Privacy Policy
T – F Studio Privacy Policy
Effective Date: 10 October 2024
T – F Studio (“we”, “our”, or “us”) is committed to protecting your privacy. Our Privacy Policy explains how your personal information (as defined below) is collected, used, and shared when you use our Services. These include our website www.tashafranken.com (the “Site”), our shop (“the Shop”), our affiliate links, our blog, our mobile app (“the App”), or any other technologies, features, and content we offer.
This Privacy Policy does not apply to third party websites, products, or services, even if they may link to our Sites and our Sites may link to them. We recommend you review the privacy practices of those third parties before accessing third party websites and sharing any personal information.
TABLE OF CONTENTS
This Policy is provided in a layered format. We encourage you to read this Policy thoroughly. For more information, contact us using the information in the “Contact Us” section.
1. Personal Information We May Collect, Use, and Disclose
2. Sources of Personal Information
3. Disclosure of Personal Information
4. Aggregated, Deidentified, or Anonymized Data
5. Cookies and Tracking Technologies
6. Data Security and Retention
7. International Data Transfers
8. Children's Privacy
9. Your Privacy Rights and How to Exercise Them
10. California Privacy Notice
11. Nevada Privacy Notice
12. Virginia Privacy Notice
13. EEA and UK Privacy Notice
14. Updates to this Privacy Policy
15. Contact Us
1. PERSONAL INFORMATION WE MAY COLLECT, USE AND DISCLOSE
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal information includes “personal data” as that term is defined in applicable privacy laws, as may be further described in Your Privacy Rights. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information.
We may disclose non-personal information, such as aggregated user statistics, to third parties. Our use of aggregated, anonymized, and de-identified data is not subject to this privacy policy.
|
Category of Personal Information |
Purposes of Collection and Use |
Categories of Third Party Recipients |
|
Identifiers, including
|
Contact you and provide information Provide customer service Perform identity and age verification as required under applicable law Provide and maintain the Service Facilitate interactive features Internal analytics Market our products and services Market the products and services of others Promotions and sweepstakes Internal business purposes, including general business administration Audit, compliance, legal, policy, procedure, and regulatory obligations Customer claims and fraud investigation and prevention Systems and data security Protecting the safety of our employees and others Targeted advertising Profiling For any purpose consistent with your preferences |
Service platform Our advertising and marketing partners Third party advertising platforms |
|
Commercial information, including
|
Same purposes as noted above for “Identifiers” |
Our advertising and marketing partners Third party advertising platforms |
|
Financial information, including
|
Provide and maintain the Services Internal business purposes, including general business administration |
N/A |
|
Internet or other electronic network activity information, including
|
Same purposes as noted above for “Identifiers” |
Our advertising and marketing partners Third party advertising platforms |
|
Geolocation Data, including
|
Internal business purposes, including general business administration Customer claims and fraud investigation and prevention Systems and data security Protect the safety of our employees and others Internal analytics |
Our advertising and marketing partners Third party advertising platforms |
|
Audio, electronic, visual or similar information, including
|
Same purposes as noted above for “Identifiers” |
Our advertising and marketing partners Third party advertising platforms |
|
Characteristics of protected classifications, including:
|
For internal business purposes, including general business administration Customer claims and fraud investigation and prevention Systems and data security Protecting the safety of our employees and others Internal analytics |
N/A |
|
Education information, including:
|
Provide and maintain our Services Internal analytics Promotions |
N/A |
|
Sensitive information or sensitive data, including:
|
Provide customer service Provide and maintain the Service Internal analytics Market our products and services Market the products and services of others Internal business purposes, including general business administration Audit, compliance, legal, policy, procedure, and regulatory obligations Targeted Advertising Profiling For any purpose consistent with your preferences |
N/A |
|
Inferences about you using any of the above |
Any of the above purposes |
Our advertising and marketing partners Third party advertising platforms |
Due to the overlapping nature of categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.
2. SOURCES OF PERSONAL INFORMATION
We may collect personal information about you from the following categories of sources:
- Directly from you through your interactions with us, such as when you use the Sites or Services, create an account with us, complete electronic forms, or otherwise contact us via email, SMS or social media.
