Privacy Policy

Last Updated: May 17, 2021

Tipofili.com, including its subdomains together with all of their features and content and related or commonly-owned or operated websites (the “Website”), is made available by Tipofili LLC (“Tipofili”).

How This Privacy Policy Applies

Your privacy is very important to Tipofili , and in order to best protect your information, Tipofili has adopted this privacy policy (“Privacy Policy”), which applies to any and all information you submit to Tipofili in connection with your access to and/or use of the Website. This Privacy Policy describes the information Tipofili collects from you through the Website, how Tipofili uses that information, and its legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to Tipofili. It also covers whether and how that information may be shared and your rights and choices regarding such information.

By using the Website, you are accepting the practices described in this Privacy Policy (including new versions of this Privacy Policy when and as they go into effect), and Tipofili’s Terms and Conditions of Use, which governs this Privacy Policy and contains all disclaimers of warranties and limitation of liabilities, and which constitutes a legally binding agreement between Tipofili and each individual, corporation, limited liability company, partnership, association, or other entity or party (a “Person”) that visits or uses the Website (collectively, “Users,” and each, a “User”, “you” or “your”). Capitalized words not defined in this Privacy Policy are defined in the Terms and Conditions of Use.

What Information Tipofili Collects and Receives

In order for you to use the Website, Tipofili needs to collect and process certain information, which depending on how you use the Website, may include:

Information you provide by using the Website, such as by completing forms the Website, such as your name, email address, mailing address, or telephone number. We may ask for this information if you subscribe to our newsletter or contact us;
Details of any requests or transactions you make through the Website Tipofili offers products for sale through the Website and partner with Stripe, Inc. and PayPal, Inc. to facilitate in the transaction, in which case the payment information you submit will be collected and used by the payment processor in accordance with their respective privacy policies;
Information that is not personally identifiable, but that relates to your usage of the Website or that is necessary for the proper functioning or improvement of the Website, including: (i) times and dates and the extent of your usage of the Website; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Website; (iii) device keyboard settings; (iv) usage history such as areas and pages within the Website that you access or use and/or which buttons on the Website you click on; (v) the search terms you entered into a search engine that may have led you to the Website; (vi) the Internet service provider (ISP) or mobile platform you use, and (vii) other device and Website access information such as your browser type, operating system, Internet Protocol (IP) address, referring/exit pages, and other unique device identifiers; and
Communications you send to Tipofili, such as when you request support, submit comments or questions, or report a problem to Tipofili.

You can opt out of being included in Google Analytics at https://tools.google.com/dlpage/gaoptout. For more information about our use of data analytics to protect and improve our Website, see Cookies and How We Utilize Them below.

Tipofili also collects and maintain aggregated, anonymized, or pseudonymized information to protect the safety and security of the Website, improve the Website, or comply with its legal obligations.

You may decline to provide Tipofili with some or all of your information. However, this will limit your ability to use the Website.

Types of Cookies Tipofili Utilizes

Tipofili uses the following types of cookies and other technologies:

Security: Tipofili secures the Website with cookies that facilitate security features and allow Tipofili to detect activity that might violate the Terms and Conditions of Use, such as unauthorized access or activity.
Localization: Some cookies help Tipofili provide localized experiences, such as displaying the Website in the local language.
Site Features and Services: Certain cookies provide greater functionality to the Website and help Tipofili deliver our products and services.
Performance: Tipofili uses performance cookies to help route traffic between servers and understand how the Website is performing so Tipofili can provide Users with the best experience possible.
Analytics and Research: Cookies and other technologies also help Tipofili to understand, improve, and research features and content on the Website, such as by using Google Analytics, which you can opt out of at https://tools.google.com/dlpage/gaoptout.
Marketing and Online Behavioral Advertising: Cookies help us deliver targeted advertisements through web browsers and on social media platforms based on your activity on the Website and to track the performance of those ads. In some cases, our partners may use cookies to provide us with information about your interactions with their services. Those third-party cookies would be subject to such third-party service’s privacy policies. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. Visit http://optout.aboutads.info/ to opt out of having your online behavior collected for advertising purposes.

Limiting or Blocking Cookies and Our Do Not Track Policy

Your browser may give you the ability to control cookies, which may depend on the type of cookie, and browsers can be set to reject browser cookies. However, blocking or deleting cookies may prevent you from using most of the Website.

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. If you block cookies, certain features on the Website may not work. If you block or reject cookies, not all of the tracking described in this Privacy Policy will necessarily stop.

Note that certain options you select are specific to certain browsers and devices.

Web Beacons

The Website may contain electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Website is used.

Tipofili uses third parties to gather information about how you and others use the Website. For example, Tipofili will know how many Users access a specific page and what Website Content they clicked on. Tipofili uses this aggregated information to understand and optimize how the Website is used.

