinations of all these types of information. In each case, it is indicated on the Sites whether any personal or demographic data must be provided to use the requested service or not.

Personal Information is information that can be used to identify you, or any other individual to whom the information may relate, personally. We do not collect Personal Information unless you choose to log into the Site or otherwise provide it to us. Some examples of Personal Information that we collect in some areas of our Site, depending on the services you use and local law, are: your name; address; e-mail address; telephone number; credit card number; contact information; and billing information.

Demographic information is information that is not unique to you in the sense that it refers to selected population characteristics, such as your ZIP code or postal code, age, preferences, gender, race or ethnicity, occupation, interests and favorites.

MCS also collects, or logs, certain other information that cannot identify you personally when you visit our Sites. This information includes your Internet Protocol (“IP”) address and your domain name. An IP address is a number that is automatically assigned to your computer by the ISP computer through which you access the web and a domain name is the name of the ISP computer itself through which you access the web. MCS logs these IP addresses and domain names and aggregates them for system administration and to monitor the use of our Sites. We use the aggregated information to measure the number of visits to our Sites, the average time spent on our Sites, the number of pages viewed, and various other site use statistics. This monitoring helps us evaluate how our Sites are used and continuously improve the content we provide.

How Information is Used

Personal Information may be disclosed to trusted persons working together with MCS if they are involved in the completion, delivery or customer support of your order of goods and/or services offered through the Sites. Examples include third parties who are providing the goods and/or services offered through the Sites, assist in hosting our web servers, analyzing data, providing marketing assistance, processing credit card or other forms of payments, and providing customer service. We also may share aggregated anonymous information about visitors to the Sites with third parties so that they can understand the kinds of visitors to the Sites and how those visitors use the Sites.

By logging into the Sites, or expressly opting in when presented with choices, you have consented for us to use your information, subject to local law, in at least the following ways: to create a profile for you based on information that you have provided to us; to contact you about any Sites’ updates, informational and service-related communications, including important security updates; to provide you additional communications, information, and promotions via email or SMS correspondence; to inform you of other products or services available from MCS or its affiliates; to facilitate communications between you and vendors or other third parties concerning their offers, goods or services offered on or in connection with the Sites; to provide the services requested by you; to enable you to provide feedback, to contact us and for us to respond to you; to generate internal reports about the use of our Sites; and to provide information to United about your purchases and profile information for recordkeeping, marketing and data analytics in connection with its MileagePlus program and in accordance with United’s privacy policy. United may combine any data or information it receives with other data or information maintained or received by United.

If you choose to purchase any goods or services, or request any services, through the Sites, we may share such information with vendors and other third parties that offer or provide such goods or services, or that are used in connection with the provision of any such services or the sale of such goods or services.

We may also share your information to carefully-selected third parties, if you consent to such disclosure, so that they may inform you of offers, promotions and services.

We disclose information if legally required to do so or if requested to do so by a governmental entity. Because MCS is a US company and information collected on our Sites is stored in whole or in part in the United States, your information will be transferred to the United States and become subject to U.S. law. By using the Sites, you consent to this transfer.

We may disclose such information in connection with the collection of any debts owed by you to MCS or any vendors or other merchants associated with the Sites.

We may disclose and transfer such information to a third party who acquires all or a substantial portion of MCS’ business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event MCS becomes the subject of an insolvency proceeding, whether voluntary or involuntary, MCS or its liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court.

In each of these situations, the recipients of your data may potentially be located in countries whose data protection legislation is different from your country. If you are a resident in any EU member state, for example, you must be aware that the EU authorities do not generally consider that the regulations of non-EU countries ensure an adequate or equivalent level of protection as compared to the EU data protection regulations.

Posting Your Information to Public Areas of the Sites

We do not display Personal Information without your permission. However, if you post any of your Personal Information in public areas of the Sites, such as in product or service reviews, online forums or chat rooms, such information may be collected and used by others over whom MCS has no control. We cannot control the use made by third parties of information you post or otherwise make available in public areas of MCS.

Changes/Modifications

Changes to your MileagePlus account may be done through United.com. You may have access to, review, correct, update, change or delete your account profile information with MCS at any time. Before providing you with a copy of your Personal Information or correcting, updating or deleting such information, we reserve the right to verify and authenticate your identity and the Personal Information to which you have requested access.

