Dated: July 18th, 2018
Tracy Timm, LLC (also “TTL”, “we”, “us” or “our”) own and run the Site [and/or the App] you are currently using.
It’s really important that we protect your privacy, and that you understand your privacy rights as you use our platforms and Service(s).
This Privacy Policy (also the “Policy”) explains the types of information we collect from you or that you may provide us when you use the Service(s). It also explains how we collect, use, store, protect and disclose your information. In addition to your rights to your information.
This Policy does apply to information collected:
(i) by TTL through the Site [or App], and
(ii) in email, text or other electronic messages between you and us while you use our Services.
This Policy does not apply to:
(i) information collected offline, and
(ii) information collected by any third party or through our affiliate sites.
Also, as the use of technology changes our use of new and exciting technology changes as well. We strongly suggest you revisit this Policy from time to time for any updates regarding our use of technology and how it relates to your information.
Please note, if you use our Services that means you agree to this Policy as posted. If you do not agree with this Policy, you must stop using the Services. If you have any questions, please contact us at info@tracytimm.com.
Definitions:
When we use the bolded words in the Policy, they will have the meaning we’ve given in this section. Any word you see bolded in this Policy and not defined here, is defined in our Terms and Conditions of Service; which you can fine [insert specific site link] or in the specific section where it appears.
[“App” means the TTL mobile application.]
“Personal Information” means any information that may identify you directly or indirectly. This could be as simple as your name, address, phone number, social media handles, device information or email-address. This could also include information about you that does not individually identify you (such as how you use our Services) or information about your internet connection and the equipment you use to access our Services. [When you access our Services using a mobile device, we and/or our business partners may also collect information such as the unique device identifier (“UDID”) of your device, identifier for advertisers (“IDFA”), identifier for vendors (“IDFV”), device type, and other technical information. We may also collect information about the device, such as its hardware model, operating system and version, and motion information. Please note, this list is not exhaustive and more specifics around the information we collect is below in Information We Collect. Keep in mind, where an applicable law or statute takes a broader definition with the term “Personal Information” we will use that definition when referring to or defining what “Personal Information” is for the purposes of this Policy.]
“Policy” means this Privacy Policy.
“Service(s)” means any service offered through our Site [or App] offers personal development tools by coaching, presentations, audio, video and webinars. We do this through a many different products or services and through software, apps and this website http://tracytimm.com/.
“Site” will mean http://tracytimm.com/
1. Information We Collect
As you use our Services, the categories of information we collect are your:
• Name
• User name and password
• Physical address
• Occupation
• Age or birth date
• Profession or occupation
• Work History
• Email Address
• Home/work/mobile telephone number
• Postal or physical address
• Credit/debit card information
• Information you input into searches (i.e. salary, location)
• Instagram profile information (when you use Instagram to log-in to our Services or to create an account for our Services)
• Facebook profile information (when you use Facebook to log-in to our Services or to create an account for our Services)
• Any other Internet platform profile information (when you use that platform to log-in to our Services or to create an account for our Services)
• Your activity on our Services (i.e. page views, time in Service, browser types)
• Messages you send and any information included with or in those messages
• IP addresses and other tracking information collected by your use outlined in Section 4 below.
• Device identifiers or Geo-location when using the Services*
[*When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the UDID. From time to time, we may send you push notifications to inform you about events or promotions we may be running. If you want to stop receiving these types of communications, you can turn them off in the applicable “Settings” profile for your device. We may also collect information about where you are located when you are using our Services. We use this data to optimize your connection and suggest customizations (for example, video speeds). We share this information with our data center provider and our advertising partners. If you do not want us to share this information for these purposes, please opt-out by contacting us at info@tracytimm.com.]
2. How We Collect Information
The ways we collect information are:
• Directly from you through registration forms you fill out,
• When you sign up for Services,
• When you post messages or questions,
• As you submit questionnaires and other materials or Content,
• As you use and pay for Services,
• When you report a problem with our Services,
• From records and copies of our discussions with you (including e-mail addresses) if you contact us,
• When you conduct searches,
• When you fill out our screening questions or assessments,
• When you subscribe to our newsletter
• From messages you send to other users of the Service(s),
• Automatically as you use the Services, where it relates to things like usage details, IP addresses, data connections, and information collected through cookies or other tracking technologies,
• From third party business partners or affiliates,
• Billing and collecting payment for use of Services,
• Participating in groups or forums, or
• Registering for newsletter subscriptions.
3. Why We Collect Your Information
Collecting this information enables us to do administrative processing, communicate with you, provide our Services, and meet our legal obligations to you and others. We also want to make your experience the best possible, and collect information to improve our platform and Services. But rest assured, we’ll only ask you for what we need. You can also unsubscribe from our emails at any time, by following the prompt at the bottom of those emails.
