We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use.
The personal information we collect can include the following:
- Name and Contact Data – We collect your first and last name, email address, postal address, phone number, and other similar contact data.
- Credentials – We collect passwords, password hints, and similar security information used for authentication and account access.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
INFORMATION AUTOMATICALLY COLLECTED
Some information, such as IP address and/or browser and device characteristics, is collected automatically when you visit our Sites.
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
INFORMATION COLLECTED FROM OTHER SOURCES
We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
HOW YOUR INFORMATION IS USED
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process – If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
- To send administrative information to you – We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
- To protect our Sites – We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies – To respond to legal requests and prevent harm. If we receive a subpoena or
other legal request, we may need to inspect the data we hold to determine how to respond.
HOW YOUR INFORMATION IS SHARED
We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent – We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests – We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract – Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations – We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests – We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers – We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
COOKIES AND OTHER TRACKING TECHNOLOGIES
TIME FRAME FOR INFORMATION STORAGE
When we have no ongoing legitimate business need to process your personal information, we will either delete or provide anonymity for it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
INFORMATION STORAGE AND SECURITY
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
INFORMATION FROM MINORS
We do NOT knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at privacypolicy @tolerogroup.com.
You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
- Contact us using the contact information provided.
SPECIFIC PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.
Yes, we will update this policy as necessary to stay compliant with relevant laws.
If you have questions or comments about this policy, you may email us at privacypolicy @tolerogroup.com or by post to:
c/o Tolero LLC
9732 Pyramid Way, Suite 181
Sparks, NV 89441
Effective as of: October 20, 2019