This Privacy Notice applies to freshtorylane.com (also referred to herein as the “Site”) which is provided by BLT Innovations, LLC (also referred to herein as “Company,” “us,” or “we”). The Company respects your privacy and is committed to protecting it through our compliance with the policies and procedures stated in this Privacy Notice inclusive of special provisions as required by the General Data Protection Regulation (GDPR) for users in the European Union (EU), European Economic Area (EEA), Andorra, Monaco and San Marino, as well as Switzerland.
This Privacy Notice describes the types of information we collect from you or that you may provide when visiting our websites, and our practices for collecting, using, maintaining, protecting, and disclosing that information. As used in this Privacy Notice, “personal information” means information which relates to an individual and which identifies that individual, either directly or indirectly, such as your name or your contact information.
This Privacy Notice applies to information we collect in all of the following ways:
a. On any of our websites.
b. In email, text, and other electronic messages between you and Company.
c. Offline, such as when you call our customer service personnel or send physical mail to us.
d. When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Notice.
e. Information you provide to us when requesting services.
Please read this Privacy Notice carefully to understand our policies and procedures regarding your personal information and how we will treat it. If you do not agree with our policies and procedures, your choice is to stop using our websites.
By using our websites and creating an account, you acknowledge that you have reviewed this Privacy Notice and agree to the terms and conditions described within this Privacy Notice and in our Terms and Condition. If you do not agree with our privacy policies and procedures, please ask us to remove your account and please do not use our websites or services.
Acceptance of Terms
By accessing and using our Sites, you agree that we may use any personal information you have provided or that has been collected for any purpose within the constraints of the law, including technical, administrative, research and development, customer administration, marketing, trading of personal data, age verification, promotion and advertising by this website or authorized third parties. By using this site, you agree that the site may, within the constraints of the law, share, disclose, transfer, rent, license or sell any of the personal information that it has gathered or collected with third parties. All information collected may be shared to comply with applicable law and/or to cooperate with law enforcement agencies and courts/tribunals. If you do not agree with our information practices, please do not access or use our Sites.
As provided below, we reserve the right, at our discretion, to change, add or remove portions of this policy at any time by posting such changes to this page. Such changes will be effective upon posting.
Minors under the Age of 18
Our websites are not intended for and shall not be used by anyone under the age of 18 years old or 21 years old, whichever is applicable by law in your jurisdiction. No one under 18 may provide any information to or on this website and should not knowingly access any of our websites. Company does not knowingly collect personal identifiable information from persons under 18.
Member areas of site may contain content considered offensive to some and are inaccessible to individuals under the age of 18 via a standard credit card wall, as advocated by the Communications Decency Act. It is possible that by fraud or deception we may receive information given to us or pertaining to minors under the age of 18. If we are notified of this and it is verified, we will immediately delete the information from our servers. If you want to notify us of our receipt of information by minors, please do so by emailing us at [email protected]
We willfully cooperate with law enforcement authorities, private-party litigants, investigators and others seeking information about our end users as required by applicable law. We will also notify the appropriate authorities if we suspect that any of our users are engaged in illegal activities, such as obscenity, child pornography, or credit card fraud.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our website, including information:
a. By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
b. That is about you but individually does not identify you, such as the languages you speak or can read; and
c. About your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
a. Directly from you when you provide it to us.
b. Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
c. From third parties, for example, our business partners.
Information You Provide To Us
Registered Users (“Users”)
When you become a User, you provide us with personal information as follows:
• Account-related Information: To create an account and/or upload videos you must provide certain information, including your user name, email address, a password, and your date of birth. We may allow you to submit additional information including additional contact data, including phone numbers. You may provide other information about yourself in connection with customer support inquiries and other communications with us.
- Correspondence: Records and copies of your correspondence (including your email address), if you contact us.
- Transaction Information: Financial information that is collected is used to check the users' qualifications for registration and to bill the user for products and services. However, payment details are collected directly by our payment vendors and are not received or stored by the company.
- Search: Your search queries on our websites.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our websites, we may use automatic data collection technologies to collect certain information, not tied to your user profile on our portal, about your equipment, browsing actions, and patterns, including:
- Usage Information: We may collect information about your use of the site, including your accessing, viewing, and transaction (purchase) history on all company websites.
- Automatic Information: When you visit site, our servers may automatically record certain information that your web browser sends. This may include your activities, your IP address, browser type, browser language, referring URL, platform type, domain names, date/time stamps, and related metadata.
