TYLT VENTURES, LLC AND TYLT LABS, LLC (collectively “TYLT”, “We”) are committed to the protection and proper and legal use of our customers’ personal information and data.  We respect the privacy of individuals who use this Web site (“Site”) and the content and services available on the Site (“Services”).  As such, we’ve designed the Site and Services with your privacy in mind.  This Web Site Privacy Policy (“Policy”) describes how we obtain, use and disclose nonpublic personal information about you to others in connection with the Site.  As used in this Policy, the terms “we” and “us” refer to TYLT VENTURES, LLC AND TYLT LABS, LLC a Delaware corporation and www.tylt.com (hereafter “we” “us” “our”).  You agree that you will be subject to the terms of this Policy if you access or use this Site or register for or use any of the Services.   If you have any questions or concerns, please contact us at [email protected] .

 

HOW WE OBTAIN AND USE INFORMATION ABOUT YOU

We may obtain information about you from several sources in connection with this Site:

• When You Use or Register for Services. When you use or register for the Services (some of the Services may require that you register and others do not), we collect the information that you provide to us about yourself, such as your name, address, e-mail address, credit card number, debit card number, and telephone number.  We also collect any optional information you elect to tell us about yourself, such as your age, occupation, gender, interests, computer uses and preferences. 

• How We Use Your Information?   We may use your information for billing and internal tracking purposes, to respond to your requests for Services, to communicate with you, to determine what goods and services may be of interest to you, and to make your use of our Services more rewarding. 

• Your IP Address. We may note and store your IP address when you visit our Site.  An IP address is a number that is automatically assigned to your local network or your computer when you use the Internet, depending on your Internet Service Provider’s (ISP) setup.  IP addresses are not linked to personally identifiable information.  We use IP addresses to analyze trends, administer our Site, track user movements, and gather demographic information for marketing purposes.   

• Cookies. We may place “cookies” on your computer to track your use of our Site.  A cookie is a piece of data that is stored on your hard drive and takes up very little room on your system.  It helps us customize our Site for you and make its navigation easier, and estimate the number of persons that use our Site and determine which areas of our Site are the most popular.  Unless you are registered with us, the cookie does not provide us with any personally identifying information about you, such as your name or address. Third party advertisers and Service Providers (as defined below) may also place cookies on your computer; we do not have any control over these cookies or responsibility for information collected through them.

• Web Logs. We may also utilize web logs to track aggregate information about how the Site is being used.  Web logs track anonymous user information, including the number of visitors to our site, operating systems, IP addresses, and browser type. Unlike cookies, web logs are maintained only on our servers and do not store or place anything on the your computer.

• Web Beacons. Web pages on our Site, including third-party Advertisements/Offers (as defined below), may contain non-visible electronic images (called “web beacons,” “single-pixel GIFs” or “1×1 GIFs”) that allow the Site to access cookies or to count users who have visited particular pages on the Site. HTML-formatted email messages (messages that include graphics) may also contain web beacons, which allow us to determine which email messages were opened and whether a message was acted upon, as well as access cookies and count users.

• Accessing the Site From Online Banner Ads. If you come to the Site from an online banner ad on another site, an anonymous identification number may be passed to the Site.  This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising campaigns.

• When you purchase products or services from our Site, you are entering information into a Web site controlled and operated by a Payment Service Provider on our behalf. You will be interacting directly with the Payment Service Provider.  The Payment Service Provider may collect and use information about you in a way that is different from this Policy.  We encourage you to read the Payment Service Provider’s privacy statement.  The Service Provider may provide us with information about you, in which case our use of such information will be subject to this Policy.

• Surveys, Contests and Promotions. We may seek information from you from time to time in connection with surveys, contests, promotions or special offers.  Your participation in these activities is completely voluntary.  The information requested may include contact information (such as name and address), demographic information, preferences and interests.  We may use this information to fulfill your requests for Services, to contact you, and to identify promotions by third parties that you may find of interest.

• Passwords. You may provide us with identifying information, such as a password, in order to access certain Services. Your password will be encrypted and not visible and/or readable by any employee of ours. Do not divulge your password to anyone.  We will never ask you for your password in an unsolicited phone call or in an unsolicited email.  To increase your privacy, be sure to sign off your user account and close your browser when you have completed your use of the Site and Services, particularly if you share a computer with someone else or use a computer in a public place.

• Advertisements/Offers. Third parties may provide us with advertisements, services, promotions, and other offers (“Advertisements/Offers”) for persons who visit our Site or use our Services.  We may analyze the information we have about you (e.g., from your registration or from cookies), and use that information to display, email or mail the Advertisements/Offers we believe may be of interest to you. Except as indicated below, we do not share your personally identifying information with such third party advertisers. 

