Privacy Policy

Middleton (“we,” “us,” or “our”) has created this Privacy Policy to provide transparency and confidence as you access and use our website and mobile application, and to demonstrate our commitment to fair information practices and the protection of your privacy.

This Privacy Policy applies solely to the Middleton website and mobile application and does not apply to any third-party websites or mobile applications, which may have data collection, storage, and use practices that differ materially from those described in this Privacy Policy. Please review the section titled Third-Party Websites and Services for additional information.

BY ACCESSING OR USING THE MIDDLETON WEBSITE OR MOBILE APPLICATION, YOU REPRESENT THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY DISCONTINUE USE OF THE WEBSITE AND MOBILE APPLICATION.

This Privacy Policy is effective as of the date stated below and applies each time you access or use the website or mobile application. We encourage you to review this Privacy Policy periodically to remain informed of any updates or changes, as outlined in the Updates and Changes to This Privacy Policy section.

1. Children’s Privacy

The Middleton website and mobile application are not directed to children under the age of thirteen (13). Middleton does not knowingly solicit, collect, use, or disclose personally identifiable information from children under the age of thirteen (13). If Middleton becomes aware that it has collected personal information from a child under thirteen (13), such information will be promptly deleted from our records. Because Middleton does not knowingly collect personal information from children under thirteen (13), we do not use or share such information with third parties. This Privacy Policy is designed to comply with the Children’s Online Privacy Protection Act (COPPA).

2. Information Collection Practices

a. Traffic Data. Like most website or mobile application operators, LSP automatically gathers information of the sort that browsers automatically make available, including: (i) IP addresses; (ii) domain servers; (iii) types of devices accessing the Website or Mobile Application; and (iv) types of Web browsers accessing the Website (collectively "Traffic Data"). Traffic Data is anonymous information that does not personally identify you.

b. Cookies.A cookie is a small data file that a website stores on a user’s device and that the user’s browser sends back to the website with each subsequent request. Cookies are used to recognize users as unique visitors and to enhance functionality, but not to collect personal information directly. Middleton uses cookies to personalize your experience, remember your preferences, reduce repetitive messages, and facilitate login functionality so you do not have to re-enter information each time you visit the website. Most web browsers automatically accept cookies, but you may adjust your browser settings to receive notifications when cookies are placed, refuse certain cookies, or disable cookies entirely. Please note that disabling cookies may limit the availability or functionality of certain features of the Services.

c. Personal Information.To access certain Services, you may be asked to provide personally identifiable information (“Personal Information”). Personal Information may include, without limitation: (i) Contact Information, such as your name, email address, mailing address, and phone number; (ii) Demographic Information, such as age, gender, location, occupation, education level, or preferences, if voluntarily provided; and (iii) Financial Information, such as credit or debit card details and expiration dates, when required to process payments. In all cases, Personal Information is collected only when you knowingly and voluntarily provide it and is not collected without your awareness. Middleton may supplement the information you provide with additional information obtained from lawful public sources or authorized third parties. You are not required to provide Personal Information; however, choosing not to do so may limit your ability to access certain features or Services offered through the website or mobile application.

d. Information you Make Public on the Website or Mobile Application. The Website or Mobile Application may contain features (e.g. public profiles, forums, and message boards) that permit you to upload, post, transmit, display, perform or distribute content, information or other material, including your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which LSP is unable to exercise control. You should exercise caution when deciding to disclose your Personal Information by means of such features, and you agree to assume all responsibility for doing so.

3. INFORMATION USE AND DISCLOSURE PRACTICES

Middleton analyzes Traffic Data and information collected through cookies to better understand how users access and interact with the website and mobile application. This information helps us identify usage patterns and trends, improve functionality, enhance user experience, and deliver more relevant content. From time to time, Middleton may share aggregated and anonymized Traffic Data and cookie-related information, such as reports on usage trends. Middleton does not link information collected through cookies to personally identifiable Personal Information.

b. Personal Information

i. General Use of Personal Information Middleton uses your Contact Information to communicate with you regarding our Services, including service updates, information about our products and services, marketing and promotional communications, and details related to your orders or transactions. Financial Information is used to process payments and billing. Demographic Information, where provided, is used to personalize and improve your experience on the Middleton website and mobile application. From time to time, Middleton may use or disclose aggregated and anonymized demographic or usage data, such as reports on usage trends, which do not identify individual users.

ii. Disclosure Practices except as expressly described in this Privacy Policy, Middleton maintains the confidentiality of your Personal Information and does not sell, rent, or share it with third parties.

