Effective Date: June 28, 2021
Last Updated: June 28, 2021
- Information We Collect
- How We Use Information We Collect
- Our Legal Basis for Collecting Personal Information
- Cookies and Similar Technologies
- Your Failure to Provide Personal Information
- Our Retention of Your Personal Information
- Sharing Personal Information
- International Transfer
- Your Privacy Choicesa. European Users’ Rights with Respect to Personal Information
- Links to Other Websites
- How We Protect Personal Information
- Children’s Privacy
- Direct Marketing and “Do Not Track” Signals
- Contact Us
Information We Collect
We collect information, including personal information, to provide better Services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata.
You may choose to provide us with Personal Information about yourself, including your name, email, and phone number, when you complete forms on our website, such as when you request information about our services.
- Website Visitors
You may choose to provide us with Personal Information about yourself, including your name, organization name, title, phone number and email address by completing forms on our website. You may also provide us with Personal Information about yourself when you report a problem or have a question about our services.
When you visit our website, we collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, when you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location.
We may collect the following Personal Information about you when you use our Services: your name and email address. Tovera may also collect your credit card information and billing address when you provide Tovera with such information, such as when you buy products on our Sites; however your payment card information is passed securely to our payment card processor and is not stored by Tovera.
How We Use Information We Collect
We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- Providing services, including to:
- Register, create, and maintain your account;
- Allow you to purchase products online;
- Communicate with you regarding your account or any Services you use;
- Improve the convenience and functionality of our Site;
- Manage our business and protect ourselves, you, other persons, and the Services.
- Provide a personalized experience and implement your preferences.
- Better understand our customers and how they use and interact with the Services.
- Market to you and provide personalized services, offers, and promotions on our Sites
- Comply with our policies and obligations, including, but not limited to, disclosures and responses in response to any requests from law enforcement authorities and/or regulators in accordance with any applicable law, rule, regulation, judicial or governmental order, regulatory authority of competent jurisdiction, discovery request, advice of counsel or similar legal process.
- Resolve disputes, collect fees, or troubleshoot problems.
- Provide customer service to you or otherwise communicate with you.
We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by Tovera. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations.
To the extent we rely on consent for the processing of your Personal Information, we will seek such consent at the time we collect your Personal Information. We may also use the Personal Information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Legal Basis for Collecting Personal Information
Whenever we collect Personal Information from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
- Intra-organization transfers for administrative purposes;
- Product development and enhancement, where the processing enables Tovera to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our Sites or Services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google Analytics, Plausible, Cloudflare, and similar partners.
The technologies we use for this automatic data collection may include:
Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
Your Failure to Provide Personal Information
Your provision of Personal Information is required in order to use certain Services and programs. In some instances, if you fail to provide such Personal Information, you may not be able to access and use our Services, or parts of our Services.
Our Retention of Your Personal Information
We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal and contractual requirements (such as applicable statutes of limitation).
Sharing Personal Information
- Our business partners and third parties involved in the delivery of our products and services to you – including those involved in a sale of all or part of our business operations or assets and those for business, operational and general administration;
- Our marketing and advertisement partners;
- Our agents, advisors, consultants, other third party suppliers and/or service providers to assist us to operate effectively and provide you with the best experiences with our services;
- Other third parties when we have your consent or are otherwise permitted by law to do so.
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Tovera if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Fulfill any purpose for which you provide it;
- Meet any applicable law, regulation, legal process or enforceable governmental request;
- Detect, prevent, or otherwise address fraud, security or technical issues;
- Protect against harm to the rights, property, assets or safety of Tovera, our Users or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
- For any other purpose disclosed when you provide the information; and,
- When we obtain your consent to do so.
We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Your Privacy Choices
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to visit our Site or use our Services, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
- European Users’ Rights With Respect to Personal Information
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Information you have shared with us when we are the data controller. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Information which we hold about you.
- The right of correction: You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
- The right to be forgotten: You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
- The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
- The right to data portability: You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers / IT environment to another service provider’s servers / IT environment.
- The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority.
You can make these requests by emailing us at [email protected] or by contacting us at the contact information below. We will consider your request in accordance with applicable laws.
- Changing or Deleting Your Personal Information
You may update or correct information about yourself by emailing us at [email protected]. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Information on a regular basis to ensure its integrity for the purposes of ongoing data management.
- Our Opt-in/Opt-out Policy
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
Links to Other Websites
The Sites may contain links to webpages operated by parties other than Tovera. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Tovera strongly recommends that each User review the third party’s terms and policies.
If you have any questions about the privacy practices of other websites, you should contact the relevant parties controlling these websites for more information.
How We Protect Personal Information
Tovera maintains administrative, technical and physical safeguards designed to protect the user's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.
Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Information or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.
The Sites and Services are not designed or intended to be used by anyone under the age of 13. If you are under the age of 13, do not use the Services, or make purchases via the Services, use any interactive features of the Services, or post any Personal Information to our Sites or submit any Personal Information via the Services. We do not knowingly or intentionally gather Personal information about children who are under the age of 13. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13 in the applicable jurisdiction, please contact us [email protected]. If we learn that we have inadvertently collected the Personal Information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.
Direct Marketing and “Do Not Track” Signals
Tovera does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to [email protected] with the subject heading “California Privacy Rights,” or (b) a letter addressed to Tovera, Inc. PO Box 1113, Lake Geneva, WI 53147. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
How to Contact Us
Via e-mail: [email protected]
By writing to us: