Tolam Earth, Inc. recognizes that privacy is important and is committed to maintaining the privacy of personal information collected at this website and on our mobile application (collectively “website”). Unless you have “opted out” of receiving direct marketing contacts (as described below), when you provide any of the information described in this Privacy Notice (including information that may be automatically generated), you consent to the use and disclosure of that information as described by this statement. This Privacy Notice describes the personal information that Tolam Earth collects and the uses that Tolam Earth will make of that personal information.
Information we collect and how we use it:
“Personal Information” is information that identifies you as an individual. We may collect personal information that identifies you as an individual, such as:
- Your first name and your last name;
- Your postal address (including billing addresses);
- Your e-mail address;
- Passwords and reminder questions/answers.
Tolam Earth collects personal information when you participate in various opportunities that we provide, for example:
- When you create an account on the website;
- When you register for communications or other subscriptions through this website, Twitter, Facebook, Instagram or any other digital media, or social media application;
- When you make a request;
- When you participate in a contest, promotion, sweepstakes, survey or other promotion; and
- When you participate in a blog or forum.
We may combine personal information that we collect about you with personal information you provide to us through other sources, such as our third-party payment applications. We will use the combined personal information in accordance with this Privacy Notice for as long as it is combined.
Other Information We Collect
“Other Information” is any information that does not reveal your specific identity or relate to you as an identifiable individual. Other Information is anonymous data.
Other Information includes:
- Browser information;
- Information collected through cookies, pixel tags and other technologies;
- Aggregated information;
- Usage preferences; and
- Physical location.
How We Collect Other Information
Tolam Earth and Tolam Earth’s third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser or mobile device;
Certain information is collected by most browsers and devices, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system version, device manufacturer and model and Internet browser type and version.
- Through your use of a mobile application.
When you download and use a mobile application, we and our service providers may track and collect mobile application usage data, such as your location, or the date and time the mobile application on your device accesses our servers and what information and files have been downloaded to the mobile application based on your device number.
- Through your use of a mobile application, connected device or vehicle, including unmanned aerial vehicles.
The physical location of your device and its associated date and time is collected by satellite, cell phone tower, Wi-Fi signals or other technologies. We may use your device’s physical location to provide you with personalized location-based services and content. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our partners may not be able to provide you with the applicable personalized services and content.
- From you.
Information such as your location as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site or mobile application.
- By aggregating information.
Aggregated Personal Information does not personally identify you or any other user of the website. For example, we may use Personal Information to calculate the percentage of Tolam Earth clients or interactors who have a particular telephone area code or who use an Android device or an iOS device.
How We Use and Disclose Other Information
Because Other Information does not personally identify you, we may use and disclose Other Information for purposes of improving your experience and for any other legal purpose. If we are required to treat Other Information as Personal Information under applicable law, then we use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Notice.
In some instances, we combine Other Information with Personal Information, such as combining your name with your geographical location. If we combine any Other Information with Personal Information, the combined information will be treated by Tolam Earth as Personal Information.
Automatically Collected Information
We may passively collect information that is automatically sent to us by your web browser or your internet service provider. This information typically includes your domain name, your username, and your numerical IP address. The amount of information sent by your web browser depends on its settings. Please refer to your browser if you want to learn what information it sends. We use this type of information to see which web pages you visit at our website, which website you visited before coming to our website, and where you go after you leave our website. We can then develop statistics that help us understand how our visitors use our website and how we can improve it.
When you submit a question or a suggestion using this website, you will be required to provide information that we need to complete your request, including your name and email address. We may have collected similar information from you in the past.
Cookie Generated Information
We may actively obtain information about you by installing a marker on your computer commonly called a “cookie”. Cookies enable us to know you by a computer-generated, unique identifier. By providing you with a unique cookie, we are able to create a database of your previous choices and preferences, and in situations where these choices or preferences need to be collected again; they can be supplied by us automatically, saving you time and effort. Your computer may be specially configured to reject cookies; please refer to your browser for more information. Many websites of companies associated with Tolam Earth will allow you to visit without accepting cookies, but some features of our websites may not work properly if you choose to reject cookies.
User Generated Information
We collect information at this website when you contact us and when you respond to surveys, questionnaires, or other requests that we might make available. If you provide us with your e-mail or e-mail us directly, you are voluntarily releasing the content of your e-mail to us (including your e-mail address). If you answer questions we placed on the website page or a social media site, you are also voluntarily releasing that information to us. You may decide not to answer any questions presented to you at our website or on a social media site; if you do, you may still continue your visit, but we may elect not to provide you with services, opportunities, responses or features related to the questions you choose not to answer.
