Last modified: April 22, 2021 - This policy supersedes all prior privacy polices posted on or through
www.tchoye.com/legal/privacypolicy.1. Introduction Tchoye LLC, a Florida limited liability company (”Tchoye” or “We” or “Us” or “Our”), respects your privacy and is committed to protecting it through our compliance with this policy. We are a controller with respect to the data we collect for purposes of the General Data Protection Regulation (“GDPR”). We are subject to the GDPR to the extent we collect or process the personal information of individuals in the European Economic Area or the United Kingdom.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to access and/or use our Website and Services. By accessing or using our Website and Services, you agree and consent to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website and Services after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates. The date our privacy policy was last modified is indicated at the top of this page. This policy describes (1) the types of information we may collect from you or that you may provide when you visit the website at
www.tchoye.com (our
“Website”), communicate with us, or otherwise use the services we provide on the Website, mobile applications, or other platforms (collectively, our “Services”), and (2) our practices for collecting, using, maintaining, protecting, and disclosing that information.
Specifically, this policy applies to information we collect:
• when you interact or engage with our Services in any way, for example, when you navigate on or through our Website, create an account, login to the Website, or use our Tchoye mobile application.
• In email, text, or other electronic messages between you and Tchoye, including direct messages either you or Tchoye send each other via social networks and other platforms.
It does not apply to information collected by:
• any third party, including through any application or content that may link to or be accessible from our Services.
2. Children Under the Age of 16 Our Services are not intended for, nor directed to, children under 16 years of age. We do not knowingly collect personal information from children under 16 that may access or navigate through our Website or otherwise use our Services. If you are under 16, do not use our Services or provide any information to us. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@tchoye.com.
3. Information We Collect About You and How We Collect It We collect several types of information from and about users of our Services, including information:
• by which you may be personally identified, such as your name, user name or ID, email address, password, or any other identifier by which you may be contacted online or offline (”personal information”);
• that concerns you but individually does not identify you, such as an IP address, device ID, or any other similar identifier, in addition to aggregated data derived, in part, from information about you;
• about how you and other individuals access and/or use our Services; and/or
• about how you and other individuals interact with the electronic communications we send to you and others.
We collect this information:
• Directly from you when you provide it to us.
• Automatically and passively as you navigate through the Website or otherwise use our Services. Information collected automatically or passively may include usage details, IP addresses, and other information collected through cookies and other tracking technologies utilized by Tchoye and/or our third-party service providers and partners, as described below.
• Automatically and passively through web beacons, clear gifs, and other pixel tags used in electronic communications between you and Tchoye.
Note, however, that the third-party service providers and partners (identified below) we use to automatically and passively collect this information may collect more information about you than we have access to. Such information may include personally identifiable information beyond the personal information you provide to us directly, or that we otherwise collect or have access to.
Also, personal information once “de-identified” is not subject to this privacy policy and we may treat it as non-personal information and use it without obligation to you except as prohibited by applicable law.
Please see the linked privacy policies below for more information concerning the information these third parties may collect from you as you interact with our Services: (a) Google, click
here.(b) Stripe, click
here. For more information on how you can control and/or limit the collection or use of your information by these third-party service providers and partners, see the section below called Choices About How We Use and Disclose Your Information.
3.1. Information You Provide to Us Directly The information we collect on, through, or in connection with our Services may include:
• Information that you provide by filling in forms in connection with our Services. This includes information provided at the time of registering to use our Services, logging in with email credentials, commenting or interacting on or through the Tchoye mobile application, or requesting further services. We may also ask you for information when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Any other information you provide directly on or through our Services.
Much of the information you provide directly to us will be published or displayed (hereinafter, "posted") on public areas of the Services, or transmitted to other users of our Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
3.2. Information We Collect Through Automatic or Passive Data Collection Technologies As you navigate through our Website and interact with our Services, we may use automatic or passive data collection technologies or third-party services (which in turn use certain automatic or passive data collection technologies) to collect certain information about you and other users of our Services, including information about your equipment, browsing actions, and patterns.
