2. Information We Collect
A. Personally Identifiable Information. The types of personally identifiable information we collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with TPA and the requirements of applicable law. Below is more information on the ways we collect personal information and how we use it.
B. Types of personal information. TPA collects personal information from its current, prospective, and former customers, visitors, and guests (collectively “Individuals”) through the following channels:
Information Provided Directly to Us: When you use the Services, contact us directly, or engage in certain activities, such as registering for an account with TPA, placing an order on our website, or signing up to receive emails about our latest products and services, we may ask you to provide some or all of the following types of information: your name, email address, mailing address, phone number, payment information, such as a credit card number, billing address, and/or other related information required to complete the purchase (such payment information, “Financial Information”).
Communications: We may collect personal information from you such as your email address, phone number or mailing address when you choose to request information about our Services, visit our retail stores, register to receive communications over email or text messaging, participate in promotions, or loyalty programs, or otherwise communicate with us. Where allowed by applicable law, we may also record and store customer support calls for training and quality purposes.
Sweepstakes and Contests: If we run a sweepstake or contest, we may ask you to provide contact information (e.g., a phone number or an email address) or other personal information. Your contact information may be used to reach you about the sweepstakes or contest, and, to the extent permitted by law, for other promotional, marketing and business purposes. In compliance with the laws of your jurisdiction, as a participant you may have the opportunity to opt-out of any communications that are not related to awarding prizes.
Information from Third Parties: We may receive information about you from other sources, including through third party services and organizations, to supplement information provided by you. This supplemental information allows us to enhance our ability to provide you with information about our business, products and Services.
Automated Data: We may collect certain information automatically through our Services and/or other methods of technical analysis, such as your IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, in-store activity through (e.g., through closed circuit TVs for security monitoring or geofencing to identify traffic), the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services (such as preferences).
Please note that if you attend one of our in-person events, we may collect personal data from you and such data may be linked to information we also collect online or through email and other marketing campaigns.
3. How We Use Your Information
By providing personally identifiable information to us, we are able to perform a number of business functions, such as:
Provide Products, Services, or Information Requested. TPA may use information about you to fulfill requests for products, Services or information, including to:
Respond to questions, comments, and other requests;
Provide access to certain features of the Services;
Personalize product recommendations;
Communicate with you about logistical matters, including product deliveries and shipping;
Conduct internal research and development;
Review and respond to requests for customer support; and
Allow you to register for online profiles or in-person events.
Administrative Purposes. TPA may use personal information for administrative purposes, including to:
Measure interest in our products and Services;
Develop new products and Services;
Ensure quality control;
Send emails or text messages to the email address or telephone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, delivery updates, or system maintenance;
Process payment(s) for products or services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Maintain and administer our Services; and
Enforce our Terms of Service
Marketing. TPA may use personal information to provide you with marketing materials that may be of interest, including:
To notify you about offers, products and Services that may be of interest or about which you have previously expressed an interest (e.g., request for program information or early notification to future events);
For other purposes disclosed at the time that you provide personal information; or
Otherwise with your consent. You may contact us at any time to opt-out of the use of your personal information for marketing purposes, as further described in Section 6.
Research and Development. TPA may use personal information alone or in the aggregate with information obtained from other sources, in order to help us improve our existing products and Services or develop new products and Services. From time to time, TPA may perform research (online and offline) via surveys. We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns and/or promotional activities. If you participate in a survey, the information given will be used along with that of other study participants.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with personal information, or whose personal information we obtain from third parties, may, as permitted by law, receive periodic emails, newsletters, mailings, text messages or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events that we believe may be of interest. We offer the option to decline these communications at no cost by following the instructions in Section 6.
Anonymous and Aggregated Information. TPA may use personal information and other information about you to create anonymized and aggregated information, such as de-identified demographic or psychographic information, information about the computer or device from which you access the Services or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not personal information, and we may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may also share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Shared Content. From time to time, we may offer referral services of features that allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services or purchase product from us.
Other. TPA may use personal information for which we have a legitimate interest, such as fraud protection or compliance with legal obligations, or any other purpose disclosed to you at the time you provide personal information or with your consent.
4. Cookies, Pixels, and Similar Technologies
Our uses of such Technologies fall into the following general categories:
Operational. We may use Technologies that are necessary to the operation of our Services. This includes Technologies that allow you access to our websites, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of functions such as shopping carts, saved search or similar functions.
Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services or tools.
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into the Service or keeping track of your specified preferences, interests or past items viewed so that we may enhance the presentation of content.
Advertising-Related. We may use first-party or third party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. We may also use third parties to serve targeted advertisements to people similar to our customer base (e.g., by uploading a hashed customer list to Facebook Custom Audiences) or incorporating a pixel from the third-party on our Site. Even if you have disabled certain cookies, advertisements may still be displayed to you through these third-party channels.
If you would like to opt-out of the Technologies we employ, you may do so by blocking, deleting or disabling them as your browser or device permits. See Section 6 for additional opt-out options. Please note that blocking, deleting, or disabling these Technologies will affect the functionality of our Services and may prevent you from being able to access certain features.
5. How We Share Your Information
We share information collected through the Services with the following categories of parties:
Business Partners. TPA may share personal information with its business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. TPA may also provide personal information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with TPA.
Marketing. TPA may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities on our Services (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected personal information (such as demographic information and past purchase history) we have collected with third party advertising partners. Advertising partners may use this information (and similar information collected from other companies) for purposes of delivering targeted advertisements to you when you visit non-TPA related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Service to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.