How Information is Used and Shared
We may use Personal Information for one or more of the following purposes and relying on the following legal basis:
- Purpose: Respond to your inquiries and provide support for your use of the website and Tolam Earth’s products; collect your suggestions, and fulfill your requests, such as to send you e-mail alerts, and contact you to answer any questions to the extent possible. Legal Basis: Our legitimate interest in fulfilling your requests and communicating with you.
- Purpose: Send you important information regarding our products, affiliated products, services, maintenance issues, the website or terms, conditions, and policies and/or other administrative information. Legal Basis: Our legitimate interest in advertising our products or services, or where necessary, to the extent you have provided your prior consent, and to inform you of changes that are important to your participation or relate to additional security measures.
- Purpose: Complete and fulfill your request or inquiry, for example, to communicate with you regarding your questions about our products, to answer to your questions, and to provide you with related service and assistance, if any. Legal Basis: Our legitimate interest in fulfilling your requests and communicating with you and fulfilling any contract/obligation we have entered into with you.
- Purpose: Allow you to participate in surveys, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your personal information, so we recommend that you read these rules carefully. Legal Basis: Consent or explicit consent (if required under applicable law) or our legitimate interest in conducting the survey or research based on its stated goals (where no special categories of Personal Data are in scope).
- Purpose: Allow you to communicate and interact with others through the website and through a portal or other group communication platform we might provide (for example, through a blog, dashboard, message board, messaging functionality, chat functionality, profile or other social media). Legal Basis: Our legitimate interest in hosting and maintaining such a community for the benefits of its members, as well as in order to inform you of program changes that are important to your participation or relate to additional security measures.
- Purpose: Enable our business purposes, such as data analysis, audits, researching and developing new products and services, enhancing this website and our products, improving our services, developing new products, identifying usage trends and determining the effectiveness of our promotional campaigns. We may analyze aggregated demographic information and personal information for historical, statistical, or scientific purposes, or we may store the personal information for your convenience should you return to this website in the future. Legal Basis: Our legitimate interest in providing online content and a functioning website to our customers and prospective customers regarding our service offering and related information and our legitimate interest to offer innovative services and products to our users and customers, or where we seek your consent.
- As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and for any legal purpose (other than credit information); (c) to investigate security breaches; (d) to respond to requests from public and government authorities; (e) to enforce our terms and conditions; (f) to protect our operations; (g) to protect our rights, privacy, safety or property, of you or others; and (h) to allow us to pursue available remedies or limit the damages that we may sustain.
In the course of any of these activities, we may transmit any of the information we have collected with affiliates or third parties. We may disclose your information to companies and individuals we employ to perform business functions on our behalf such as developers and service providers who agree to maintain the same privacy level as we do. An example of a third party that could receive your personal information is a data processing contractor that operates computer systems on our behalf or a company with whom we transact business or associate with for the purposes of aggregating and analyzing demographic information, offering certain products, services, or promotion event or facilitating a product sale.
Additionally, we might establish a business relationship with advertising partners who help us to install the analytics and advertisements in our products. We may also connect our products to social networks such as Facebook and Twitter, with which we share information.
To serve you better, we may combine information you give us online, in person or through direct mail. We may also combine that information with publicly available information and information we receive from or cross-reference with affiliates or third parties, including providers of third-party cookie and other third party browsing and use data.
We use this combined information to enhance our products and personalize the experience of you and others with us, and to recognize our customers so that we can communicate with you directly about our products and services that may be of interest to you, and for other promotional purposes.
By using this website, you agree to the terms of this Privacy Notice. By agreeing to the terms of this Privacy Notice, you are consenting to our continued use of previously collected information under the terms of this Privacy Notice.
The California Consumer Privacy Act (“CCPA”) gives California residents the right to opt out of the “sale” of their personal information. Tolam Earth does not sell Personal Information in the traditional sense; that is, we do not generate revenue from disclosing your data. However, in order to provide you with the services or information you request, we may share information with third parties, or they may automatically receive certain limited information associated with you as part of your use of our services, as described above. We also may share information, including contact information, with third parties as set forth in this Privacy Notice, which might be considered a “sale” under California law.
California Consumers who wish to opt out of the sale of their Personal Information may opt out as described in the section titled “Opt Out” in this Privacy Notice or email us at privacy@Tolam.io.
We may use all information collected at this website for direct marketing and e-marketing purposes including the sharing of the information with our affiliates or third parties unless you specifically request that it not be used for that purpose.
Links to Other Sites
For your convenience, our website may contain certain hyperlinks to other websites as well as to third party websites. This Privacy Notice applies only to information collected on this website and not to information collected on linked sites. We encourage you to be aware when you leave this website and to read the privacy statements of each and every linked site that collects your personal information.
We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities. Our website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this website or through any of its features, register on the website, make any purchases through the website, use any of the interactive or public comment features of this website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@Tolam.io.
Privacy Information for California Residents
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the CCPA).