4. Cookies and Other Ways of Tracking
As you use our Services, we collect information about your equipment, browsing actions and patterns using automatic data collection technologies. Some content or applications, including advertisements, through the Services are also serviced by a third-party such as Google (including advertisers, ad networks, ad servers, content providers and application providers) also use this technology. The use of these technologies is outline in our Cookies Policy at [insert specific site link].
5. What We Do with Your Information
There are limitations to how we are able to use your Personal Information, under some laws this is referred to as “Processing.” In all instances, we will use your Personal Information in accordance with our Policy. Where applicable, we will also ensure we collect and use (or Process) your Personal Information in accordance with one of the lawful bases outlined below in Section 7.
The specific ways we process your Personal Information is to:
1. Facilitate your communications with other users through groups, forums or chats;
2. Provide you with notices, service related emails or fulfill service requests;
3. Administer, customize, personalize, analyze and improve our Services, technologies, communications and relationships with you;
4. Offer the Services and its contents to you as outlined under any legal agreements with you;
5. Enforce our terms with you to protect the security of our Services;
6. Analyze the demographics, transaction histories, and preferences of our users to better the experience;
7. Offer support for our Services;
8. Comply with all reporting and other legal requirements or proceedings;
9. Perform research and analysis for product development;
10. Communicate with you on all the newest happenings, announcements, maintenance, updates, changes, or offers;
11. Customize marketing to you based on your preferences and requests; and
12. Hire or utilize third party vendors and service providers in connection with our Services.
If any of the above concern you, you may contact us at info@tracytimm.com to remove or deactivate your profile.
6. What Happens if We Don’t Collect Your Information?
You may refuse to provide some or all of your information (including Personal Information); however, keep in mind this may limit the ways in which we can interact with you, including providing you with our Services. For example, we may not be able to give you certain information you’ve requested or tailor your experience with the Services.
7. Our Legal Basis for Collecting Your Personal Information
Under certain laws, TTL must have a “legal basis” (or reason found in the law) for collecting certain types of Personal Information. Where this is the case, some of the basis TTL relies on are:
• Performance of a Contract: Most of the Personal Information we “Process” (i.e. collect & use) will be done so we can perform the terms we have in place with you, based on all of the agreements we have with you, or to facilitate entering into an agreement with you. An example of this would be assessments or questionnaires we send out through our coaching services.
• Legitimate Interest: We may process your Personal Information to further “legitimate interests” we have in running our business. For example, this could include marketing or protecting against fraud. However, information will only be processed strictly to the extent legitimate interests require we do so.
• Compliance with a Legal Obligation: There are instances where laws we are subject to require we Process information to comply with an obligation it imposes. This may happen, for example, where a law requires we keep certain financial records for a period of time.
• Consent: There are instances where we’ll request your permission specifically to process your Personal Information. Where this happens, we’ll ask for your permission before collecting, explain what it is that we’re collecting your information for and only process your information in accordance with the reason we supplied at the time of your consent.
8. Your Rights
You have rights with regard to your Personal Information. You may access your information and ensure that it is correct. You may also opt out of receiving certain communications from us or our partners by emailing info@tracytimm.com If you have any questions, would like access to your information, or need to correct/update your information please contact us at info@tracytimm.com.
Certain countries afford additional rights to its citizen and residents with regard to their Personal Information (for example, those countries who are members of the European Union or the United Kingdom). Depending on where you live, or access the Services, you may have the right to:
• Access any Personal Information we may hold of yours;
• Stop the processing of your Personal Information for use to directly market to you;
• Request a copy of any Personal Information of yours that we may have;
• Request we move your Personal information to another party or service;
• Restrict or limit the way we process your Personal Information;
• Request we delete any of your Personal Information that we may have; or
• Request we update your Personal Information.
Once a request is made, we will reply as soon as possible. But will ensure that responses fall within the time periods outlined in the law applicable to the request. And reserve the right to confirm your identity before we comply. We may charge a reasonable fee to cover any reasonable costs associated with carrying out your request.
Please note, there may be certain exemptions that apply, and would change our obligations should you make one of the requests listed. For example, we may be required to process or keep your Personal Information to comply with law even where you request it be deleted. We may also deny a right where it infringes on the privacy rights of others or violate law.
Also, please keep in mind where you make a request we delete information there may be bits of information left in our systems that does not directly identify you, for example data on your behavior with the Services.
9. How Long We Keep Your Data
The length of time we keep your Personal Information depends on the type of Personal Information and the purposes we’ve specified for collecting it. Where applicable, we ensure your Personal Information is not kept any longer than reasonably necessarily to comply with law or administering the Services. We look at the type of data, sensitivity, need, amount and risk of disclosure when deciding how long is “reasonably necessary.”
