Effective November 1, 2022
1. Scope of This Policy
2. Agreement to Terms
3. Information We Collect
We may collect the following categories of personal information (a) directly from you (such as when you create an account, contact us, complete a survey or registration form, or when you make a purchase), (b) from third parties such as social media networks, (c) from the device and browser that you use to access the Service, and (d) from cookies and similar technologies.
We may collect your name, email address, account username and password, postal address, and phone number.
Financial and Transactional Information
We may collect payment details such as credit or debit card information, billing and shipping address, and order history.
We may collect information you post to the site, such as product reviews. If you complete a survey, we also collect your survey responses.
We may also draw inferences from the information that we collect that reflect your preferences, characteristics, and interests.
We may collect device information when you use our Service. Device information may include unique personal identifiers, online identifiers, IP address, geolocation information, browser type, device type, and access times.
We may collect information concerning your interaction with the Service, including when you access the Sites and your browsing activity on the Sites (such as which pages you visit, in what order, and for how long). This may also include “traffic data” or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Site and App.
We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on the Site are generally divided into the following categories:
- Strictly Necessary Cookies. These are required for the operation of the Sites. They include, for example, cookies that enable you to log into password-protected portions of a Site. These cookies are session cookies that are erased when you close your browser.
- Analytical/Performance Cookies. These allow us to recognize and count the number of visitors to a Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located).
We also use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. Google provides users with the ability to prevent their data from being used by Google Analytics—learn more by going to https://tools.google.com/dlpage/gaoptout.
- Functional Cookies. These improve the functional performance of the Sites and make them easier for you to use. For example, cookies are used to remember that you have previously visited a Site and asked to remain logged into it (e.g., this saves your username). These cookies qualify as persistent cookies because they remain on your device for use during your next visit to the Site. You can delete these cookies as detailed below.
- Marketing Cookies. These record your visit to the Sites, the pages you have visited, and the links you have followed to recognize you as a previous visitor, and to track your activity on the Sites and other websites you visit. These cookies are used to display ads on other websites based on your visits to the Sites and other online activity. These cookies qualify as persistent cookies because they remain on your device. You can opt out of these cookies through our cookie banner. If you opt-out, you will need to apply these opt-out settings in each browser and device from which you wish to opt out. If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.
We also use third parties to provide certain features or functionality through the Service. For example, we use Shopify to power our online stores. You can learn more about Shopify’s cookies at https://www.shopify.com/legal/cookies.
You can also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Site, however, you might not be able to access or use important functions or features of our Site, and you may, for example, be required to re-enter your log-in details.
At this time, TLGRP does not recognize automated browser signals regarding tracking mechanisms, which may include “do-not-track” instructions.
5. Children’s Privacy
The Service is not intended for users under the age of 13 and TLGRP does not knowingly collect personal information from individuals under the age of 13. If you are aware of, or suspect that, someone under the age of 13 is using the Service without permission, please notify us immediately by contacting us as detailed in the How to Contact Us section below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.
6. Our Use of Personal Information
We collect and use your personal information for the following purposes:
- Providing the Service to you and providing services requested by, or reasonably anticipated within the context of our relationship with, you;
- Managing our relationship with you;
- Responding to your inquiries or requests, and requesting feedback;
- Administering promotions, events, or surveys;
- Providing promotional material or other marketing materials that we believe will be of interest to you;
- Tailoring advertisements to what we or our advertising partners believe may be of interest to you (including working with our advertising partners to display advertisements on third-party websites that you may visit);
- Analyzing use of our Sites;
- Keeping track of your shopping cart;
- Keeping track of your login username and password;
- Personalizing the Sites (e.g., displaying your name when you login to a Site);
- Detecting security incidents and protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible;
- Complying with legal and regulatory requirements.
7. Our Disclosure of Personal Information
We may share your personal information with the following third parties:
- Service providers, including hosting providers and IT outsourcing, payment processors, contact management software providers, customer relationship management providers, marketing providers, and warehousing, shipping, logistics and order tracking and fulfillment providers. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
- Other users when you post a product review or comment.
- Advertising networks, to provide you with marketing that we or our advertising partners believe will be relevant to you.
- Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
- With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
- Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.
8. Your Privacy Choices
If you no longer want to receive our newsletter, emails, or other marketing communications, you may unsubscribe at any time by following the unsubscribe options in the communication itself or by emailing us at the contact information below under How to Contact Us.
