MITÚ PRIVACY POLICY

EFFECTIVE DATE: February 21, 2015

The fierce.wearemitu.com website (“Website”) is owned and operated by Mitú, Inc. and publishes lifestyle, news and entertainment content for a Latino millennial audience. The mitú services include: (i) those offered on any mitú-branded URL, including fierce.wearemitu.com; (ii) the mitú mobile services (“Mobile Services”) and (iii) any other features, content, or applications offered or operated from time to time by mitú in connection with the Website, Mobile Services and/or mitú’s business, including, without limitation, when mitú is accessed via the internet, a mobile device, an application, or any other device (“Additional Services”)(the Website, Mobile Services and Additional Services are collectively referred to as “the Services”). This privacy policy (“Privacy Policy”) explains the ways in which your information is collected and used on the Website and via the Services.

By accessing and/or using the Services (whether such use is intended or not), you are accepting the terms and conditions of this Privacy Policy and mitú will have the right to use your personal and other information as described in this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, you must immediately discontinue your access to and use of the Services.

1. SCOPE.

This Privacy Policy covers personally identifiable and non-personally identifiable information collected by mitú when you visit or use the Services. Please note that this Privacy Policy does not apply to third parties, including, without limitation, entities that Mitú does not own or control, such as third party sites that may have a link to or from the Services.

2. NO INFORMATION COLLECTED FROM CHILDREN UNDER 13 YEARS OF AGE.

The Services are general audience services, are not directed to individuals under 13 years of age and do not knowingly collect personal information from individuals under 13 years of age. If you are under 13 years of age, please do not attempt to register for the Services or provide any personal information about yourself to the Services. If mitú learns or believes that it has collected personal information from a child under 13 years of age, mitú will delete that information as quickly as possible. If you are a parent or guardian of an individual under 13 years of age and you become aware that your child or ward has provided mitú with personal information without your consent or you believe that mitú might have any personal information from an individual under 13 years of age, please contact mitú at info@mitunetwork.com.

3. INFORMATION MITÚ MAY COLLECT.

Mitú may collect both personally identifiable information as well as non-personally identifiable information when you visit or use the Services.

a. Personally Identifiable Information. Personally Identifiable Information (“PII”) means information that would allow a third party to identify or locate a particular person. PII includes, without limitation, your full name, email address, mailing address, mobile or other telephone number, birth date, and credit card number. Mitú only collects PII if that information is voluntarily provided by you. This may happen in several ways:

i. User Accounts. In order to access and utilize certain products or services provided by the Services, you may be required to create a user account and to provide certain PII, such as your full name, an email address, a user name and/or a password, contact information, etc. You are under no obligation to provide this information to mitú. However, if you decide not to share this information, you may be unable to create an account on the Services and/or you may be unable to fully utilize all or some the Services.

ii. Financial Transactions. Mitú may use third parties to provide credit card and other payment processing services for the Services. When you make any payment on or through the Services, you will be required to provide mitú and/or its authorized third party agents with financial information and related payment information. mitú and its third party agents may retain the details of transactions or payments you make on or through the Services. You authorize mitú and such third party payment processing services to store your payment history and payment account information (e.g. credit card account information) even after your account and/or your credit card has expired, to avoid interruptions in your service (e.g. subscriptions) and to facilitate easy payment for new service.

iii. Public Forums. Mitú may provide areas on the Services where you can post information about yourself and others and communicate with others or upload content such as photographs and videos. Whenever you disclose personal information on publicly-viewable web pages, that information will be publicly available and may also appear on other websites and in publicly available search results. If you post your personal contact information, you may receive unsolicited messages. Mitú encourages you to exercise discretion and caution with respect to the public posting of your personal information.