- Through cookies and tracking technologies, as discussed in more detail in Section 5.
- From third parties, including our third party service providers, business and marketing partners, affiliates, analytics providers, ad network providers, ad agencies, and advertisers.
- From social media and other content platforms, such as Google, TikTok, Meta, and Bing, if you access the Service through a third-party connection or login or interact with us on these platforms to use the Sites or Services.
- From government agencies or public records.
3. DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose personal information that we collect, or that you provide to:
- Our affiliates. We may share personal information among our affiliates to provide our Services, and for internal administrative purposes.
- Our service providers. We share personal information with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use the information for any other purpose. For example, we use Vimeo to power our video content and you can read more about how Vimeo uses your Personal Information here: https://vimeo.com/privacy.
- Our advertising and marketing partners. We partner with businesses and organizations that may offer products and services that we believe may be of interest to you. In certain cases, we may share personal information with these partners consistent with this Privacy Policy and the context in which you provided the information to us.
- Third party platform advertising. We may share your information with third-party platform providers who assist us in serving advertising to others who may be interested. We also partner with third parties who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location, and/or interests.
- Compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities.
- Affiliate and business transfers and transactions. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity.
4. AGGREGATED, DEIDENTIFIED, OR ANONYMOUS INFORMATION
We may create aggregated, de-identified, or anonymous information from personal information by removing certain data components (such as your name, email address, or linkable tracking ID) that make the data identifiable, or through aggregation, obfuscation or other means. For example, we may de-identify any information and data provided and/or generated in connection with your use of our Services, in compliance with applicable law. Subject to applicable law, our use of such aggregated, de-identified, or anonymized information is not personal information or subject to this Privacy Policy.
5. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies and analytics services to track activity on and guage the effectiveness of the Sites.
Cookies
Cookies are files with a small amount of data which may include unique identifiers. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies we may use include web beacons to track information and analyze the Services. Beacons (also known as pixel tags, clear GIFs) are small objects embedded in an image on a website and can transmit information directly to use, or to another person or entity of our choice. We may use the following types of cookies:
- Strictly necessary. We may use cookies that we consider strictly necessary to allow you to use and access our website, including cookies required to prevent fraudulent activity, improve security, or allow you to use shopping cart functionality.
- Performance. We may use cookies that are useful in order to assess the performance of our website, including as part of our analytic practices or otherwise to improve the content, products or services offered through our website.
- Functionality. We may use cookies that are required to offer you enhanced functionality when accessing our website. This includes identifying you when you sign in or keeping track of your specified preferences, including in terms of the presentation of content on our website.
- Advertising. We may use cookies to deliver content, including ads, relevant to your interests on our website and third party sites based on how you interact with advertisements or content.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Analytics
We may use Google Analytics, Klaviyo, Shopify, Lucky Orange, or other service providers for analytics services. These analytics services may use cookies and other tracking technologies to help us analyze how users use the Services. Information generated by these services, such as your IP address and other usage information, may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. You may exercise choices regarding the use of cookies from such service providers; for example from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
Session Replay
Our Sites use session replay technology. Session replay is a reconstruction presentation of how an individual experiences a website or mobile application. It captures things like clicks, mouse movements, and page scrolls, and generates a walkthrough-style video of what the individual did while on a site enabled with it. We use session replay technology to understand how you and other individuals experience our Sites and how to enhance or improve them, our products, and services. We do not use session replay technology to collect information that is inconsistent with your intent, and we do not use it to record sensitive information related to credit cards. We do not provide information gathers to third parties other than our service providers.
Our Sites use Lucky Orange. For information on how Lucky Orange may collect and use your personal information, please review Lucky Orange’s Privacy Policy.
Third Party Ad Networks
Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.
In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members' ad networks. You can learn more about opting out of such targeted advertising or to use the NAI tool here. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you. This will affect this and other services, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g., mobile app), your NAI/DAA browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third parties opt-out options or programs or the accuracy of their statements regarding their programs.