Professional Advisors: We share personal data with our legal, financial, insurance and other advisors in connection with corporate transactions or in connection with the management of all or part of our business or operations.
Legal Disclosure / Law Enforcement. We may access, preserve and disclose your personal information, other account information and content if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process, such as, a court order or subpoena; (ii) to respond to your requests; (iii) to protect yours, ours or others’ rights, property or safety; (iv) to enforce TPA policies or contracts; (v) to collect amounts owed to TPA; (vi) to comply with records retention policies; (vii) when we believe access, preservation, or disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (viii) if we, in good faith, believe that access, preservation, or disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order to allow them to identify users in connection with their investigation of unauthorized activities.
6. Managing Your personal information / Opt-out
We want to communicate with you only if you want to hear from us. You have the right to object to and opt-out of certain uses and disclosures of your personal information. Where you have consented to TPA’s processing of your personal information, you may withdraw that consent at any time and opt-out to further processing by contacting firstname.lastname@example.org. Please note that even if you opt-out, we may still collect and use non-personal information regarding your activities on our Service and/or information from the advertisements on third party websites for non-interest based advertising purposes, such as, to determine the effectiveness of the advertisements.
Email. You can unsubscribe from email, text and phone communications at any time. If you would like to opt-out of receiving marketing via email, click the unsubscribe link on the footer of marketing emails. We will process your request within a reasonable time after receipt, in accordance with applicable laws. TPA will continue to send you non-promotional, service emails concerning your account, such as emails relating to available upgrades, billing and payment information, outstanding balance on your account, and other emails relating to your account and/or your use of the Site.
Direct Mail. If you would like to opt-out of receiving communication via postal mail, contact email@example.com. To learn more about your rights as a consumer and to receive less national advertising mail, please visit the Direct Marketing Association at www.dmachoice.org.
Account. You may review, update, or modify your account information at any time by logging into your TPA account. You may also deactivate or delete your TPA account by emailing firstname.lastname@example.org.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not override these settings or options. However, in order to access certain content, features, services, products, or benefits of the Services, you may be required to provide us with certain information, including some types of personally identifying information. If you do not wish to provide such information through the Service or if you opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products, or benefits of the Site.
Cookies and Similar Technologies. You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs may not be effective on mobile interfaces. However, on many mobile devices, application users may opt-out of certain mobile advertisements via their device settings. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at:
You can also choose not to be included in Google Analytics:
7. Security & Retention
The security of your personally identifiable information is important to us and TPA is committed to handling such information carefully. We maintain physical, electronic and procedural safeguards to guard your personally identifiable information. We use secure socket layer technology to protect the security of your payment information and we encrypt your personally identifiable information when it is sent over the Internet. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Services or sending an email to you. You may have a legal right to receive this notice in writing.
8. Children’s Privacy
Our Services are not directed to children under the age of 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect personal information from children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at email@example.com. If we learn that we have collected personal information of a child under the age of 13 (or under the age of 16 in certain jurisdictions, such as EU member countries) we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.
9. California Residents
California law requires us to disclose certain information related to our privacy practices, as set forth below.
A. WHAT PERSONAL INFORMATION WE COLLECT
The list below identifies the categories of personal information we have collected over the preceding 12-month period, as well as examples in each category. For more information about the personal information we collect, please see Section 2.
Examples of personal information in this Category
Name, email address, billing address, shipping address, phone number
Internet protocol (IP) address, billing address, shipping address
Internet or other electronic network activity information
IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences
Financial, medical, or health information
Payment information, such as credit card number
Audio, electronic, visual, thermal, olfactory, or similar information
Recordings of customer support calls
Inferences drawn from any of the above information categories
Inferences about the type of products you prefer; demographic and psychographic inferences
The sources of the personal information we collect above include personal information that you directly provide to us (through the Services), personal information we receive from third party partners (for example, certain marketing, research or survey partners), and personal information that we generate internally. Please see Section 2 for additional details.
C. WHAT PERSONAL INFORMATION WE SHARE
D. YOUR RIGHTS
As a resident of California, you have certain rights, such as:
Right to access personal information. You may be entitled to receive the specific pieces of your personal information we have collected in the 12 months preceding your request.
Right to data portability. You may be entitled to receive a copy of your electronic personal information in a readily-usable format.
Right to know. You may be entitled to receive information regarding the categories of personal information we collected, the sources from which we collected personal information, the purposes for which we collected and shared personal information, the categories of personal information that we sold and the categories of third parties to whom the personal information was sold, and the categories of personal information that we disclosed for a business purpose in the 12 months preceding your request.
Right to deletion. You may be entitled to request that we delete the personal information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need to keep such information, such as for our legitimate business purposes or as required to comply with applicable law.
Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your personal information to third parties for monetary or other valuable consideration. What is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information as we understand it.
You may freely exercise these rights without fear of being denied goods or services. If you are a California resident and would like to exercise one of your rights, please email us at . Please note that California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We (or third parties we engage to assist us) may ask you to provide certain information to us in order for us to verify the request.
In addition to these rights, pursuant to California’s “Shine the Light” law, California residents who share personal information with us have the right to request and obtain from us once per year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you would like to exercise this right, please use the contact information listed in this section to contact us.
10. Additional Topics
B. International Data Transfers. You agree that all personal information collected via or by TPA may be transferred, processed and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or on the servers of our service providers. By providing information to TPA, you explicitly consent to the storage of your personal information in these locations.
Questions or Concerns?
If you have any feedback, questions, or concerns regarding privacy, please send a detailed message to firstname.lastname@example.org.