b. Non-Personally Identifiable Information. Non-Personally Identifiable Information (“Non-PII”) means information that does not allow a third party to identify or locate a particular person. You can visit the Services to read information about the Services and the products and services offered without revealing any PII. However, during your visit to the Services, mitú may collect anonymous Non-PII such as the activity of your browser when you are viewing the Services; your site path during your visit to the Services; demographic data; the amount of time you spend on the Services and general information regarding your internet service provider and host. The Non-PII may be collected by mitú in several ways:

i. Logging Of Your Activities On The Services. When you access the Services from a computer, mobile phone, or other device, mitú may collect and log information from that device about your browser type, location, and IP address (the number assigned to computers on the Internet). mitú may also collect and log anonymous “traffic data” information that does not personally identify you, but that may be helpful to mitú for marketing purposes or for improving the services that mitú offers to its users, such as the pages you visit, the length of your visit, your referring/exit pages, your clickstream activity and the actions you take while using or visiting the Services. No personal information about you is revealed in this process.

ii. Cookies. Mitú may use “cookies” to enhance your use of the Services and to monitor your activity during your visit(s) to the Services. Cookies are text files placed in your computer’s browser to identify your Internet browser and to store your preferences. You can remove or block cookies by programming your Internet browser, but in some cases that may impact your ability to access certain aspects of the Services.

iii. Beacons. Mitú may also use “web beacons”, clear.gifs, or similar technologies, to track the activity and flow of your visit(s) to the Services. “Web beacons” and clear.gifs are small pieces of code placed on a web page to monitor the behavior of and to collect data about the visitors to that page.

iv. Third Parties. Mitú may institute information sharing programs with third parties. For instance, mitú may request that advertisers provide mitú with information regarding the ad response rate for the users of the Services that were served specific ads. This helps mitú improve the relevance of the advertisements that you are served. Mitú may also receive information about your interaction with various ads on other sites on an anonymous basis in order to measure the effectiveness of those ads and determine their relevance to you.

v. Mobile & Location Information. If you use mobile-enabled services provided by mitú, such as any mitú mobile application made available by mitú, mitú may receive information about your use of the Services from your mobile device while you use mitú’s applications or Services. This may also include information about your precise location if you have enabled location-based services on your mobile device. Certain applications or services may also require additional information collection, such as information to be collected and sent to mitú and/or third parties from your mobile device when you are not logged into mitú for alerts services, and the terms of any such collection will be fully disclosed to you when you subscribe to or sign up for such services or applications and you will be given the opportunity to opt-in to or to decline receiving such services or applications.

c. Do Not Track Signals. At this time mitú does not respond to browser ‘Do Not Track’ signals, as mitú awaits the work of interested stakeholders and others to develop standards for how such signals should be interpreted.

d. Sensitive Information. Mitú asks that you not send to mitú, and that you not post or disclose any sensitive and/or personal information (e.g., social security numbers, phone numbers, addresses, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise.

4. INFORMATION COLLECTED BY THIRD PARTIES.

a. General. Mitú may use the services of third parties for various purposes, including, without limitation, to provide mitú with data collection (such as impressions, clicks, date and time of impressions and clicks, pages viewed, amount of time spent on certain pages or engaged in certain activities, browser type and operating system, and other general click stream information), user traffic activity, reporting and ad response measurement, and to deliver advertisements and marketing messages. These third parties, or mitú on their behalf, may use their own cookies to monitor your activity during your visit to and/or use of the Services. Additionally, these third parties, or mitú on their behalf, may place web beacons, clear.gifs or similar technologies on the Services, including, without limitation, on any and all (i) webpages and (ii) email or other electronic communications generated as part of the Services which are sent to you, as well as your replies thereto, and your actions in connection therewith, such as whether or not an email has been opened, a link has been clicked, or a page has been visited. mitú does not control the foregoing third party monitoring technologies or the information which they may collect and mitú has no responsibility or liability in connection with the foregoing. A third party’s use of the foregoing monitoring technologies and the information collected is subject to the third party’s own privacy policies and is not covered by this Privacy Policy. You can remove or block third party cookies and similar technologies by programming your Internet browser, but in some cases that may impact your ability to access certain of the Services.