· Disclosure in Connection with Services. Middleton discloses Personal Information to third parties who assist in providing the Services, including those that perform technical, administrative, and data-processing functions such as hosting, billing, fulfillment, and data storage and security.

· By Law or to Protect Rights. Middleton discloses Personal Information when required by law or legal process, including in response to a subpoena or court order, or when Middleton reasonably believes that such disclosure is necessary to protect the rights, property, or safety of Middleton, third parties, or the public.

· Business Transfers; Bankruptcy. Middleton reserves the right to transfer all Personal Information in its possession to a successor organization in the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of Middleton’s assets. Except as otherwise ordered by a bankruptcy or other court, the use and disclosure of any transferred Personal Information will remain subject to this Privacy Policy, or to a new privacy policy if you are provided notice of such policy and an opportunity to affirmatively opt out where required by law. Personal Information collected after a transfer may be governed by the successor organization’s privacy policy.

· Unpaid Accounts. If you fail to pay any balance owed for Services, Middleton may, to the extent permitted by applicable law, disclose or report relevant Personal Information, including outstanding balances, to consumer credit reporting agencies, collection agencies, or other entities involved in the collection of such amounts.

4. CONSENT TO RECEIVE COMMUNICATIONS FROM STARFISH PERKS

By registering with the Middleton website, you consent to receive periodic email and other communications from Middleton regarding policies, service updates, new product or service offerings, promotions, and related matters. If you no longer wish to receive email communications, you may opt out at any time by following the unsubscribe instructions included in each email or by contacting us at [email protected]

5. SECURITY OF PERSONAL INFORMATION

LSP has implemented and maintains reasonable security procedures and practices to protect against the unauthorized access, use, modification, destruction or disclosure of your Personal Information.

6. LOST OR STOLEN INFORMATION

You must promptly notify us if your credit, banking, other financial information, user name or password is lost, stolen or used without permission. In such an event, we will remove that credit card number, bank account information, other financial institution information, user name or password from your account.

7. USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION

LSP wants your Personal Information to be complete and accurate. By using the Website or Mobile Application, you represent and warrant that all information you provide on any registration form or otherwise in connection with your use of the Website or Mobile Application and Services will be complete and accurate, and that you will update that information as necessary to maintain its completeness and accuracy. To confirm the completeness and accuracy of, or make changes to, your Personal Information, visit your Profile. Through your Profile you may review and update your Personal Information.

8. THIRD-PARTY WEBSITES AND MOBILE APPLICATIONS

Middleton does not own or control third-party websites or mobile applications. Accordingly, such third-party websites or mobile applications are not subject to this Privacy Policy except with respect to Personal Information provided directly to them by Middleton. Before accessing or providing Personal Information to any third-party website or mobile application, you should review their privacy policies and practices and take any steps you deem necessary to protect your privacy. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information may be shared with subcontractors solely to support service-related functions, such as customer service. All other use-case categories exclude text messaging originator opt-in data and consent; such information will not be shared with any third parties.

9. PROMOTIONAL ACTIVITIES

From time to time, Middleton may conduct contests, giveaways, and other promotional activities (collectively, “Promotional Activities”). Any information submitted in connection with such Promotional Activities will be handled in accordance with this Privacy Policy. Middleton may also invite you to participate in surveys intended to help improve the website, mobile application, or Services. Any Personal Information provided in connection with a survey will be used solely for the purposes of that survey and may be disclosed to third parties only in aggregated and anonymized form, and not in a manner that identifies you individually.

10. UPDATES AND CHANGES TO PRIVACY POLICY

Although most changes are likely to be minor, LSP reserves the right, at any time and without notice, to add to, update, change or modify this Privacy Policy, simply by posting such update, change or modification on this page. Any such addition, update, change or modification will be posted on the Website or Mobile Application 30 days prior to the effective date of the amendment(s). Each time you use the Website or Mobile Application, the then-current version of this Privacy Policy will apply. Accordingly, each time you use the Website or Mobile Application, you should check the date of this Privacy Policy (which appears at the end) and review any changes since the last time you used the Website or Mobile Application. Unless LSP obtains your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier Privacy Policy.