We also may use these technologies to collect information about your online activities on our websites and/or our partners’ websites over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our websites and to deliver better and more personalized services, including by enabling us to:
a. Estimate our audience size and usage patterns.
b. Store information about your preferences, allowing us to customize our websites according to your individual interests.
c. Speed up your searches.
d. Recognize you when you return to our websites.
The technologies we use for this automatic data collection may include:
b. Web Beacons. Pages of our websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to do certain things, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Such information will be gathered solely by the company and is for use solely by the company and trusted partners, including our service providers, sub-processors, and advertising and marketing partners. When we request information that is not required for us to fulfill our promises to you, you will be notified that such information is optional and be given the choice not to provide it.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
a. To present our websites and their contents to you.
b. To provide you with information, products, or services that you request from us.
c. To fulfill any other purpose for which you provide it.
d. Help streamline our marketing and hosting operations and to improve the quality of the site user-experience.
e. To provide you with notices about your account, including expiration and renewal notices.
f. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
g. To notify you about changes to our websites or any products or services we offer or provide though it.
h. To allow you to participate in interactive features on our website.
i. In any other way we may describe when you provide the information.
j. For any other purpose with your consent.
k. To comply with any relevant laws, regulations, ordinances, rules, directives, or statutes.
If your IP address indicates you are in the European Union or the European Economic Area, we do not use your email address or other personal information to send commercial or marketing messages without your consent.
But if you chose to opt-in to receive marketing materials from us, possibly when you created your account, be aware that we may use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box to opt-out located on the account creation form on our websites or at the bottom of any marketing emails you may receive from us. You can also opt-out by sending an email to [email protected]
You expressly and specifically acknowledge and agree that your email address or other means of communicating with you may be used to send you offers, information or any other commercially oriented emails or other means of communications. You may remove yourself from such mailing lists at any time by following the instructions that shall be sent as part of any such mailings.
Legal bases for processing (For EEA users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only where:
a. We need it to provide you with the Services you requested, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services, which includes all processing necessary for the performance of our contract(s) with you;
b. It satisfies a legitimate interest that is not outweighed by your data protection rights and interests, such as for research and development, to market and promote the Services, and to protect our legal rights and interests;
c. You give us consent to do so for a specific purpose; or
d. We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use although, in some cases, this may mean no longer using our services.
Location of Your data
All of our information, including the personal information about you described in this Privacy Notice, is stored in the United States of America.
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Disclosure of Your Information
We may disclose aggregated (i.e. anonymized) information about our users, and information that does not identify any individual, without restrictions.
We may disclose personal information that we collect or you provide as described in this Privacy Notice:
a. To our subsidiaries and affiliates.
b. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
c. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the company about our website users is among the assets transferred.
d. To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our website, or copy a co-worker on a request being made through our portal, we will transmit the contents of that email/request and possibly your email address to the recipients.
e. For any other purpose disclosed by us when you provide the information.
f. With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms and Conditions or Privacy Notice and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices about How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Marketing Emails. You can review and change your personal information in our marketing systems by using the unsubscribe function on our marketing emails.
- Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our services, you can opt out by un-checking the relevant box located on the form on which we collect your data (the order/registration form) or at any other time by sending us an email stating your request to [email protected] If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or use the opt-out feature on the email.
Accessing and Correcting Your Information
You are legally entitled to request details of the personal data we are holding about you. The company provides you the ability to keep your personal data accurate and up-to-date. If at any time you would like company to rectify, erase or restrict the processing of your personal information, or you would like to obtain confirmation whether or not your personal information is processed by the company, access your personal information, exercise your right to data portability or withdraw your consent to processing, please contact us.
We do our best to respect your privacy rights and provide you access and control over your data. You may make any of the following requests regarding your data by contacting us at [email protected]:
- Access and review your data.
- Correct your data or request that we delete some or all of it.
- Obtain copies of your data in human or and/or machine-readable format suitable for importing to other software.
- Restrict us from using or processing your data.
Be advised that we use a differential backup system; this means that we cannot delete your specific information from our backups. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.
Recourse, Enforcement & Liabiliy
In compliance with the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles, we are committed to investigate and expeditiously resolve complaints about your privacy and our collection or use of your Personal Information. The Company uses the self-assessment method of verification of compliance and is subject to the enforcement authority of the US Federal Trade Commission.