The information we collect from you automatically or passively is anonymous or is aggregated with information collected from other users of our Services and cannot be used by us to specifically identify you, except as expressly set forth in this policy. However, we may tie some of this information with personal information about you that we collect from other sources or you provide to us. The aggregated and/or anonymized data we obtain automatically and passively, and have access to consists of:
• Details of users’ visits to our Website and use of our Services, including traffic data, logs, referring website addresses, data/time of visits, page views, domain names, location data, conversion rates, active users, time spent on the Website, and other similar data about how and when you and others access and use our Services.
• Information about your computer, mobile device, and Internet connection, including your IP address, operating system, device identifiers, browser type, and what Internet Service Provider (ISP) you use.
• Details about how and what users engage with the Tchoye mobile application and other features of our Services.
This information helps us to improve our Services and to deliver a better and more enjoyable service, including by enabling us to:
• Estimate our audience size and users’ usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Recognize you when you return to our Services.
• Analyze performance metrics.
• Understand how to make our Services better.
The technologies we use for this automatic and/or passive data collection may include:
• Cookies. A cookie is a small file placed on the hard drive of your computer or mobile device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or otherwise use our Services. You accept our use of cookies by accessing or using our Services.
• Web Beacons, Pixel Tags, and Similar Tracking Technologies. Our Services may contain and use small electronic files known as web beacons (also referred to as clear gifs, SDKs, pixel tags, and single-pixel gifs) that permit Tchoye, for example, to count users who have visited pages of our Website 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).
The third-party services that we use in connection with our Services include:
• Google Analytics. Google Analytics allows us to see how users are interacting with our Website and Services. Specifically, it provides us with aggregated data, such as how many users visit our Website over time, how long users stay on our Website, and what type of users visit our Website.
• Stripe. We utilize Stripe to process payments you make to us.
By accessing and using our Services, you consent to the collection and processing of your data by these third-party services as set out in this privacy policy and in each respective third-party privacy policy.
For more information on how you can control the collection or use of your information with respect to these third-party service providers, see the section below called Choices About How We Use and Disclose Your information.4. How We Use Your Information We use information that we collect about you or that you provide to us, including any personal information:
• To present our Services and their contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including any license agreements or terms of service.
• To notify you about changes to our Services.
• To optimize and enhance your experience with our Services.
• In any other way we may describe when you provide the information.
We may also use your email address to provide you with marketing related electronic messages, including news, events, updates, and promotional emails. If you do not want us to use your information in this way, please email us at support@tchoye.com, and we will remove you from our mailing list.
For more information on how you can control the collection or use of your information, see the section below called Choices About How We Use and Disclose Your Information.
5. Disclosure of Your Information We may share or disclose aggregated, anonymized, or generalized information about our users, including all non-personal information, without restriction.
We do not share or disclose your personal information with third parties, except we may disclose personal information that we collect or you provide as described in this privacy policy as follows:
• To our subsidiaries and affiliates.
• 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.
• 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 Tchoye LLC or one of its subsidiaries or affiliates’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent, to the extent your consent is required under applicable law.
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.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tchoye LLC, or our owners, employees, users, or others.
6. Choices About How We Use and Disclose Your Information We strive to provide you with choices regarding the information you provide to us. Below are the tools available that allow you to control all or part of the information collected from you as you interact with our Services:
• Cookies. Generally speaking, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please visit your browser’s website for more information. If you disable or refuse cookies, please note that some parts of our Services may then be inaccessible or will not function properly, or your opt-out choices will not work.
• Electronic Messages Opt-Out. If you no longer want us to send you electronic messages related to our business or Services, you can opt-out by clicking the unsubscribe link found at the bottom of each electronic message we send to you. You can also email us at support@tchoye.com and we will remove you from our electronic message mailing list. Your opt-out request will be processed within a commercially reasonable period of time.
