Effective as of 9 July 2020
Thank you for choosing to be part of our community at Tonalitie Speech Services, doing business as tonalitie (“tonalitie”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you visit our website https://tonalitie.com (the "Website"), use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the Website, the App, services rendered therein, and services rendered by agents of the company), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
Please see section 18 for our policies regarding HIPAA.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you receive Services, when you participate in activities on the Site or App (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the services and features you use. The personal information we collect may include the following:
Personal Information Provided by You.
We collect names; phone numbers; email addresses; mailing addresses; usernames; passwords; contact preferences; contact or authentication data; billing addresses; debit/credit card numbers; age; PHI; disability status; and other similar information.
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by a payment processor holding a Business Associate Agreement with us in accordance with HIPAA.
Social Media Login Data.
We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.
Location Data. We collect information data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected through our App
In Short: We collect information regarding your geo-location, mobile device, push notifications, when you use our App.
If you use our App, we also collect the following information:
Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.
2. WHAT IS HIPAA?
In Short: HIPAA protects patient privacy.
HIPAA is the acronym for the Health Insurance Portability and Accountability Act that was passed by Congress in 1996. HIPAA Provides the ability to transfer and continue health insurance coverage for millions of American workers and their families when they change or lose their jobs, it reduces health care fraud and abuse, it mandates industry-wide standards for health care information on electronic billing and other processes, and it requires the protection and confidential handling of protected health information. We aim to explain how we protect your privacy and security in relation to HIPAA and the data that you give us, or that we collect from you. The HIPAA Privacy regulations require health care providers and organizations, as well as their business associates, to develop and follow procedures that ensure the confidentiality and security of protected health information (PHI) when it is transferred, received, handled, or shared. This applies to all forms of PHI, including paper, oral, and electronic, etc. Only the minimum health information necessary to conduct business is to be used or shared.
3. WHAT INFORMATION IS PROTECTED UNDER HIPAA?
In Short: PHI is information that can be used to identify an individual and their health information.
PHI is any information in a medical record that can be used to identify an individual, and that was created, used, or disclosed to a covered entity (doctors’ offices, clinics, psychologists, nursing homes, pharmacies, hospitals, home healthcare agencies, insurance companies, HMOs, Speech Therapists, and others) and/or their business associate(s) (vendors or subcontractors that have access to PHI) in the course of providing a health care service, such as a diagnosis or treatment. It is the combination of health information and personally identifiable information (PII). Health information includes information that is created or received by a covered entity via any medium, including verbal, written, electronically or otherwise. This information includes the physical or mental health condition of an individual at any point in time. PII is considered health information because it has the potential to reveal an individual's personal identity, which could then be connected to the health information created or received by a covered entity. PHI includes, but is not limited to:
Addresses — In particular, anything more specific than state, including street address, city, county, precinct, and in most cases zip code, and their equivalent geocodes.
Dates — Including birth, discharge, admittance, and death dates.
Telephone and fax numbers
Social Security numbers
Driver’s License information
Medical record numbers
Health plan beneficiary numbers
Vehicle identifiers and serial numbers, including license plate numbers
Device identifiers and serial numbers
Names of relatives
Internet Protocol (IP) address numbers
Biometric identifiers — including finger and voice prints.
Full face photographic images and any comparable images.
4. NOTICE OF HIPAA PRIVACY PRACTICES
In Short: This notice describes how certain medical information about you may be used and disclosed and how you can get access to this information.
To the extent we request and obtain any personal healthcare information (“PHI”) about your medical history and current health that may be protected under the Health Insurance Portability and Accountability Act (“HIPAA”) and applicable state law, this Notice of Privacy Practices explains how that information may be used and shared with others. It also explains your privacy rights regarding this information.
Under HIPAA, certain parties that obtain PHI entities are required by law to abide by the terms of this Notice, to make sure that information that identifies you is kept private, and to provide this Notice of our legal duties and practices with respect to PHI to you. We are also required to notify you in the event there is a breach of your health information.
Uses and Disclosures of your Health Information:
We may use PHI to carry out treatment, payment and health care operations.
Treatment is the provision, coordination or management of health care: For example, we may use and disclose your information to consult with a third party or to refer you to other health care providers.
Payment includes the activities necessary to obtain reimbursement for the provision of health care: For example, we may need to give your health plan information about treatment you received so your health plan will pay us or reimburse you for the treatment.
Health care operations include the activities necessary for Tonalitie Speech Services to run its business operations. For example, we may use your information to review treatment and services and to evaluate the performance of our staff.
We may use or disclose your health information:
When required by federal, state, or local law.
To support public health activities by reporting as required or authorized by state or federal law. These reports may include the reporting of exposure to a communicable disease or risk of spreading a disease or condition.
To cooperate with law enforcement officials for certain law enforcement purposes as directed by a court order, warrant, criminal subpoena, or other lawful process.
To report abuse or neglect.
To support health oversight activities that are authorized by law, such as administrative or criminal investigations, inspections, licensure or disciplinary actions and other similar activities necessary for appropriate oversight of government benefit programs or functions.
When required by a coroner or medical examiner for the purpose of identifying a deceased person, determining a cause of death or other duties as required by law.
When necessary to prevent or lessen a serious and imminent threat to the health and safety of a person or the public and the disclosure is to a person reasonably able to prevent or lessen the threat, as consistent with applicable law and standards.
For judicial or administrative proceedings, in response to a valid court order, administrative order, a grand jury subpoena, or with your written consent.
For research purposes, with your written authorization or as permitted by law.
To business associates to perform functions on Tonalitie Speech Services’ behalf, if the business associate has signed an agreement to protect the confidentiality of the information.
We may disclose your health information to a family member, other relatives, or a close friend or any other person you identify if the information relates to that person’s involvement in your health care if you consent to such a disclosure. If you are unable to agree or object to the use or disclosure, we may disclose such information as necessary if we determine that it is in your best interest.
We May Use or Disclose Your Health Information for Other Purposes Only With Your Authorization: Your written authorization to use and disclose your health information is required in order for us to:
Use and disclose speech therapy notes containing your health information (to the extent we hold any).
Send marketing communications to you. If we will receive payment for making a marketing communication, we will state this in the authorization.
Receive payment in exchange for your health information.
In addition to the above situations, any other uses and disclosures of your health information not described elsewhere in this Notice will be made only with your prior written authorization.
Inspect and obtain a copy of your health information. You have a right to inspect and obtain a copy of your health information that is used to make decisions about your care for as long as Tonalitie Speech Services maintains the information. You may request an electronic copy of this health information that we maintain electronically. This right does not apply to certain health information, including information compiled in reasonable anticipation of or for litigation. Requests for access to health information should be made in writing to Tonalitie Speech Services . You may also ask us to provide a copy of this health information to another person. In that case, your written request must be signed by you, must clearly identify the person to whom you want us to send the copy of your health information, and must state where the copy is to be sent. If access is denied, you will be provided with a written explanation that sets forth the basis for the denial, a description of how you may review those rights and a description of how you may complain.
Request an amendment. You have the right to request that Tonalitie Speech Services amend your health information if it is incorrect or incomplete. Requests for amendment of information should be made in writing to Tonalitie Speech Services , Privacy Office, and you must provide a reason that supports your request to have the information changed. Tonalitie Speech Services may deny your request for an amendment if the request is not in writing and submitted to the Privacy Office. In addition, we may deny your request if you ask us to amend information that: (a) was not created by Tonalitie Speech Services (unless the person or entity that created the information is no longer available to make the amendment); (b) is not part of the medical information kept by Tonalitie Speech Services ; (c) is not part of the information you would be permitted to inspect and copy; or (d) is accurate and complete.
Receive an accounting of disclosures. At your request, Tonalitie Speech Services will provide you with an accounting of disclosures by Tonalitie Speech Services of your health information during the six years prior to the date of your request. However, such accounting will not include certain disclosures, such as those made: 1) to carry out treatment, payment or health care operations; 2) directly to you or your personal representatives; or 3) based on your written authorization. If you request more than one accounting within a 12-month period, Tonalitie Speech Services will charge a reasonable, cost-based fee for each subsequent accounting. Requests for a request of an accounting of disclosures should be made in writing to Tonalitie Speech Services Office.
Request communications by alternative means or at alternative locations. You may request, and we will accommodate, any reasonable written request for you to receive PHI by alternative means of communication or at alternative locations. You must request confidential communications in writing.
Request a general restriction. A general restriction is one that restricts or limits our use or disclosure of your health information. To request a general restriction, you must identify in this request: (i) what particular information you would like to limit, (ii) whether you want to limit use, disclosure, or both, and (iii) to whom you want the limits to apply. We will consider your request but are not required to agree. We have the right to terminate the restriction if: (i) you agree orally or in writing to terminate the restriction, or (ii) if we inform you of the termination, which becomes effective only for your health information created or received after we inform you of the termination.
Request a plan restriction. A plan restriction is one that meets the following three conditions: (a) it is to restrict disclosure of your health information to a health plan for purposes of payment or health care operations; (b) the health information relates solely to a health care item or service for which you, or someone on your behalf, has paid us in full; and (c) the disclosure is not otherwise required by law. If you wish to request a plan restriction, you must do so separately for each service visit, and must make your request at the Tonalitie Speech Services before your visit. Otherwise Tonalitie Speech Services will automatically submit the claim to your health plan on record, if any, for payment. We will not agree to a plan restriction unless we have first received payment in full for the item or service. We will also not agree to a plan restriction if by law we are required to submit your health information to the plan. If we do agree to a restriction, we will not apply the restriction in the event of an emergency.
Obtain a copy of this Notice. To obtain a paper copy of this notice, contact the Tonalitie Speech Services Privacy Office.
Exercise right through a personal representative. You may exercise your rights through a personal representative as permitted or required by applicable law. Your personal representative may be required to produce evidence of authority to act on your behalf before that person will be given access to your information or allowed to take any action for you.