 

SHARING INFORMATION WITH OTHERS

 

We do not sell or provide the personally identifying information that we obtain about you through this Site to third parties unless you request or permit us to do so or the disclosure is permitted or required by law.  Some of the circumstances under which we may provide information about you are described below.

• Your Profile. Certain information in your profile is intended to be public – in particular, user name, school, gender and photo. This information is viewable by the public (including people who are not users of the Site) and by other users. These disclosures are at your own risk.

• User Generated Content (UGC). If you upload videos and other content to the Site, you may be revealing otherwise private information about yourself or other people. Any videos and other content that you submit to us may be redistributed through the internet and other media channels, and may be viewed by other users or the public.

• With Your Permission. We may forward personally identifying information about you to others at your request (e.g., to respond to Advertising/Offers, to process a transaction by you, or to verify your identity to the third party). These disclosures are at your own risk.

• We may permit third parties to mail or email Advertisements/Offers to you in a fashion that prevents them from learning personally identifying information about you. (You will have the opportunity to opt out of receiving such Advertisements/Offers when you provide personally identifying information to us and when such Advertisements/Offers are sent to you.)  For instance, we may require that the third party provide the Advertisement/Offer to us or to a Service Provider, then we or the Service Provider would perform the actual mailing or email.  We will not provide personally identifying information about you to such a Service Provider until it has agreed to keep such information confidential and to use it only for the specific purpose that was authorized.  If you respond to an Advertisement/Offer from a third party, that party may collect and use information about you in a way that is different from this Policy; we encourage you to read the privacy statement of any such third party.

• Public Forums. Certain portions of our site (e.g., chat rooms, forums and message boards) may be available to the public or other Site users.  If you provide information at such locations, your disclosures will not be private. These disclosures are at your own risk.

• Anonymous Data. We may disclose aggregate user statistics and demographic information to third parties in order to describe our Services to current and prospective shareholders, investors, advertisers, and other third parties, and for other permissible purposes.  That data will not contain any personally identifying information about you.

• Surveys/Promotions. If you participate in surveys, promotions or contests conducted at our Site, we may share information with others in the manner described in the surveys, promotions or contests or as described in the previous paragraph (Anonymous Data) or as required by law.  We may post the names and schools of contest winners on our site. Unless otherwise indicated, those activities will be subject to this Policy.

• Service Providers. To the extent necessary to make the Site and Services available to you, we may provide information to vendors (“Service Providers”) who provide operational services related to the Site and Services, such as hosting, telecommunications and billing.

• Law Enforcement and Legal Action. We may provide information to law enforcement agencies and other appropriate third parties as required or permitted by law or if we believe that a crime has been or may be committed involving you, your account, the Site or the Services or if we believe that disclosing information will help identify, contact, deter or bring legal action against someone who may be violating the Terms of Service or injuring or interfering with anyone’s rights, property, or personal safety.

• Technical Problems. We may disclose information if we believe doing so is necessary to detect, prevent, repair or otherwise address any technical problems such as software bugs.

• Change of Ownership. If the ownership of all or substantially all of the Tylt business, or individual business units owned by us, were to change, your user information may be transferred to the new owner so the service can continue operations. In any such transfer of information, your user information would remain subject to the pre-existing Privacy Policy until you are notified of any changes.

 

INFORMATION SECURITY

 

Security Measures.  Security is an important feature of our Site.  We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information.  However, no data storage, transmission or safeguards can be guaranteed to be secure.  Thus, we do not warrant the privacy or security of any information you provide to us (or to any Service Provider), and you do so at your own risk.   However, we do use commercially standard malware software and encrypt your sensitive credit card information using Secure Socket Layer technology.   Transactions are processed through a gateway provider and NOT stored on our servers. 

 

Our Employees.  

Our employees and Service Providers are given access to personally identifiable information only to the extent they have a need to know such information.

 

When You No Longer Use Our Site and Services.  

If you discontinue using our Site and Services, we will continue to treat and protect personally identifiable information about you in accordance with this Policy.  Although we may delete such information from our records after a period of time, we reserve the right to maintain such information.

 

How You Can View and Change Your Personal Information.  

You can review the personally identifiable information we maintain on you and make changes or corrections, or delete your account, on the Account Information Page. Note that, for security reasons, you cannot change your email address.

