PRIVACY POLICY

INFORMATION WE COLLECT AND HOW WE USE ITSHARING OF INFORMATIONAUTOMATED DATA COLLECTION / COOKIESPERSONAL DATA RETENTIONPRIVACY AND SECURITYUSE OF AUTOMATED DECISION MAKING AND PROFILINGCHILDRENLINKS TO THIRD PARTY PLATFORMSYOUR RIGHTSYOUR CALIFORNIA PRIVACY RIGHTSYOUR NEVADA PRIVACY RIGHTSADDITIONAL INFORMATION FOR CERTAIN U.S. RESIDENTSINTERNATIONAL DATA TRANSFERSCHANGES TO THIS PRIVACY POLICYGENERAL LEGAL

Welcome to the tranformativ website, www.transformativ.net/  (the “Website”), and the mobile application (the “App”) (the Website and App are collectively referred to as the “Services”). The Services are operated by tranformativ

 (“we,” “us,” or “our”). We believe that the privacy and security of your information and personal data (“Information”) is very important. This Privacy Policy (“Policy” or “Privacy Policy”) explains the type of Information we collect from users of the Services, how that Information is used, how the Information may be shared with other parties, and what controls our users have regarding their Information. We encourage you to read this Policy carefully.

Any updates or modifications to this Policy will be posted to our Website on this page and on the App. By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy.

Our Services are operated in the United States but can be accessed worldwide.

If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), we are subject to the UK General Data Protection Regulation (“UK GDPR”) and the EU General Data Protection Regulation (“EU GDPR”) and are the Controller of your data.

California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.

If you have questions about this Policy, please contact us at  info@transformativ.net

INFORMATION WE COLLECT AND HOW WE USE IT

Types of Information

We may collect the following types of Information through our Services:

(1) “Personal Data” such as your name, e-mail address and phone number, account or mailing address, and other information that can be used to directly identify and contact you (which, in some cases, may include certain Device Information or information from the signature block of your e-mail).

(2) “Device Information” which is information relating to the computer or device you are using when you access our Services, such as your computer’s IP address, your mobile device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.

(3) “Usage Data” which is data related to your use of the Services such as the pages you visit, the sites you use before or after visiting ours, your actions within the Services, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.

(4) “Audio, electronic, visual, or similar information” such as voicemails on our customer service phone line.

As described in more detail below, we collect Personal Data only when you provide it to us but may collect other types of Information whenever you use our Services through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below).

Personal Data

You may enter the Website and browse its content without submitting any Personal Data. However, we will need to collect relevant Personal Data to provide you with certain services offered by the Services, including if you choose to create an account on our website, contact us or otherwise communicate with us in any way, subscribe or opt in to our newsletter, alerts, or other communications, subscribe or opt in to SMS messages, sign up for product waitlists, participate in a contest or promotion, order our products, submit product reviews, questions, feedback or user comments, complete an optional survey, contact customer service or otherwise interact with the Services.

We use the Personal Data that we collect to respond to your requests, communicate with you regarding the Services and our content, send you promotional or marketing communications, guard against potential fraud, provide product information, service your requests and orders, and provide you with the applicable services, features or functionality associated with your submission. When you submit Personal Data through the Services, whether by directly providing it to us upon request or voluntarily disclosing it through comments, you are giving your consent to the collection, use and disclosure of your Personal Data as set forth in this Privacy Policy.

Device Information & Usage Data

Whether or not you submit Personal Data, any time you visit our Services, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and in aggregate form for internal business purposes, such as optimizing the Services, evaluating the popularity of content, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.

Information to and from Social Networks

We may provide functionality that will allow you to connect to our Services through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”). If you connect through a Social Network, we may collect Personal Data from your profile, such as your name, username, and e-mail address, and we will use that Personal Data for the purposes set forth herein. In addition, our Services may offer social sharing features which will allow you to “Share” or “Like” on a Social Network. If you decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network, so you should check the privacy policy of each Social Network before using such features.

Payment Information

Payments submitted in connection with the Services must be made via the Services by credit, debit card, or through alternate payment methods (such as PayPal) where such alternate payment methods are made available as an option. Please note that alternate payment methods may be provided by third parties subject to that third party’s privacy policy. This Privacy Policy does not apply to such third party’s collection and use of your information. Please review the applicable third party’s privacy policy. With regard to credit and debit card payment, all credit and debit card information is provided directly to our third-party payment processor. We do not directly access, handle, or store your credit or debit card information. To submit payment using the Services, you will need to provide us with your contact information (e.g., name, address, email address, telephone number), and your credit or debit card information to our payment processors. Our payment processor will use your credit and debit card information in accordance with its privacy policy. Where online storefront on the Services is hosted or powered by a third party, we encourage you to review any posted terms and privacy policies.