Categories of Personal Information We Collect. Throughout this Privacy Notice, we discuss information we collect from and about users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. Depending upon the types of services you use, the categories we collect are:
Customer Records Information, including personal and online identifiers (such as name, address, email address, device ID);
- Financial data (such as payment information);
- Internet or other network or device activity (such as information related to your browsing history and the device(s) you use to access the website);
- Geolocation information (e.g., your city and state inferred from IP address);
- Demographic information (e.g., such as age, and gender);
- Other information that identifies or can be reasonably associated with you.
Use of Personal Information. We may use, or disclose the personal information we collect for one or more of the following legitimate business purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to make a purchase or ask a question about our products or services, we will use that personal information to respond to your inquiry.
To identify business opportunities for third party partners.
- To provide, support, personalize, and develop our products and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries.
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or when we notify you of other uses at the time of collection, or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tolam Earth’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Tolam Earth is among the assets transferred.
We may share or disclose such aggregate or anonymous information with any third party, including advertisers and affiliates.
Depending on the circumstances, we may share any of the above categories of information we collect with: business partners to provide you with services that you request; service providers; other parties, including government entities, when required by law or to protect our users and services; or in connection with a corporate transaction. In addition, we may share commercial information and financial data, including your payment information, with payment processors, and we share device information and identifiers and internet or other network or device activity with entities that provide content and functionality. See the above sections for more information.
Notice of Right to Opt Out of Sale of Personal Information.
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include when we share your information with third parties to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior, to deliver targeted advertising on our site or on other services.
We may provide the following categories of information to third parties for these purposes:
- For sharing with third parties to send you relevant business opportunities, ranging from possible venture partnerships to employment opportunities: contact and account registration information; demographic and statistical information, customer records information and user-generated content, and geolocation.
If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may submit a sale opt-out request by emailing us at privacy@Tolam.io.
Your California Privacy Rights
If you are a California resident, the CCPA provides you with certain rights regarding the information we have about you. Specifically, the CCPA allows you to request:
- Information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Privacy Notice.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
We will consider all requests and respond during the applicable time period. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information or to comply with a legal obligation. Depending on the sensitivity of the information sought, we also may take steps to verify your identity before responding to a request, which might include, at a minimum, verifying your name, email address, and date of birth. You are also permitted to designate an authorized agent to submit certain requests on your behalf. An authorized agent must have a signed, written permission from you or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
Additionally, exercising your deletion rights may mean that you may no longer be able to use portions of Tolam Earth’s service that require personal information to function (e.g., if you register for an account, you cannot delete your username and password if you want to maintain your account).
If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at privacy@Tolam.io.
Shine the Light Disclosures. If you reside in California, you may request certain general information regarding our disclosure of personal information during the preceding year to third parties for their direct marketing purposes. To make such a request, please write to us at privacy@Tolam.io.
Privacy Information for Nevada Residents
Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. In some circumstances, we may share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you. This sharing may qualify as a sale under Nevada law. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of “sales” activity emailing us at privacy@Tolam.io. Please note we may take reasonable steps to verify your identity and the authenticity of the request.
Additional State Privacy Rights
Colorado, Connecticut, Virginia, and Utah each provide their residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
Colorado, Connecticut, and Virginia also provide their residents with rights to:
- Correct inaccuracies in their personal information.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights, please send an email to privacy@Tolam.io.
How Long We Keep Your Personal Information
We may retain your Personal Information for a period of time consistent with the original purpose of collection or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
For more information on data retention periods, please send an email to privacy@Tolam.io.
“Do Not Track” Signals
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide requested services or information to you;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
We use commercially reasonable methods consistent with industry practice to protect your personal information from unauthorized access or disclosure. While we consider these policies and procedures to be adequate, there is still a risk that your personal information could be misappropriated. No method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee the absolute security of your Personal Information. If you have any questions about security on our site, you can send an email to us at email address specified below.
Changes in this Privacy Notice
We reserve the right to modify this Privacy Notice at any time, so please review it frequently. If we make material changes to this notice, we will notify you here, by e-mail, or by means of a notice on our home page.
If you do not want us to use your Personal Information as described in this statement, please contact us at privacy@Tolam.io. Please note that we will not be able to process questions or contact you without your Personal Information.
Your Personal Information might be stored and processed in any country where we have operations, property developments, or where we have engaged a service provider, including the United States, which may have different data protection rules than in your country.
If you are located in the European Economic Area (“EEA”): Some non-EEA countries are recognized by the European Commission (“EC”) as providing an adequate level of data protection according to EEA standards (see the full list of countries). For transfers from the EEA to countries not considered adequate, please contact us to work with you to put in place adequate measures.
If you have any questions, comments, or would like to request access to the information Tolam Earth has gathered about you at this website by contacting privacy@Tolam.io.
Information Request Center
Attention: Privacy Lead
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