 

OTHER TERMS

Measures We Have Taken For the Protection of your Information:

 

• We maintain accurate internal lists of any personal customer information and only utilize same for the purposes stated herein. We keep such lists in places that are clearly identified internally and under secure systems.
• We utilize a Data Protection Officer who can be reached at any time by the public at [email protected]
• All decision makers involved in data security at TYLT are aware of all of our Privacy Rights and protocols.
• Our system security protecting your data is updated regularly.
• We train our internal staff who are responsible for data and information security and systems.
• Any of our sub-processors for data are aware of our requirements and systems for data.
• Part of our internal systems and controls includes protocols for the public dissemination of any data breaches, if any, promptly and with sufficient detail.
• Customers have easy access via [email protected] at any time to request their personal information, update or change such information, request DELETION of any personal information on our systems or stop us from using such information at any time.
• We maintain systems to auto-delete personal information if not used after some time.
• We ask all third parties to adhere to our Privacy Rights rules and policies.
• We object to any third party PROFILING of our customers personal information or data.
• We will always ask for consent to use your data.
• We constantly update our customers on any and all changes in our Privacy Rights policies, if any.

 

Links.  

This Site contains links to other sites.  We encourage you to read the privacy statement of every Web site that you visit.   When you click on a banner ad of a third party linked to our Site, for example, you will leave our Site and will be interacting directly with the third party.  That party may collect and use information about you in a way that is different from this Policy.  Although the third party will not receive personally identifiable information about you from us without your consent, it may know that you meet the criteria it sets for the distribution of its Advertisements/Offers on our Site.   Also, whenever you click on a link (on our Site or any other Web site), the Web site to which you are directed may be able to determine the Web site from which you came.

 

Privacy Infringement by User Generated Content (UGC). 

If you feel that your privacy is infringed by any UGC, please email us at [email protected]  and provide the following information:  the location (URL or other description) of the infringing material on our Site; your address, telephone number, and email address; where in the UGC you appear (for instance, specify how many minutes and seconds into the work you appear and describe the scene); a statement by you, made under penalty of perjury of the laws of the State of California and of the United States, that the above information in your notice to us is accurate and that you are (or are authorized to act on behalf of) the person whose privacy is infringed. We reserve the right to require that you confirm this information in writing (by mail or fax, for instance), with a physical signature.

 

Other Third Party Content. 

We may display other third-party on the Site, such as news stories, video clips from television networks and the like. If you feel that your privacy is infringed by any such content, please notify us by following the procedure in the preceding paragraph regarding UGC.

 

Toolbars and Other Access to Site. 

We may make the Site or some of its features accessible via toolbars or other means. Your use of the Site in such ways is subject to this Policy.

 

Services and Advertisements/Offers from Third Parties.  

Some Services or Advertisements/Offers are provided by companies other than us.  If you provide them with information, their use of that information will be subject to their privacy policy, if any, and will not be subject to our Policy.  If you use such a Service or accept an offer or make a purchase, the third party may be able to identify that you have a relationship with us (for instance, the third party may only have made the offer available through us).

 

Changes to this Policy.  

We may add to, delete from, update, or change the terms of this Policy from time to time.  We may notify you of the changes by mail, email, or by posting a modified Policy on our Site.  Unless stated otherwise, the revised Policy will apply to all information that we have about you, including information collected before the revision. Your continued use of the Site or any Service following such notification or posting will constitute your acceptance of the revised Policy.  Accordingly, please check this Policy regularly for revisions.

 

Consequences of Failure to Provide Required Information.  

If you fail to provide required information you may not be eligible to receive all Services provided at this Site.  In addition, you may not be eligible for promotions such as contests, coupons, special offers, etc. unless you provide certain information.

 

Minors.  

Minors under age 18 are not allowed to register for this Site.

 

Google.  

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en.   

Google, as a third party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

 

We have implemented the following:       

• Demographics and Interests Reporting

We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.

Opting out via Google:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

 

California Online Privacy Protection Act.   

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

 

According to Cal OPPA we agree to the following:   

Users can visit our site anonymously

Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.  Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.

Users will be notified of any privacy policy changes on our Privacy Policy Page and,

Users are able to change their personal information:

• By emailing us
• By calling us
• By logging in to their account
• By chatting with us or sending us a ticket

 

How does our site handle do not track signals?  

We honor “do not track” signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third party behavioral tracking?  

Yes.  It’s also important to note that we allow third party behavioral tracking.

COPPA (Children Online Privacy Protection Act).  

The Children’s Online Privacy Protection Act (COPPA) puts parents in control of their children under the age of 13. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.  We do not specifically market to children under 13.

CAN SPAM Act.  

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

 

To be in accordance with CANSPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

 

YOUR CONSENT

By using this Site or any Services, you consent to this Privacy Policy to having your personal data transferred to and processed in the United States. 

CONTACTING US

Questions.  If you have any questions regarding this Policy, please contact us at [email protected]. You may also contact us by mail at:

685 Cochran Street
Simi Valley, CA 93065, 

Attn: Legal Affairs. 

If you believe someone has gained unauthorized access to, or use of, your account or your personal information, please contact us immediately at that address.

 

Updated  May 23, 2018.