10. Sharing Your Personal Information
We do not sell, trade, or rent Personal Information to third parties for direct marketing. However, we may share generic aggregated demographic information (such as the total number of visitors) not linked to Personal Information with our business partners and trusted affiliates. Anyone we disclose your information to is expected to treat it with the same care we do, and comply with all laws related to your privacy.
We may also:
• Share your Personal Information with business partners or affiliated applications so they can carry out their services to TTL.
• Use third party service providers to administer activities (such as advertising) on our behalf but only disclose information for the limited purpose of performing those services.
• Disclose Personal Information where our assets are being purchased or sold, where we are being acquired, go out of business, or restructure and the assets we transfer include user information.
• Disclose Personal Information: (i) To fulfill the purpose for which you provide it (for example, to initiate communication); (ii) For any purpose disclosed by us when you provide the information; (iii) To comply with any court order, law or legal process, including a response to any government or regulatory request; (iv) To investigate, prevent, or take action regarding suspected or actual illegal activities or take precautions against liability; (v) If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us or others; (vi) With affiliates or subsidiaries; or (vii) With the public where information is posted to a public forum.
Any Personal Information you voluntarily disclose for posting to the Service, becomes available to the public as controlled by any applicable privacy settings. This may happen if you participate in public forums, chat rooms or webinars. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information. TTL may also retain information after you delete your account if required by law, such information is needed for investigation purposes or for archival purposes.
11. Direct Marketing
From time to time we may send you marketing communications directly. How we do this will depend on what you’ve signed up for, but could include text-messaging, mail, email or other forms. Marketing will be sent in accordance with the applicable laws (for example, CAN-SPAM) and you can request we only make certain communications by emailing. You can also opt-out of our emails by following the “unsubscribe” instructions at the bottom.
12. How We Secure Your Personal Information
We use a variety of security technologies and procedures to secure Personal Information on its equipment or the equipment of third party vendors. When you provide Personal Information we do our best to ensure it’s encrypted via SSL. However, none of these are fail-proof, and we ask for your cooperation in ensuring your information stays safe. Please note we may discard any information: (i) after your account has been cancelled or terminated, (ii) upon your request; or (iii) any time in our sole discretion and in compliance with law, whichever occurs earlier.
13. Collection and Use of Children’s Personal Information
Our Services are not intended for children under 13 years of age. If you are under 13, do not use or provide any information through our Services. If we learn we have collected or received personal information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@tracytimm.com.
14. Third Party Links
We are not responsible for the privacy practices or the content of third party websites and their use of information will be in accordance with their own privacy policies. Your use of a third party website is at your own risk and we cannot be held liable for any damages, costs, fees or penalties arising or resulting from your use of third party sites.
15. Complaint, Inquiry or Withdrawing Consent
If you have any questions, concerns, or comments about our Policy or practices, please contact us via email at info@tracytimm.com with the words "PRIVACY POLICY" in the subject line. You may also withdraw consent to this privacy policy the same way.
16. Security and Possible Risks
TTL cannot warrant the security of data while in transit to or from our Services. By using a Service, you understand we use commercially reasonable precautions to protect your Personal Information.
17. Applicable Law
Any claim relating to the Services will be governed by the internal laws of the State of Texas without reference to its choice of law provisions, and resolved solely through proceedings held within the State of Texas (Dallas, Dallas County specifically).
18. Notification of Privacy Policy Changes
TTL has the discretion to update this Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. If we make material changes, we will notify you through a notice.
19. Data Transfer
To provide Services to you, your Personal Information will be transferred to, stored and processed in the United States. Your Personal Information may also be processed by staff, agents or vendors operating in India, Philippines and other countries used by our third party suppliers. However, we take steps to ensure your Personal Information is treated in accordance with this Policy. By providing your Personal Information to use Services, you consent to the transfer and processing outlined above.
20. Beta Releases
We sometimes release alpha and beta versions of our products, which are further refined before the release of the final version. Because these products are still in a test phase we may not always catch an unintended privacy issue, despite our efforts. However, we welcome user feedback on any privacy concerns you may have.
21. Privacy Rights for California, North Dakota and Vermont Residents
California. A California resident may request us not to share Personal Information with a third party. Existing California users can provide us with their order ID, name, email address and postal address either by email at info@tracytimm.com. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 1625 North Market Blvd., Suite N 112 or by phone at 800-952-5210.
North Dakota. Pursuant to state law, we will only share information with our service providers and with third parties as required or permitted by law or as permitted by you.
Vermont. We will not disclose information about you with our affiliated companies or with Non-Affiliated Third Parties, other than as required or permitted by law or permitted by you.
PLEASE PRINT AND RETAIN A COPY OF THIS AGREEMENT FOR YOUR RECORDS.