b. Yahoo Web Beacons. Mitú may use Yahoo! web beacons to help analyze where visitors go and what they do while visiting the Services. Yahoo! may also use anonymous information about your visits to the Services and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo!, go to http://info.yahoo.com/privacy/us/yahoo/opt_out/tar…. If you don’t want mitú or other companies collecting information about your activity through Yahoo!, you can opt out by clicking here http://info.yahoo.com/privacy/us/yahoo/opt_out/targeting/details.html

c. Google Analytics. Mitú may use Google analytics to use Google cookies to collect data for display advertisers and for its other features. If you would like more information about this practice and to know your choices about not having this information used by Google and how you can opt-out from Google Analytics, then please go to http://www.google.com/policies/privacy/partners/.

d. Third Party Ad Servers. Some of the third party advertising companies that deliver ads on the Services may be members of the Network Advertising Initiative (“NAI”) which is a cooperative group of ad serving providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations of Internet advertising practices and how they affect you and the Internet generally. For more information about the NAI, third party ad servers generally, and the opt-out opportunities available through the NAI, visit http://www.networkadvertising.org/index.asp.

e. Interest-based advertising controls. Mitú may use your browsing history and personal information to display interest-based advertising that is relevant to you. Mitú may place interest-based advertisements on the Services as well as other third-party sites. If you don’t want mitú or other companies to collect or use information based on your activity on websites, devices or apps other than the mitú Services for the purpose of showing you interest-based ads, you can opt out for all participating companies through the Digital Advertising Alliance by going to http://youradchoices.ca/choices.

5. HOW MITÚ MAY USE YOUR INFORMATION. Mitú may use the PII and non-PII it collects under this Privacy Policy as follows:

a. Use Of Your PII.

i. Mitú may use the PII you share with mitú to manage your account, fulfill your requests for products, programs, and services, to respond to your inquiries about mitú’s offerings, to offer you other mitú products, programs or services that mitú believes may be of interest to you, to enforce the legal terms that govern your use of the Services, and for the purposes for which you provided the information.

ii. Mitú may use the PII you share with mitú to communicate with you (such as to notify you that you have won a contest or to provide you with updates, etc.), to contact you about your account, to respond to your comments or requests for information, etc. If a comment or request is made by email, mitú may respond by sending an email response back to the sender. Mitú may store the emails received by mitú for archival purposes and also for internal promotional purposes if mitú feels that this is consistent with the nature of the comment/request.

iii. Mitú may share your PII with mitú’s affiliated entities if mitú has a business reason to do so.

iv. Mitú may share your PII with third parties that assist mitú with the management, operation or administration of the Website; the analysis of the performance of the Website; the provision of mitú products and services (including, without limitation, the processing and serving of email and other electronic communications) and the administration, judging and prize fulfillment aspects of contests, sweepstakes and promotions. However, these third parties do not have any independent right to share this information and are required to treat your PII as confidential, to maintain appropriate security measures and to not use your PII for any purpose other than to carry out the services they are performing for mitú.

v. Mitú may also provide your PII to a third party in those instances where you have been notified that the fulfillment of your request for information, services or products will require mitú to share your PII with a third party and you have agreed that mitú may provide your PII or access thereto to the third party. mitú has no control over the use of your PII by any of these third parties. You should carefully review their privacy policies to make sure that you are comfortable sharing your PII with them.

vi. Mitú may from time to time offer promotions such as contests and sweepstakes that are sponsored by or co-branded with third parties. Prior to being able to participate in a promotion, you may be asked to agree to official rules that govern that promotion, which may contain specific requirements of you, including, allowing the sponsor of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion. If you agree to the applicable official rules of a promotion and if such rules so provide, then in connection with each such promotion, (1) mitú may provide your PII to such third parties if requested by the sponsor/branding entity as part of your participation in the promotion and/or (2) such third parties may obtain PII that you voluntarily submit to mitú or to such third parties in order to participate in the promotion. mitú has no control over the use of your PII by any of these third parties. You should carefully review their privacy policies to make sure that you are comfortable sharing your PII with them, either directly or via mitú. If you do not agree to mitú sharing your PII with such third parties, you should not agree to the official rules or participate in such promotion.

vii. Mitú may use third party payment processors for financial transactions (such as the payment of fees for various services) made through the Services. When you make a payment through the Services, mitú will require those third parties to agree to treat your PII as confidential, to maintain appropriate security measures and to not use your PII for any purpose other than to carry out the services they are performing for mitú.