Please note that in accordance with our routine corporate record keeping practices, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.

If you delete or close your account or account profile information with MCS altogether, MCS may retain an archival copy which is not accessible by you or third parties on the Internet. The archival copy is retained only for as long as MCS reasonably considers necessary for audit and record purposes. We will retain logs, demographic, indirect, and statistical information about you and keep an archival copy of this information in an anonymous form. If your Personal Information was previously accessed by others using our Sites, we are not able to delete the information or copies thereof from their systems.

Other Important Information

Security

You are responsible for ensuring that your log-in credentials (your User ID and password) are kept confidential. MCS has implemented technical and organizational measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure. Notwithstanding such measures, the Internet is an open system and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your Personal Information for improper purposes. Please consider this prior to submitting your Personal Information to us via the Sites.

We also use cookies and web beacons to administer our Sites and deliver a personalized experience. For additional detailed information on each of these, please see below.

Children’s Privacy

 

The Sites are not intended for children under 13, and Personal Information from children under 13 will not knowingly be collected. Children’s privacy is a serious matter and parents are encouraged to play an active role in their children’s online experience at all times.

Use of Cookies, Web Beacons, and Java Script

*Cookies: MCS uses “cookies” to help personalize and maximize your online experience and time online. A cookie is a text file that is either stored in your computer’s memory temporarily or placed on your hard drive by a Web page server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you.

When you return to the Sites, cookies enable us to retrieve the information you previously provided, so you can easily use the features that you customized. Because of our use of cookies, we can deliver faster and more accurate results and a more personalized site experience. For example, a cookie helps us to recall your specific information (such as User ID, password and preferences).

Most cookies expire after a defined period of time or you can delete cookie files stored on your computer any time. While most Web browsers are initially set up to accept cookies, you can reset your Web browser to refuse cookies or to indicate when a cookie is being set. However, if you choose to decline cookies, that may hinder performance and negatively impact your experience on the Sites. For example, without cookies, you will not be able to set personal preferences and may have difficulty completing financial transactions.

We may also allow other companies to display advertisements to you while you are visiting our Sites. Because your Web browser must request these advertisements from the other companies’ servers, these companies can view, edit or set their own cookies, just as if you had requested a webpage from their site. MCS has no control over, and is not responsible for, the practices of those third party advertisers and encourages you to review the policies of such advertisers.

We may allow third party cookies as part of online advertising campaigns to determine and track site traffic landing from MCS’ advertising banners that have been placed on the websites of third parties. The data collected via these cookies is anonymous and the information is not linked to your personally identifiable information without your permission.

*Web Beacons: MCS’ Sites may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that allow us to count users who have visited those web pages and to deliver co-branded services. Web beacons are not used to access your Personal Information; they are a technique we use to compile aggregated statistics about our Sites’ usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. Because Web beacons are the same as any other content request included in the recipe page, you cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.

Opting Out

MCS provides users the opportunity to opt-out of or discontinue receiving communications from MCS that are unrelated to your transactions on the Sites. If you do not desire to continue receiving such communications from MCS, please send your request to opt out of MCS at support@mileageplusgolf.com. It may be necessary to contact affiliates, business partners or other third parties directly in order to cease receiving communications from those third parties.

Your California Rights

We do not share Personal Information with third parties for their direct marketing purposes unless you affirmatively agree to, or opt in to, such disclosure. California customers may request further information about our compliance with California laws by e-mailing us at support@mileageplusgolf.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.

Third Party Interaction

As a user of the Sites, you may interact with, purchase goods and/or services, or participate in promotions of advertisers, members, partners, or sponsors showing their goods and/or services on the Sites. Unless otherwise stated, any such interaction, purchase or promotion, including the delivery of and the payment for goods and/or services, and any other term, condition, warranty or representation associated with such correspondence, purchase or promotion, is solely between you and the applicable third party. You agree that MCS, its subsidiaries, affiliates, officers, agents, co-branders or other partners, and employees have no liability, obligation or responsibility for any such interaction, purchase or promotion between you and any such third party.

Changes to the Privacy Policy

MCS reserves the right to modify or amend this Privacy Policy at any time and for any reason. MCS will notify you about any significant changes by providing a prominent notice on the Sites. The changes will be effective as of posting on the Sites. Your continued use of the Sites following the posting of changes indicates your acceptance of these changes.