You can also exercise opt-out choices regarding Google Ads, Bing Ads, TikTok, and Meta.
6. CHILDREN’S PRIVACY
Our Services are not intended for children under age 16 and we do not knowingly collect information from such persons. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers. If you believe that we might have any information from or about an individual under age 16, please contact us at info@tashafranken.com
7. DATA SECURITY AND RETENTION
We have taken reasonable steps to secure and protect your personal information from loss, unauthorized access, unauthorized disclosure, misuse, destruction, or alteration. However, there is always some risk involved in transmitting information over the Internet, and we cannot fully eliminate security risks associated with the storage and transmission of personal information.
We will assume that anyone who has and uses the required login/password information for your account is you, so please keep this information confidential. If you have an account with us and you suspect any unauthorized use of your account or password, that the security of your account has otherwise been compromised, or have any questions about our security, please notify us in accordance with the Contact Us section below.
We will retain your personal information only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal information for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.
8. INTERNATIONAL TRANSFER OF YOUR PERSONAL INFORMATION
Your information, including personal information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there. For such transfers, we take the necessary measures to ensure that your personal information receives an adequate level of protection.
We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and is not transferred an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
9. YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM
You may have certain rights and choices regarding our collection, use and disclosure of your personal information, based on your location or place of residency.
Opting out of promotional electronic communications from us
We may use your personal information to send you updates regarding existing products and services, information about new products and services, upcoming events, surveys, and other announcements and inquiries. Please note that we may send you marketing and advertising messages on behalf of a third party (including subject to a paid arrangement); provided, under such a circumstance, we will not disclose your personal information to said third party. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or communicate your opt-out request using the information below. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with the Service or for other reasons disclosed in this Policy.
Additional rights available in certain states and jurisdictions
This Notice discloses information related to our privacy practices required by certain U.S. State laws which include, but are not limited to, California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, Virginia, and Washington.
Certain jurisdictions, including California, Virginia, Nevada, the EEA, and the UK, provide residents or those located in it with certain rights with respect to their personal information or personal data as defined under applicable law. Please see jurisdiction-specific sections below for more information on rights and terms specific to your place of residence.
Exercising your privacy rights
Please use the following information to exercise your rights. Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in another language, you may access your privacy rights by emailing us at info@tashafranken.com
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Depending on applicable law, you may be limited in how many verifiable or authenticated consumer requests you make within a twelve (12) month period. If we have inadvertently collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Generally, a rights request must include:
- Sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which must include, at a minimum, your first and last name and email address.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.
We cannot respond to your request or provide you with personal information if we cannot verify or authenticate your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request.
You are not required to create an account with us to submit a verifiable or authenticated consumer request. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact info@tashafranken.com. Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.
How to submit a request. To exercise any of the rights described in this Privacy Policy, please send your request(s) using one of the following methods:
• Emailing us at info@tashafranken.com
• Visiting the contact page at our Site
10. CALIFORNIA PRIVACY NOTICE
This California Privacy Notice provides additional information regarding personal information about California residents that we collect, how we use it, what sources it is derived from, and to whom we disclose it, and provides information regarding to California residents’ rights, and our responsibilities, under the California Consumer Privacy Act and its amendments in the California Privacy Rights Act (“CCPA”), and other relevant California laws and regulations.
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information, as well as rights to access, correct, delete, and restrict the sale, use, and disclosure of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of their privacy rights under the CCPA. If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in another language, you may access your privacy rights by emailing us at info@tashafranken.com
Personal Information We Collect
We may collect, or have collected, the categories of personal information about you as described in Section 1. For purposes of this section, personal information also includes personal information as described in California Civil Code Section 1798.80(e), which includes “financial information” as described in Section 1. Additionally, for purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
Certain of the personal information that we collect may constitute “sensitive personal information” as defined by California law. This may include:
- Your account login information
- Content of messages sent through the Site or Services
- Personal information collected and analyzed concerning your health.
How We Use Your Personal Information
We use the personal information we collect about you for all of the purposes outlined in Section 1 above.
Sources of Personal Information
We may collect personal information about you from the sources outlined in Section 2 and supplement it with information we obtain from other sources, including online and offline information providers.