To opt-out of text messages, you may text “STOP” in reply to any TLGRP marketing text message.
Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or purchases placed through the Sites.
By logging into your account, you may view, update, and/or delete certain information associated with your account (e.g., name and postal address). You may also contact us at email@example.com. We may maintain information associated with your account after you cancel for our internal purposes.
We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.
You play an important role in keeping your information secure. You should not share your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at the contact information in the How to Contact Us section below.
10. Additional Disclosures for Residents of California
To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section Information We Collect above.
We collect this personal information, as further described in the Our Use of Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.
We may share personal information with the third parties listed above in the section Our Disclosure of Personal Information. Below, we have provided more detail regarding the two ways we share your personal information: (a) “sales” of information and (b) general disclosures of information for a business purpose.
“Sales” of Information
We have marked “sales” in quotation marks because a “sale” under California law broadly includes any disclosure of information in return for any value. This value does not need to be monetary, like in a traditional sale. For example, a “sale” can be when a business provides information collected through cookies to an advertising network that it has hired to promote its own ads—but then the advertising network is able to use the cookie data provided for its own purposes, outside of this particular business relationship.
TLGRP does not share personal information in exchange for monetary payment, however, we use advertising networks to help us improve your advertising experience (such as serving advertisements on our behalf across the Internet and providing analytics services). Sharing personal information with the third-party provider while using these tools may fall within the definition of a “sale” of personal information under California law.
In the past 12 months, we may have provided Device Information, Internet Activity, and Inferences to Advertising Networks.
We do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.
Disclosure of Information for a Business Purpose
To manage our business and provide services to you, we sometimes share personal information with third parties. These third parties cannot further collect, sell, or use the personal information we share with them except as necessary to perform our purposes, as instructed by us.
In the past 12 months, we may have disclosed the following categories of personal information to the following third parties for our operational business purposes:
- Identifiers – Service Providers
- Financial and Transactional Information – Service Providers
- Inferences – Service Providers
- Device Information – Service Providers
- Internet Activity – Service Providers
Under California law, you have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the information will be used. You have the right to access a copy of the categories and specific pieces of personal information about you that we collect, use, disclose, and/or sell, and the right to ask us to delete or anonymize your personal information, subject to some exceptions. You also have the right to opt-out of the sale of your personal information. Finally, you have the right to be free from discrimination for exercising your rights.
You may exercise your right to opt-out of “sales” by clicking this link and following the instructions: Do Not Sell My Personal Information.
If you wish to exercise the right to access or delete your information or have any questions or concerns regarding the processing of your personal information, please contact firstname.lastname@example.org with the subject line “California Privacy” so that we can get your email to the right team. We will respond to your request consistent with applicable law.
Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. If we possess appropriate information about you (e.g., name, email, address), we will attempt to verify your identity using that information. If it is not reasonably possible to identify you, we may not be able to respond to your request.
To use an authorized agent to make a request on your behalf, we may need the authorized agent to provide proof that you gave the authorized agent signed permission to submit the request on your behalf. We may also require you to verify your identity directly with us.
11. Additional Disclosures for Residents of the European Union (EU) and the United Kingdom (UK)
This section provides additional information for residents of the EU and UK.
As a US company, most of our operations are conducted in the United States and in order to provide the Service, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, and where applicable, we implement the standard contractual clauses approved by the European Commission.
Retention of Your Personal Information
We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise required or permitted by law.
Legal Basis for Processing Your Personal Information
Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in the Our Use of Personal Information section above, including: (i) as may be necessary to perform a contract with you; (ii) as necessary to comply with a legal obligation; (iii) consent (where consent has been provided as appropriate under applicable law); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Service).
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.
As available and except as limited under applicable law, individuals in the EU and UK have the rights described below:
- Access. You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
- Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
- Deletion. You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such information to comply with a legal obligation or to establish, exercise, or defend a legal claim.
- Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
- Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise, or defend a legal claim.
- Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information based on your consent before the point in time when you withdraw your consent or processing of your information based on other legal bases.
Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at email@example.com with the subject line “EU Privacy” so that we can get your email to the right team. We will respond to you request consistent with applicable law.
If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.
12. Links to Other Websites
For your convenience, we may link to third-party sites and services, or otherwise display third-party content through the Sites to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.
14. How to Contact Us