Complaints. If you desire further information about your privacy rights, are concerned that we have violated your privacy rights, or disagree with a decision that we made about access to PHI, you may contact our Privacy Officer. You may reach our Privacy Officer at the contact information provided below. You may also file written complaints with the relevant local, state, national, or international privacy agency. We will not retaliate against you if you file a complaint with us or any governmental agency.
5. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your written consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about your use of our Services.
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent. In order to post a comment or otherwise interact with another user on the site, you must sign up for the Service, and signify that you have been notified of the following policy, herein noted: The integrity of your PHI is important to us. You are hereby notified that any self-publication (including the posting, broadcast, or transfer) of your PHI, that reveals or otherwise contains individually identified provider information posted on or transmitted through the Tonalitie Speech Services Website or App (in the public comments section of articles, in communication with users on the Site, or in the messaging system on the Site) will be considered public disclosure and constitutes a waiver of any protections afforded such PHI under HIPAA, as well as any other applicable regulations, rules or laws. Any and all comments and publications will be considered self-disclosed/waived protections of your PHI to the extent such publication is made.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect via written consent to participate in our competitions.
To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service, when you provide written consent to receive those services.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services. For example, if you are having trouble logging in or utilizing certain functions of the service.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your prior written consent.
6. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, excepting when that share or transfer of information would violate applicable law.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. We do not share, sell, rent or trade any of your information with third parties for their promotional purposes, and all third parties privy to your PHI information have entered into a Business Associate Agreement with us for the purpose of protecting your information.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice and HIPAA regulations. Affiliates would include: parent companies and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to provide services to you. These business partners enter into a Business Associate Agreement with us.
Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
7. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short:We only share information with the following third parties.
We only share and disclose your information with the following third parties, who have entered into Business Associate Agreements with us if they handle PHI. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
Advertising, Direct Marketing, and Lead Generation:
Affiliate Marketing Programs:
Allow Users to Connect to Their Third-Party Accounts: Facebook account, Google account
Cloud Computing Services: Google Cloud Platform
Communicate and Chat with Users, based on their consent to communicate via this method: Facebook Chat, Wix chat by Ascend, Instagram Direct Message and Twitter Direct Message
Content Optimization: Google Site Search and YouTube video embed
Data Backup and Security: Google Drive Backup, Wix
Invoice and Billing:
Retargeting Platforms: Google Ads Remarketing , Google Analytics Remarketing, Facebook Remarketing and Facebook Custom Audience. All ads we place are generic, and we will not disclose PHI to these parties.
Social Media Sharing and Advertising: Facebook advertising, Facebook social plugins, Instagram advertising, Google+ social plugins, LinkedIn social plugins and Twitter social plugins. All ads we place are generic, and we will not disclose PHI to these parties.
User Account Registration and Authentication: Wix
User Commenting and Forums: Wix
Web and Mobile Analytics: Google Ads, Google Tag Manager, Google Analytics, Facebook Analytics and Facebook Ads conversion tracking
Website Hosting: Wix
Website Performance Monitoring: Wix
Website Testing: Wix
9. DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better service.
10. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Services offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
11. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third-party providers who are not affiliated with our Website.
We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
12. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives for the purpose of HIPAA compliance), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
13. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our encryption and security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
14. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org.
15. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Log in to your account settings and update your user account.
■ Contact us using the contact information provided.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
■ Contact us using the contact information provided.
16. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
18. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
19. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org or by post to:
915 Bdwy Blvd.
Kansas City, MO 64105
20. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: email@example.com. We will respond to your request within 30 days.
17. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
every individual who is in the State of California for other than a temporary or transitory purpose and
every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
A. Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
B. Personal information categories listed in the California Customer Records statute: Name, contact information, education, employment, employment history and financial information
C. Protected classification characteristics under California or federal law: Gender and date of birth
D. Commercial information: Transaction information, purchase history, financial details and payment information
E. We have not, and do not collect Biometric information: Fingerprints and voiceprints
F. Internet or other similar network activity: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
G. Geolocation data: Device location
H. Audio, electronic, visual, thermal, olfactory, or similar information: Images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information: Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
J. Education Information: Student records and directory information
K. Inferences drawn from other personal information: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:
Receiving help through our customer support channels
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries
How do we use and share your personal information?
Tonalitie Speech Services collects and shares your personal information through:
Targeting cookies/Marketing cookies
Social media cookies
Click redirects: affiliate links.
Social media plugins: Twitter, Instagram, Linkedin and Facebook. We use social media features, such as the Facebook Like button, and widgets, such as the 'Share This' button on our Website. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our Website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data as well as their additional processing.
More information about our data collection and sharing practices can be found in this privacy notice.
You can opt out from the selling of your personal information by disabling cookies in the Cookies Preferences Settings or clicking on the Do Not Sell My Personal Information link on our homepage.
You may contact us by email at firstname.lastname@example.org, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
The current list of our service providers can be found below.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.
Tonalitie Speech Services has disclosed the following categories or personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.
Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.
Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
Category D. Commercial information, such as transaction information, purchase history, financial details and payment information.
Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.
Category G. Geolocation data, such as device location.
Category H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.
Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.
Category J. Education information, such as student records and directory information.
Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHO WILL YOUR INFORMATION BE SHARED WITH?".
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at email@example.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.