To Whom we Disclose Personal
We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal information was collected. This includes the purposes described in Section 1.
We may “sell” and/or “share” personal information with third party partners as part of targeted advertising initiatives, or in certain circumstances, with our advertising and marketing partners. That sharing may constitute a “sale” and/or “share” under California law, even though we do not receive monetary payment for sharing or disclosing personal information to these third parties. In the last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal information:
- Identifiers
- Commercial information
- Internet or other electronic network activity information
Your California Privacy Rights
If you are a California resident, you have the following rights under applicable California law:
- Right to Opt-Out of Sale and/or Sharing: You have the right to opt-out of the sale and/or sharing of your personal information. We may “sell” and/or “share” your personal information for purposes of cross-context behavioral advertising, or in certain circumstances, with our advertising and marketing partners.
- Right to Provide Affirmative Consent: We cannot process your sensitive data or use your personal data for certain purposes without your affirmative consent.
- Right to Know and Access: You have the right to know what personal information we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
- Right to Delete and Erase: You have the right to request that we, as well as our service providers and contractors, delete the personal information that we collect about you under certain circumstances.
- Right to Correct Inaccurate Personal Information: You have the right to request the correction of inaccurate personal information.
- Right to Limit Use and Disclosure: You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
- Sharing with third parties for their own direct marketing purposes: We do not disclose this personal information to third parties for their own purposes without your consent. If you wish to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information provided in Section 9. You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
How to Exercise Your Rights
You may exercise any of the rights described in this section by following the instructions in Section 9.
You may opt out of the sale or sharing of your personal information by adjusting your preferences in the privacy notice pop-up displayed upon your entry to our website, where you can select your desired privacy settings.
If you do not have an account with us or if you are not logged into your account, your opt out request will be linked to your browser identifier only and not linked to any account information, because the connection between your browser and your account is not known to us.
Please note that we do not knowingly sell or share the personal information of minors under 16 years of age without legally required affirmative authorization. If you are a parent or guardian and you believe that your child has provided us with information without your consent, please review Section 8 and contact us at info@tashafranken.com
We also encourage you to utilize the cookie preferences options that appear in the cookie banner on the Services. Finally, you may also visit the websites of the Network Advertising Initiative and the Digital Advertising Alliance's Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements and how to opt back in if desired. You may also learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings.
Notice of Financial Incentives
We may provide programs and offers, such as promotional campaigns, email newsletters, student discount programs, and referral programs. When you sign up for one of these programs, we typically ask you to provide your first and last name, email address, and phone number. Because these programs involve the collection of personal information and the offering of certain benefits, they might be interpreted as a “financial incentive” program under California law. Such programs may include:
- Email Newsletter: When you subscribe to our newsletter, we may offer you special savings in the form of digital coupons for free or discounted products and announcements of sweepstakes, contests, and giveaways. In order to receive the newsletter, you must provide certain personal information, including first and last name and valid email address. To opt out of our newsletter, please click “unsubscribe” located at the bottom of any email newsletter.
- Referral Program: We may offer digital coupons for free or discounted products, store credit to our online store, or gift cards. When you sign up for our Referral Program, you will be asked for personal information such as your first and last name and valid email address to participate in the program. More information on our Referral Program is found in the program’s terms and conditions.
Under California law, the value we place on personal information collected for these promotions varies, but we estimate it equals the additional spending per promotion participant, compared to individuals for whom we do not have the collected information. You may withdraw from these promotions at any time by contacting us at info@tashafranken.com. If you withdraw from these programs, we will not contact you for at least twelve (12) months before requesting your participation again.
Retention of Personal Information
We will retain personal information as described in Section 7.
11. NEVADA PRIVACY NOTICE
Although we do not “sell” personal information as defined by Nevada Law, Nevada residents nonetheless have the right to request to opt out of any future “sale” of their personal information under Nevada SB 220 and SB 370. If you are a Nevada resident and would like to make such a request, please follow the instructions in Section 9. You must include your full name, email address and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.