European Union and Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact us at [email protected]
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles to JAMS, an independent dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint regarding our compliance with the EU-US Privacy Shield Principles or Swiss-US Privacy Shield Principles or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield to file a complaint.
If you do not receive a timely acknowledgment of your complaint regarding our compliance with the EU-US Privacy Shield Principles or Swiss-US Privacy Shield from JAMS or if your complaint is not satisfactorily addressed through JAMS, EU individuals may complain to the US Department of Commerce through the EU Data Protection Authority in the country in which you reside while Swiss individuals may complain to the US Department of Commerce through the Swiss Federal Data Protection and Information Commissioner in Switzerland.
If you do not receive a timely acknowledgment of your complaint regarding our compliance with the EU-US Privacy Shield Principles or Swiss-US Privacy Shield Principles from the US Department of Commerce or if your complaint is not satisfactorily addressed through the US Department of Commerce, EU individuals may invoke arbitration with the Privacy Shield Panel to determine whether we have violated our obligations under the EU-US Privacy Shield Principles. For more information about the arbitral model, please review Annex 1 available at http://ec.europa.eu/justice/data-protection/files/annexeseu-usprivacyshiel
International Data Transfer
Our websites are hosted on our web servers in the United States. If you are located in a non-US jurisdiction, for example in the European Economic Area ("EEA") / European Union ("EU"), you agree that the provision of personal data or other access to our website constitutes your consent to the transfer of such data/information, including personal data, to the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws in your home country. However, we have procedures in place to ensure the protection of your information, including your personal data.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls. The safety and security of your information also depends on you.
Where we have given you (or where you have chosen) a password for access to certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the websites, including chat areas described below. The information you share in public areas may be viewed by any user of the websites.
Unfortunately, the transmission of information via the internet is not completely secure and, although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our websites, particularly the end computer that you may be using to interact with our websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our websites, described in this Privacy Notice, or stated in our Terms and Conditions.
Your browser offers so-called "cookies," which – if you allow their use – store small amounts of data on your computer about your visit to our websites. Cookies assist us in tracking which of our features you like best. And when you re-visit our websites, cookies can enable us to customize our content according to your preferences. However, cookies tell us nothing about you personally unless you specifically give us additional information.
Cookies used on our websites by category:
- Strictly necessary cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of our websites.
- Functionality cookies - These cookies remember choices you made to improve your experience. By using our websites, you agree that we can place these types of cookies on your device. These cookies allow the websites to remember choices you make and provide enhanced, more personal features. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
- Advertising cookies - These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
You also have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. However, note that if you reject some or all cookies, your experience at our websites and on other sites throughout the World Wide Web may not be complete. Some sites require cookies to function, such as those with e-commerce features. In addition, if you do not allow cookies, you will not be able to take advantage of personalized content delivery offered by us or other Internet sites.
Unsolicited Email Received by You
Company does not send unsolicited email to anyone who has requested we do not contact them. Any newsletters that we send are only sent to those who are active members of the site. To stop receiving email or newsletters from the company, either follow the instructions on the email or newsletter itself or send a request to be unsubscribed [email protected]
The company also does not condone spam by affiliates or chat hosts advertising our websites. Spam by our affiliates is prohibited by our Acceptable Use Policy. Some trusted partners may email a member to present special offers to our members. Further, according to our published policy, if the company becomes aware that a customer or affiliate is in violation of the law or this Acceptable Use Policy, the company reserves the right to impose disciplinary action in its sole discretion. Our disciplinary action may include: removal from our servers of files that violate our Acceptable Use Policy, the expulsion of the customer from the site’s program, termination of site services, and forfeiture of all commissions.
If you have any questions about this Privacy Notice, please contact our data protection officer at [email protected] and provide us with your name, the site name of your membership, your login name, and any information you feel is important.
If you are concerned about an alleged breach of privacy law or any other regulation by the company, you can contact our Data Protection Officer who will investigate your complaint and give you information about how it will be handled.
If you are not satisfied with the way in which the company has resolved your complaint, you have the right to complain to the data protection authority in your country. You may also refer the matter to a court of competent jurisdiction.
Revisions to this Privacy Notice
Company reserves the right to change this Privacy Notice from time to time. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the corporate website home page, via email, or when you log in to use our portal. Please check the Privacy Notice frequently and particularly before you submit additional personal information via our websites. All revisions to this Privacy Notice will be posted on our websites via a link from the homepage. We also display the effective date of the Privacy Notice on the bottom of this page.
Effective Date: 2019-01-08