• Google Analytics. If you want to control the data collected by Google Analytics you can get the Google Analytics Opt-out Browser Add-On
here. It is available for Microsoft Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari, and Opera.
Please note that in order for your opt-out choices to be effective using these tools, you must ensure that your browser is set to accept third-party cookies such as the OpenX opt-out cookie. Some browsers block third-party cookies by default, so you may need to change your browser settings to accept third-party cookies before opting out.
If you have any questions or concerns about opt-out, please contact us at support@tchoye.com.
7. How We Respond to Do Not Track Signals We currently do not respond to do not track signals.
8. Access to Third Party Websites You will be able to access third party websites directly from our Services. This privacy policy does not apply when you access third party websites. We cannot control how third parties may use personal information you disclose to them, so you should carefully review the privacy policy of any third-party website you visit, such as the third-party privacy policies we link to, before interacting with such third-party websites or disclosing your personal information to its provider.
9. Lawful Basis for Processing Personal Information If you are in the European Economic Area or the United Kingdom, we process any personal information we collect in order to:
(1) carry out our contractual obligations with you; (2) comply with our legal obligations; and (3) engage in activities that are in our legitimate interest, such as providing you with an enjoyable experience and to provide you with information related to our Services.
To the extent the processing of your personal information requires your consent, we will obtain such consent at the time we collect such information. This consent can be withdrawn at any time; provided, however, withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent. You can withdraw your consent by emailing us support@tchoye.com.
10. Your Rights Under the GDPR, individuals have a number of important rights free of charge. In summary, these include rights to:
• Access the personal information we have about you;
• Require us to correct any mistakes in the personal information we have about you;
• Require us, in certain situations, to erase certain personal information we have about you;
• Receive your personal information in a structured, commonly used and machine-readable format that can be easily transmitted to other third parties;
• Object – at any time – to the processing of your personal information for direct marketing;
• Object in certain other situations to our continued processing of your personal information; and
• Otherwise restrict our processing of your personal information in certain circumstances.
For more information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the GDPR.
If you would like to exercise any of these rights, please:
• Email us at support@tchoye.com;
• Let us have enough information to identify you; and
• Let us know the information to which your request relates.
If we cannot verify your identity, we may request proof of your identify, such as a copy of your driver’s license or passport.
We hope that we can resolve any question or concern you raise about our use of your information; however, the GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
11. Your California Privacy Rights California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@tchoye.com.
12. International Processing Our head office is located in St. Petersburg, Florida, United States. We store and process your personal information on our computers and servers in the United States and, at times, depending on the cloud services we utilize, in various other countries. As such, that means that your personal information may need to be processed in countries where data protection and privacy laws and regulations may differ from those in your home country. In order to ensure your personal information is treated with the same level of care required in your home country, we require all authorized third parties, affiliates, and partners to take appropriate measures to keep your information confidential, safe, and secure in accordance with applicable data protection laws.
13. Data Retention We will store your personal information only for as long as necessary to provide you with the Services or information you require or request, or for as long as we are legally obligated to do so. We will also store certain personal information for archival purposes that are required for the continued operation of our business. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at support@tchoye.com.
14. Data Security We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information we collect from you is stored in the cloud, which is encrypted by third-party systems. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. 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 Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Services. Any transmission of personal information is at your own risk.
15. Changes to Our Privacy Policy We reserve the right to amend our privacy policy at any time, for any reason, without notice to you. However, if we make material changes to how we treat our users’ personal information, we will post a notice on our Website, and may in our sole discretion, notify you by email. The date the privacy policy was last revised is identified at the top of the page. If you provide us with an email address, you are responsible for ensuring we have an up-to-date active and deliverable email address for you. You are also responsible for periodically visiting our Website and this privacy policy to check for any changes.
16. Contact Information To ask questions or to comment about this privacy policy and our privacy practices, contact us at:
support@tchoye.com.
Thank you.