viii. Mitú may use your email address to send you email communications, such as notifications, information on new services offered by mitú, special offers, promotions, the mitú newsletter, etc. You can unsubscribe from mitú’s newsletter or from receiving promotional materials from mitú at any time by following the unsubscribe instructions contained at the bottom of the relevant email from mitú. Please note that your opt-out request will not apply to subsequent or different subscriptions, or to certain transactional communications relating to your use of the Services (e.g., administrative and service announcements). You may elect to continue to receive the newsletter from mitú even if you choose to opt-out from receiving mitú’s marketing or promotional communications.

ix. If you access the Services from your mobile phone, you may be able to elect to receive text alerts to your mobile phone. Mitú does not charge for mobile services, but standard or other charges may apply from your mobile carrier. Please check your mobile carrier plan to find out what charges may apply.

x. If you choose to submit content for publication on or through the Services (such as a posting to a blog or discussion board or a letter or email with comments/questions to mitú’s editors), mitú may post/publish your user name.

xi. To allow social sharing functionality. If you log-in with or connect your social media account to the Services, mitú may share your user name, age range, interests, and your activities with your social media account provider. By logging-in with or connecting your Services account and your social media account, you are authorizing mitú to share information with your social media account provider, other users and your friends, and you understand that the social media service’s use of the shared information will be governed by the social media site’s privacy policy. If you do not want your information shared in this way, please do not connect your social media account with your Services account and do not participate in social sharing on the Services.

Mitú does not rent, share, or sell the PII you share with us to any third party for marketing purposes and only shares your PII with third parties as described in this Privacy Policy.

b. Use Of Your Non-PII.

i. Mitú may measure and analyze anonymous statistical Non-PII collected on an aggregated and/or un–aggregated basis in connection with your visit(s) to the Services in order to administer the Services; improve the quality of mitú’s services; improve the design, performance and content of the Services; and improve your experience on the Services, such as by providing more relevant content to you during your visits.

ii. Mitú may use and/or share anonymous, aggregated and/or un-aggregated Non-PII with third parties for any and all reasonable business purposes as mitú determines in its sole discretion, including, without limitation, advertising, promotion, business opportunities, etc. mitú may combine (a) your Non-PII with the Non-PII of other users of the Services and (b) Non-PII mitú collects through the Services with Non-PII mitú may collect from other sources.

iii. Mitú, mitú’s licensors, third party service providers and advertisers may use Non-PII to customize content, services, promotions, advertising, etc.; to offer you services, products, etc.; to manage and measure the performance of advertisements displayed on or delivered by or through the Services; to manage your account and preferences; to compile aggregate data about traffic and interaction on or through the Services so that mitú can improve your user experience; to protect against misuse of the Services; to enforce the Services’ Terms of Use Agreement and all other legal terms that govern your use of the Services and/or for the purposes for which you provided the information.

iv. To Deliver Video Content. In the ordinary course of mitú’s business, mitú may share information that mitú collects from or about you with third parties in order to process your requests and fulfill your orders for video content offered through the Services. For example, to process your request to view certain authenticated video content through the Services, mitú may need to share information about you with mitú’s third party service providers in order to authenticate and/or authorize you to view authenticated and/or localized video content through the Services.

c. Other Permitted Uses Of Information. Additionally, mitú may disclose the information it collects on the Website, both PII and Non-PII (collectively “User Information”), under the following circumstances:

i. Mitú may disclose any or all User Information if permitted by law; if required by any legal process or valid order of a court or other governmental body; to establish or exercise any or all of mitú’s legal rights, to defend any legal claims made against mitú and/or to enforce any or all of mitú’s legal rights that govern your use of the Services.

ii. If mitú sells all or a part of its business or makes a sale of all or a material part of its assets or is otherwise involved in a merger or transfer of all or a material part of its business), then as part of the applicable transaction, mitú may transfer your User Information to the party or parties involved in the transaction. mitú may also share and/or transfer your User Information to any or all of its affiliated entities (such as any subsidiary or parent).

iii. Mitú may disclose any or all User Information to protect or defend the legal rights or property of mitú or its employees, agents and contractors; to protect the rights, property or safety of the general public, the users of the Services and/or the mitú employees, agents and contractors and to investigate, prevent or take action regarding suspected or actual illegal activities or fraud or any claims that an individual’s rights have been violated.