SHARING OF INFORMATION

In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes, provided that we do engage certain third party targeted advertising partners as discussed “Automated Data Collection / Cookies” section of the Policy below. We only share your Information with third parties for the purposes described below. See the “Selling and Sharing” section of this Privacy Policy below under the “Additional Information for Certain U.S. Residents” below for more information.

We contract with companies or individuals to provide certain services related to the functionality and features of the Services, including content streaming, email and hosting services, software development, data management, orders, payment processing, management of forms, quizzes and polls, customer service, returns, live chat, marketing, fraud prevention, product review and questions, and administration of contests and other promotions. We call them our “Service Providers.” We may share your Information with Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Information only for such purposes.

We use Odoo to host our website and to process our orders.

The server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

In certain instances, as with Paypal and Afterpay, which process payments, you may also be directed to a third-party website which is governed by its own privacy policy:

https://www.paypal.com/us/webapps/mpp/ua/privacy-full

https://www.afterpay.com/privacy-policy

We may also share or transfer Device Information and Usage Data in aggregated, anonymized form with or to our affiliates, licensees, partners and Service Providers for administrative, analytical, research, optimization, and security purposes, but no such Information will be linked with your Personal Data or be used to identify or contact you.

Finally, we may share your Information: (i) In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; (ii) When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements; or (iii) In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

AUTOMATED DATA COLLECTION / COOKIES

We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing your Information, collecting Device Information and Usage Data, understanding your use of the Services and customizing the content offered to you on the Services. We may use platforms like Google Analytics to provide aggregated or anonymized information relating to demographics, geography, interests or affinities. Other technologies we may use include:

(1) Cookies. Cookies are text files placed in your computer's browser to store your preferences. We use cookies or other tracking technologies to understand site and Internet usage and to improve or customize the Services and the content, offerings, or advertisements you see on the Services. For example, we may use cookies to personalize your experience on the Services or remember any settings you have chosen. We also use cookies to learn and track how you access and use the Services, including when and how users visit the Services and how popular particular Service pages are and aren’t. Some cookies may be considered “third-party cookies” that allow your browser to talk to third-party websites, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, not accepting cookies may make certain features of the Services unavailable to you.The types of information collected by a cookie and the purposes for which that information is used depend on the type of cookie. We may combine information collected by cookies with other Information. 

(2) Web Beacons. We may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

(2) Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or app developer platforms that use, mobile Software Development Kits ("SDKs") that are incorporated into the Services to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), geolocation information, and other information about your device or use of the Services. A mobile SDK may act as the mobile version of a web beacon (see "Web Beacons" above).

By visiting the Services, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Services through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you. Please note that no such tracking technologies will collect any Personal Data from you unless you choose to submit it to us and that data relating to you individually is not shared with any third parties.


Remarketing and Advertising

From time to time the Services may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including Google Ads and advertising services provided by Meta (sometimes referred to the Meta “tracking pixel”). These services collect information about your visits to and interactions with the Services and other websites and will use that information to target advertisements for goods and services and to display those advertisements on other websites. The information collected may be associated with your personal information.

Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Service and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. We may also enable and implement Google Analytics Advertising Features on the Services. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Service.

For certain Meta advertising services, Meta Ireland is a Joint Controller (as defined in the GDPR) and that information required under the GDPR related to such processing can be found at https://www.facebook.com/about/privacy. We work with Meta and use their advertising services to measure and improve our ads and marketing efforts, as well as to display more relevant advertising to you. For further information on how Meta Ireland processes your personal information, including the legal basis, and the ways to exercise your rights, please visit https://www.facebook.com/about/privacy.

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

Analytics

The Services use third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Services, including when you visit the Services, URLs of the websites that you visit prior to visiting the Services and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content.

For more information on how Google uses this data, visit Google’s Privacy Notice and Google’s page on How Google uses data when you use our partners' sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent Company from using other analytics tools and will not prevent data from being sent to the Service itself or to Google. For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites. You may disable cookies as discussed below, but that may impact your use and enjoyment of the Service.


PERSONAL DATA RETENTION

We retain the Personal Data we receive as described in this Privacy Policy for as long as you use the Services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

PRIVACY AND SECURITY

We take reasonable precautions to protect our customers' Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at  info@transformativ.net

USE OF AUTOMATED DECISION MAKING AND PROFILING

Except to the extent personal data is used by third-party ad networks for online behavioral advertising, neither we, nor service providers on our behalf, engage in profiling or automated decision-making activities. Specifically, we do not use your Personal Data to profile you in furtherance of decisions that produce legal and/or similarly significant effects upon you.

