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+Last Updated: December 07, 2022
California Privacy Policy
European Privacy Policy
TULA Life, Inc. and its subsidiaries and affiliates (“TULA,” “we,” or “us”) recognizes the importance of data privacy, and this Privacy Policy sets forth the terms and conditions with respect to how we process personal information. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.
This Privacy Policy applies to the personal information you provide us when you (i) visit any website that we own, license, or otherwise operate and that links to this Privacy Policy (each, a “Site”), (ii) purchase or receive products, goods, or services through the Site, or (iii) visit our offices or otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all products, goods and services sold or furnished by the TULA through a Site shall be referred to collectively as the “Services.”
PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS & CONDITIONS AND ANY APPLICABLE COOKIE POLICY ON A SITE.
You must be at least eighteen (18) years of age to access the Services. TULA is headquartered in the United States, and the personal information you provide to TULA may be processed and stored in the United States and other jurisdictions. For more information on our data transfer practices, please see Section 9 (Data Retention and Localization).
This Privacy Policy applies to personal information that TULA receives during its business operations as a “data controller” - which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. TULA may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and TULA may use such data for any purpose.
TULA collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to TULA, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:
Personal Information | ||
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Category | Description/Examples | |
Personal Identifiers | Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number. | |
Registration Data | Information provided when you register for an account to use the Site, including usernames and passwords. | |
Online Identifiers (For more information, see “Technical Data” below) | Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology. | |
Commercial Information | Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services. | |
Business Contact Data | Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities. | |
Health Data | You may furnish us with health-related information in the event you, or a third party, has an adverse reaction to the use of our products or goods. | |
Marketing and Communications Data | Information with respect to your marketing preferences and your subscriptions to our publications and alerts. | |
Internet and Electronic Network Data | Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and information derived from any device that connects to our WiFi services. | |
Your Feedback | Information you provide about our Services, which may include data gathered from any TULA surveys or reviews submitted by you. | |
Visitor Information | Information an individual provides when visiting any physical location or premises of TULA (e.g., visitor logs and registries, vehicle and parking information). | |
Video and Images | In some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing. | |
Geolocation Data | Information about the general city, state, or region in which a user of the Site is located. | |
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below) | If you apply for a job with TULA, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references. | |
Inferences | Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior. |
When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Site and other websites, including the following:
We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:
We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests.
How Your Personal Information Is Used |
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Provide, operate, maintain, improve, and promote our Services. |
Enable you to access and use our Services. |
Process and complete transactions, and send you related information, including purchase confirmations and invoices. |
Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer serivces). |
Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services. |
Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events). |
Process and deliver contest or sweepstakes entries and rewards. |
Monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests. |
Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities. |
Personalize our Services, including providing features or advertisements that match your interests and preferences. |
TULA may collect and use your personal information for any other purpose for which we obtain your consent. |
For the avoidance of doubt, you hereby agree that TULA may contact you via any means, including via SMS/text message and email and through the use of autodialing systems and serivces, to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.
In the event that you facilitate a transaction with TULA, or request information from or otherwise engage with us, and such activities require TULA to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct TULA to intentionally disclose your personal information to the service provider or third party.
We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.
As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.
The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings, export control laws), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.
TULA is based in the United States, and the personal information that we collect and process is retained and stored in the United States. TULA uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.
We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of sixteen (16), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information.
You may, from time to time, have the ability to submit via the Site a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and TULA, any and all Product Reviews and Feedback shall be considered our confidential and proprietary information. In order for TULA to utilize such Product Reviews and Feedback, you grant to TULA a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of TULA’s and our sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. TULA shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.
You are permitted, and hereby agree, to only provide personal information to TULA if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO TULA, YOU EXPRESSLY REPRESENT AND WARRANT TO TULA THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE TULA WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT TULA’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY TULA FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO TULA.
It is important that the personal information that you provide to us is accurate and reliable. You may have the ability to update your personal information at “Checkout” when you purchase a good or product. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. You may review, update, or modify your personal data, including profile and contact information, at any time by logging into your TULA account. You may request deletion of your personal data or TULA account by emailing privacy@tula.com or by completing our consumer rights webform.
Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by TULA in accordance with this Privacy Policy and TULA’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you have a right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email, and we will request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal information, provided that we advise you of any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the information contains personal information of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.
To exercise any of these data privacy rights, please complete our privacy webform or contact us, or have your designated agent contact us, in accordance with the “Contact Us” section listed below. To the extent permitted by law, we will need to verify your identity (or the identity of your agent) and ensure the authenticity of your request.
Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority. For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.
TULA does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.
Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
TULA strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.
We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. TULA may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.
As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.
TULA hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.
We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.
If you have questions regarding this Privacy Policy or our handling of your personal information, or you would like to request more information from us, or would like to exercise a data privacy right, please contact our Privacy Office at the following:
privacy@tula.com
TULA Life, Inc
ATTN: DATA PRIVACY
228 Park Avenue South
PMB 23606
New York, New York 10003-1502.
If you would like to contact us regarding exercising your privacy rights, please complete our privacy webform or contact us at the details above.
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