12. VIRGINIA PRIVACY NOTICE
This Virginia Privacy Notice provides additional information regarding personal information about Virginia residents that we collect, how we use it, and who we disclose it to, and provides information regarding to Virginia residents’ rights, and our responsibilities, under the Virginia Consumer Data Protection Act (“VCDPA”), and other relevant Virginia laws and regulations.
The VCDPA provides Virginia residents with rights to receive certain disclosures and access regarding the collection, use, sale, and sharing of personal information, as well as rights to delete, correct, and affirmatively consent to the use, disclosure, and sale of certain personal information we collect about them. Additionally, Virginia residents have the right to opt-out of targeted advertising, sale of their personal data, and profiling. Virginia residents also have the right not to receive discriminatory treatment by us for the exercise of their privacy rights. This Virginia Privacy Notice does not apply to certain personal information that is already subject to certain federal and state regulations.
Personal Data We Collect
We may collect, or have collected, the categories of personal data about you as described in Section 1. For purposes of this section, “publicly available information” means information that is lawfully made available through federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer, or by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.
We do not collect “sensitive data” as that term is defined in the VCDPA.
How We Use Your Personal Data
We use the personal data we collect about you for all of the purposes outlined in Section 1.
To Whom we Disclose Personal Data
We limit our disclosure of the categories of data above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal data, in a way that is adequate, relevant, and necessary for specific purposes described in this Privacy Policy, compatible with the nature and purpose(s) for the collection, use, and retention of the personal data.
We may “sell” personal data with third party partners as part of targeted advertising initiatives, or in certain circumstances, with our advertising and marketing partners. That sharing may constitute a “sale” under Virginia law. In the last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” the following categories of personal data:
- Identifiers
- Commercial information
- Internet or other electronic network activity
Your Virginia Privacy Rights
If you are a Virginia resident, you have the following rights under applicable Virginia law in relation to your personal data, subject to certain exceptions:
- Right to Opt-Out: You have the right to opt out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
- Right to Provide Affirmative Consent: We cannot process your sensitive data or use your personal data for certain purposes without your affirmative consent.
- Right to Know and Access: You have the right to know what personal information we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
- Right to Delete and Erase: You have the right to request that we, as well as our service providers and contractors, delete the personal information that we collect about you under certain circumstances.
- Right to Correct Inaccurate Personal Information: You have the right to request the correction of inaccurate personal information.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
How to Exercise Your Rights
You may exercise any of the rights described in this section by following the instructions in Section 9.
If you wish to appeal our decision with regard to a request that you have previously made, please contact us using the information above or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.
13. EUROPEAN PRIVACY NOTICE
This European Privacy Notice applies to any individuals located within the European Economic Area (EEA), UK from whom we may have collected personal data from any source, including through your use of the Service. We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.
European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, access, rectification, erasure, restrict processing, data portability and to object with respect to collected personal data. For the purposes of this European Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.
Basis for Processing Your Personal Data
We rely on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our terms of use; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.
Legitimate Business Interests
We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms. While our legitimate interests are most extensively detailed in Section 1, they generally include:
- Provide, improve, and develop our Services, including to deliver your requested services, send you messages and provide user support, customize the Services to better fit your needs as a user, develop new products and services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
- Protect you and others, and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions with our Services, content you submit via our Services, and information obtained from third parties.
- Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.
In certain circumstances, individuals located within the EEA and UK are entitled to the following data protection rights:
- Right to Access: You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
- Right to Erasure: You have the right to request that we erase your personal data in certain circumstances provided by law.
- Right to Rectification: You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
- Right to Object to Processing: You have the right to object to our processing of your personal data.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data.
- Right to Data Portability: You have the right to request that we provide you with a copy of your personal data in a structured, machine-readable and commonly used format.
- Right to Withdraw Consent: You also have the right to withdraw your consent at any time where we rely on your consent to process your personal data. Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data. You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA). You can view the contact information for your data protection authority here.
To exercise your data protection rights described as below, please follow the instructions in Section 9.
14. CHANGES TO THIS PRIVACY POLICY
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. We recommend reviewing this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
15. CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@tashafranken.com.