6. PUBLIC AREAS.

If you post or provide any information in any public area on the Services (such as public forums, blogs, discussion boards, etc.) or if you otherwise make any information about yourself publicly available on the Services, you should be aware that any publicly disclosed PII can be read, collected, or used by other users of the Services, and could be used to send you unsolicited messages or otherwise. Mitú is not in any way responsible for the non-disclosure or protection of any PII or other information you choose to publicly disclose on or through the Services. You are solely responsible for all of the consequences resulting from any such public disclosure.

7. THIRD PARTY LINKED SITES.

The Services may contain links to third party websites. By accessing and/or using a linked third party website, you may be disclosing your personal information to such linked website. Therefore, you should carefully review the privacy policies of these other websites. If you are not comfortable with the policies of a linked website, you should not access and/or use that website. Mitú is not responsible for the policies (privacy or otherwise) or the content, services or products offered by or through any third party website. It is solely your responsibility to review the privacy policy and other policies of third party websites to confirm that you understand and agree with their policies.

8. CO-BRANDED AREAS.

Certain areas of the Services may be provided to you in association with third parties (“Co-Branded Areas“) such as sponsors. Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of your information. If you elect to register for products and/or services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both mitú and the third party. Mitú is not responsible for such third party’s data collection or privacy or other practices and advises you to carefully review such third-party privacy policies to confirm that you understand and agree with them.

9. SECURITY.

Mitú uses commercially reasonable and appropriate physical, electronic, and managerial security measures for the protection of your personal information in mitú’s possession from unauthorized access, destruction, use, modification or disclosure. However, since it is impossible to guarantee the security of (i) information storage technology or (ii) data transmission utilizing the internet, mitú does not guarantee that its security measures will not be circumvented or breached or that your personal information will not be accessed by, used by, modified by or disclosed to a third party. mitú is not responsible for any such circumvention or breach by any third party. Additionally, it is solely your responsibility, and not the responsibility of mitú, to protect the confidentiality of your password and username. Please note that email communications to and from the Services as well as email and other means of communication via the Services may not be encrypted and if you communicate personal, confidential or sensitive information through such means, you do so at your own risk.

10. UPDATING YOUR INFORMATION.

If you have registered for an account, you can at any time terminate your account or access your account to add, delete or modify any information which you have provided. Please note that none of the foregoing changes will be retroactive. Please also note that even after you terminate your account or delete or modify information from your profile, copies of the original information may remain viewable on the Services and/or elsewhere to the extent that your information was publicly posted by you or with your authorization, previously shared with others, otherwise distributed pursuant to your privacy settings,. Additionally, even if you have requested that your information be deleted, mitú may retain a record of certain information (including your PII) in order to prevent identity theft or other misconduct or as necessary to comply with applicable federal, state or local laws. Removed and deleted information may persist in backup copies, but will not be available to others. If you update any of your information, mitú may keep a copy of the information that you originally provided to us in our archives for uses documented in this policy.

11. CHANGES TO THIS PRIVACY POLICY.

Mitú may from time to time amend this Privacy Policy to reflect changes in mitú’s practices and services. If mitú makes any material changes to the way mitú collects, uses, or shares your PII, mitú will notify you of those changes via a posting on the Services or an electronic communication to you which notice will also indicate the effective date of the posted changes. Your continued use of the Services following the effective date of a change to this Privacy Policy signifies your acceptance of and agreement to the terms of the revised Privacy Policy. mitú encourages you to regularly review this Privacy Policy so that you remain updated as to any changes. mitú will indicate that changes have been made hereto by providing a “Last Updated” date at the top of this Privacy Policy following the Effective Date.

12. CONTACT US.

If you have any questions about this Privacy Policy or to report any privacy concerns, please contact mitú at info@mitunetwork.com.