CHILDREN

Our Services are intended solely for customers who can form legally binding contracts under applicable law and are of legal age of majority in their place of residence. By using the Services, you represent and warrant that you can form a legally binding contract under applicable law and are of legal age of majority where you reside, and that you agree to abide by all of the terms and conditions of this Policy. . If you are under 13, please do not send any Personal Data about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Data, please contact us at info@transformativ.net

LINKS TO THIRD PARTY PLATFORMS

Our Services or communications may contain links to third party websites, over which we exercise no control, including the form of embedded content, sponsored content or co-branded content. Except as set forth in this Policy, we do not share your Personal Data with those third parties and are not responsible for the privacy policies of any third party or their management of your Personal Data. Because they may treat your Information differently than we do, we suggest you read the privacy policies on those third-party websites prior to submitting any Personal Data to such sites.Our Services may use YouTube to make content in video format available to you. By accessing a part of the Services where videos are available, watching an embedded video, or otherwise interacting with any content made available through YouTube, you signify your agreement with YouTube’s terms and conditions. YouTube collects and otherwise has access to usage data (e.g., what videos you accessed and watched) through videos embedded in the Services as further described in YouTube’s Privacy Notice. YouTube adheres to Google's privacy policies and principles, part of which allow you to control certain privacy settings and which data are collected. For more information, please visit https://www.youtube.com/howyoutubeworks/user-settings/privacy/

In addition, you may be redirected to a third-party platform for certain functions, including returns, forms, and customer service. See above section regarding “Sharing of Information.”


YOUR RIGHTS

 Opting Out of Communications

As described above, we may use the Personal Data we collect from you to send you newsletters or other communications from us, including those promotional or marketing in nature. If you do not want to receive such communications, you can opt out by clicking here.

You may also at any time opt out of receiving communications from us by sending an e-mail to  info@transformativ.net with the subject line “Opt Out.”

At your option, you may communicate through text messages regarding your orders and our products. You may withdraw permission to communicate with you by text message at any time by texting “STOP” to 68805. For more information or assistance, reply “HELP” to 68805 or contact us at  info@transformativ.net. Please see our Messaging Terms & Conditions for additional information and terms that apply to our text message program.

Disallowing Cookies and Location Data Collection

You can opt out of the collection and use of certain information, which we collect about you by automated means, by changing the settings in the device you use to access the Services. In addition, your browser may tell you how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies you may not be able to use some or all of the features of the Services.Changing your cookie preferences in one browser will not necessarily carry over to other browsers, so you may need to adjust your preferences each time you get a new device, install a new browser, upgrade an existing browser, or alter or delete a browser’s cookie file.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at:

http://optout.networkadvertising.org

http://www.youronlinechoices.eu

https://youradchoices.ca/choices

http://optout.aboutads.info

Do Not Track & Opt Out Signals

We use analytics systems and providers and participate in ad networks that process Personal Data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We process and comply with web browser’s “do not track” signal mechanisms where required by applicable law. Additionally, residents of certain U.S. states may opt out by broadcasting an Opt-Out Preference Signal under applicable law, including the Global Privacy Control (GPC), depending on which browsers and/or browser extensions you use that may support such a signal. To look at extensions and browsers supporting the GPC browser signal, visit here: https://globalprivacycontrol.org/. Note that if you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Note, however, that you may find information about how to opt out of online behavioral advertising and/or block or reject certain tracking technologies in the section caption “Disallowing Cookies and Location Data Collection” above.

YOUR CALIFORNIA PRIVACY RIGHTS

California residents, see our “California Privacy Notice” for more information about certain legal rights.

YOUR NEVADA PRIVACY RIGHTS

Nevada law permits our users who are Nevada consumers to request that their Personal Data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to  info@transformativ.net

ADDITIONAL INFORMATION FOR CERTAIN U.S. RESIDENTS

 Certain U.S. states require additional disclosures and provide users residing in such U.S. states with additional rights regarding Personal Data. As of the date this Privacy Policy was last updated, those states include Colorado, Connecticut, Florida, Oregon, Texas, Utah, and Virginia. This section of the Privacy Policy only applies to individuals located in such states and where such U.S. state data protection laws apply to our processing of your Personal Data. 

Sensitive Personal Data

Only where we have received your permission and consent–we collect geolocation information. For example, when using our mobile app, you may be prompted to allow or reject the tracking or your precise geolocation. Under certain applicable laws, precise geolocation may be considered “sensitive” Personal Data.

We may use such precise geolocation information for the following purposes:

  • purposes as directed by you or for the performance of Service you request and as reasonably expected in the context of such performance;
  • with your consent;
  • to protect our legal interests and to ensure the physical safety of ourselves and other individuals; or
  • to carry out our obligations under applicable law.

We do not sell or share sensitive Personal Data with any third parties for cross-context behavioral advertising or to use for their own purposes. We will only collect and use this information after receiving your prior consent.You have the ability to disable the sharing of this information with us at any time through the settings on your mobile device.

Disclosures to Third Parties

Pursuant to and consistent with the purposes for collecting your Information as set forth in this Privacy Policy, we disclose certain categories of Personal Data to third parties for a legitimate business purpose. The categories of Personal Data we disclose includes:

  1. Identifiers: including but not limited to name, telephone number, address, age, email address, or date of birth;
  2. Commercial Information: including but not limited to contact information and order history;
  3. Audio, electronic, visual or similar information: such as customer service phone line records.
  4. Internet or other electronic network activity information: including but not limited to computer and connection information, IP address, and cookies and other tracking technologies described further above; and
  5. Inferences: drawn from the above categories of Personal Data.[BL1]

The categories of third parties to which we may share the above categories of information, include, without limitation:

  1. Our affiliates and related entities;
  2. Third party service providers: including, but not limited to, payment processing companies, data analytics and advertising providers, fraud prevention providers, cloud storage providers, IT service providers, delivery partners, and marketing companies; and
  3. Law Enforcement.

Rights

Applicable laws in the U.S. state where you reside may grant you some or all of the rights listed below (subject o all applicable limitations, exceptions, and exemptions. These rights are not absolute, and we may decline your request as permitted by law. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

  • Right to Confirm, Access and Portability. You may have right to confirm whether we process your Personal Data, access your Personal Data, and/or receive a copy of the Personal Data that we have collected about you.
  • Right to Correct. You may have the right to correct inaccurate Personal Data that we have collected about you.
  • Right to Delete. You may have the right to delete the Personal Data we have obtained about you or that you have provided to us with certain exceptions.
  • Right to Opt-out of Tracking for Targeted Advertising Purposes. You may have the right to opt-out of certain tracking activities for targeted advertising purposes.
  • Right to Opt-Out of the Sale of Personal Data. You may have the right to opt-out of our sale of your Personal Data to third parties.
  • Right to Non-discrimination. You have the right to be free from discrimination due to your exercise of your rights under applicable law. We do not discriminate against users for exercising the rights granted to them under applicable law and that are applicable to our processing of your Personal Data.

You also have the right to submit a complaint about our processing of your Personal Data to the applicable government regulator or authority in the jurisdiction in which you are located (e.g., your state’s Attorney General).

Selling and Sharing

We do not sell your Personal Data as the concept of “selling” is traditionally understood as being the exchange of something for money. However, we sell your personal information to, and share your personal information with, third parties for the purpose of cross-contextual behavioral advertising purposes (e.g., targeted advertising and remarketing). Applicable U.S. state data protection laws hold such disclosures and sharing to be considered “selling” or “sharing”. Therefore, you may have the right to opt out of such selling and sharing. In the preceding 12 months, we have sold or shared the following categories of Personal Data with the following categories of third parties and for the following purposes:

  • Identifiers: We provide such information to analytics, marketing, advertising and remarketing partners and services providers for analytical and targeted advertising purposes, including, to target advertisements to you for goods and services and by displaying those advertisements on other websites.
  • Internet or other electronic network activity information (e.g., cookies and other online unique identifiers): We provide such information to analytics, marketing, advertising and remarketing partners and services providers for analytical and targeted advertising purposes, including, to target advertisements to you for goods and services and by displaying those advertisements on other websites.

You have the right to opt out of the selling or sharing of your Personal Data as described herein. You may exercise this right to opt out by utilizing the Global Privacy Control as mentioned in the “Do Not Track & Opt Out Signals” section above, or by clicking the “Do Not Sell or Share My Personal Information” option in the footer of the website and changing your Cookie Settings as described on that webpage. If you have any questions, concerns, or would like more information on our ability to opt out, you can contact us by emailing:  info@transformativ.net

Exercise Your Rights

You can exercise your rights by submitting a verifiable request to use by:

  1. Emailing:  info@transformativ.net

Please note that to exercise your rights to opt-out of targeted advertising and/or the sale of your Personal Data, you must follow the instructions provided under the “Selling and Sharing” section of the Privacy Policy directly above. Only you or a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. Without limiting the foregoing, the verifiable consumer request must:

  1. Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.Making a verifiable consumer request does not require you to create an account with us.We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will respond to your request within the applicable timeframe required under applicable law. If we deny your request, you can appeal such denial through the same methods as set forth above. If the appeal is denied, you may submit a compliant to the applicable government regulator or authority in the U.S. state in which you are a resident (e.g., the state Attorney General in the state in which you reside).

INTERNATIONAL DATA TRANSFERS

If you are located outside the United States, we transfer Personal Data for processing in the United States, including Personal Information sent via e-mails or when you make an order. Under the GDPR, we are considered a “controller” of the Personal Data. By using the Services outside the United States, you acknowledge that we will transfer your data to, and store your Personal Data in, the United States, which may have different data protection rules than in your country, and Personal Data may become accessible as permitted by law in the United States, including law enforcement and/or national security authorities in the United States. For transfers of data into and out of the EEA, Switzerland and the UK, pursuant to Article 46 of the GDPR, we use standard contractual clauses adopted by the European Commission or applicable regulator.

Rights of Swiss, EEA and UK Residents

Under the GDPR, you may have the following rights with respect to your Personal Data, including to:

  1. Right to Access and Portability. You have the right to access your Personal Data and/or receive a copy of the Personal Data that we have collected about you in a portable format.
  2. Right to Object to Processing. You have the right to object to the continued processing or use of your Personal Data.
  3. Right to Correct. Right to update and correct inaccuracies in your Personal Data.
  4. Right to Object. Right to object to the continued processing or use of your Personal Data in certain situations, including for direct marketing.
  5. Right to Erasure. Right to have the Personal Data blocked, anonymized or deleted, as appropriate in certain situations.
  6. Right to Complain. You have the right to complain to a supervisory authority, and your Personal Data may be blocked, anonymized or deleted, as appropriate. If you are in the USA, you may find information about your supervisory authority here.

The right to access Personal Data may be limited in some circumstances by local law. If you qualify, in order to exercise these rights, please contact us as set forth below.

E-mail:  info@transformativ.net

We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

Please understand, however, that we reserve the right to retain an archive of such Personal Data for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.

This section of the Privacy Policy is applicable to individuals located in the EEA, Switzerland, and the United Kingdom (“European Data Subjects”).

Our purpose for collecting and processing Personal Data from European Data Subjects is to provide them with the features and functionalities of our Services and information regarding our Services. The legal basis for processing Personal Data is because it is necessary for performance of a contract between us to provide you with the Services and its related features and functionality and in other circumstances may be necessary for our legitimate interests in making the Services available and secure, or to exercise our rights or comply with legal obligations. We also rely on your consent to receive information about our Services. You may withdraw consent from receiving marketing and promotional communications by clicking the “Unsubscribe” link on the communication or sending an e-mail to  info@transformativ.net with the subject line “Opt Out.” If European Data Subjects do not provide Personal Data to us or withdraw consent for processing such Personal Data, we may not be able to provide such individuals with certain features or functionalities of the Services or information regarding the Services, including processing orders.

European Data Subjects may obtain information about the Personal Data that we hold about them by contacting us at  info@transformativ.net

Rights of Canadian Residents

Residents of Canada are permitted to request and obtain from us information respecting the existence, use, and disclosure of their Personal Data as well as access to that information (subject to certain exceptions pursuant to applicable laws). Without limiting the above, residents of Canada will, upon request:

•Right to Be Informed. You have the right be informed of whether we hold Personal Data about you.

•Right to Know About Third Parties. You have the right to be provided with an account of third parties to which we have disclosed your Personal Data.

•Right to Accuracy. You have the right to be able to challenge the accuracy and completeness of your Personal Data and have it amended as appropriate.

•Right to Know About Policies and Practices. You have the right to be provided with information about our policies and practices with respect to the management of Personal Data, including: the name or title, and address, of the person who is accountable for our privacy policies and practices; the means of gaining access to personal information; a description of the type of personal information held by us, including a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and what personal information is made available to related organizations.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Policy at any time. In the event we make changes to this Policy, such policy will be re-posted in the "Privacy" section of our Services with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy. If you have any questions about the changes that were implemented, please contact us at  info@transformativ.net and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Services after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Services or opt out by sending us an appropriate notice.

GENERAL LEGAL

If you have questions or comments about this Policy, please contact us at  info@transformativ.net with “Privacy” in the subject line of your email.