Tipofili may implement the use of certain social media plug-ins (e.g., Facebook, Twitter, YouTube) to allow you to communicate with such services and interact (e.g., “like” or “comment”) with various Website content. The social media plug-in, if and when implemented, will enable a direct communication between your end user device and the servers of the applicable social media provider, allowing the applicable social media provider to communicate with you and collect information about you browsing the Website. This processing is based on Article 6, Section 1(f) of the EU general data protection regulation 2016/679 (“GDPR”) and represents Tipofili’s legitimate interest to improve the User experience and to optimize those services and functionalities offered via the Website. If you decide to use a social media plug-in that Tipofili implements on the Website, Tipofili may transfer your personal data, whether or not you have a registered user account with the applicable social media provider. Tipofili is not responsible for the content and the data collection on respective third-party websites or apps and that Tipofili neither controls the extent of personally information collected by the respective plug-in provider nor knows the processing’s purpose or the period your personally information will be retained. For further information as to how and for what purpose certain social network providers process your data, please see the relevant privacy policies of the three main social network providers, and their notification when you connect to the social network in question.

Facebook: Facebook, Inc., Attention: Privacy Operations, 1601 Willow Road, Menlo Park, California 94025, USA

https://www.facebook.com/policy.php

Twitter: Twitter, Inc., Attention: Privacy Policy Inquiry, 1355 Market Street, Suite 900 San Francisco, California 94103, USA https://twitter.com/en/privacy

YouTube: Google LLC d/b/a YouTube, 901 Cherry Avenue, San Bruno, California 94066, USA

https://policies.google.com/privacy

How Tipofili Uses the Information It Collects

Tipofili uses the information it collects for the following purposes:

To protect the Website;
To enable Tipofili to provide you and other Users with the Website, and to improve and promote the Website and services;
To address inquiries and respond to customer service requests, questions, and comments;
To contact you with newsletters, offers, promotions, and other product specials or to customize your experience on the Website;
To track and analyze use of the Website and Tipofili’s services, such as to identify trends, conduct data analysis, and determine the effectiveness of marketing and promotion efforts, and other service offerings, so that Tipofili can improve how its performance and provide Users with the best experience possible;
To maintain security and to enforce the Terms and Conditions of Use and comply with applicable law; and
For other purposes that Tipofili believes are necessary to protect its rights and the rights of others, or as otherwise described to you at the time of collection.

California Users

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for those third parties’ direct marketing purposes. As explained elsewhere in this Privacy Policy, Tipofili will not sell or transfer your personal information to any third-party companies for their direct marketing purposes without your consent. California Users who wish to request further information about Tipofili’s compliance with this statute or who have questions more generally about the Privacy Policy and Tipofili’s privacy commitments to its Users should not hesitate to contact Tipofili at info@tipofili.com.

European Union Users

European Union data protection law requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Tipofili’s lawful bases include:

Consent: In certain cases, you have affirmatively provided Tipofili with your consent to collect your personal data for a specific purpose, such as providing your name and email address when you sign up for our newsletter or register for an Account.
Contract: Tipofili may need your personal data to comply with contractual obligations to deliver the Website, such as fulfilling subscriptions or transactions made through the Website.
Legal Obligations: Sometimes the law requires the collection and use of your data, such as applicable tax laws may require Tipofili to retain records of payments made through the Website.
Legitimate Interests: This is a technical term that means Tipofili has a good and fair reason to use your data and in ways which do not harm your interests and rights, such as to pursue Tipofili’s legitimate interests in a way that might reasonably be expected as part of running its business and that does not materially impact your rights, freedom, or interests. For example, Tipofili uses identity, device, and location information to prevent fraud and abuse and to keep the Website secure, may also send you promotional communications about the Website and services subject to your right to opt out, analyze how Users interact with the Website so Tipofili can understand better what elements do or do not work well, thereby facilitating improvements and developments in the quality of the online experience for all Users.

How Tipofili Shares the Information It Collects

Information Tipofili Never Shares Publicly

The following personal information is never publicly displayed or revealed to other Users:

Your name;
The date you register for any services Tipofili provides through the Website;
Your email address, IP address, mailing address, or phone number;
Any other identity verification information or documentation;
Any payment information you provide; and
Communications you send to Tipofili.

Information Tipofili Shares with Trusted Third-Party Service Providers

Tipofili may share certain information pertaining to you with certain trusted third-party service providers to help provide, improve, promote, or protect the Website, such as when Tipofili partners with payment processors or use services to help manage ads on other websites. When Tipofili shares data with third-party services to help deliver the Website and Tipofili’s services, Tipofili requires those service providers use your information only for the purposes Tipofili has authorized and protect your personal information at least to the same standards Tipofili does. Tipofili may also share information that is aggregated and anonymized in a way that it does not directly identify you.

Information Tipofili Shares to Protect Tipofili and Comply with the Law

Tipofili reserves the right to disclose information Tipofili collects from or about you when doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect Tipofili’s legal rights, property, or the safety of Tipofili , Users, or others. You hereby authorize Tipofili to share or disclose your personal information, including, without limitation, any content, records, or electronic communications of any kind, when Tipofili determines, in its sole discretion, that the disclosure of such information is necessary to identify, contact, or bring legal action against you if and to the extent:

You are or may be violating the Terms and Conditions of Use or this Privacy Policy;
You are interfering with the rights or property of Tipofili or a third party;
You are violating any applicable law, rule, or regulation;
Necessary or required by any applicable law, rule, or regulation; and/or
Requested by governmental authorities in the event of any investigation, act of terrorism, or instance of local, regional, or national emergency.

In the event that Tipofili is acquired by or merged with a third-party entity, or sells all or substantially all of its assets, Tipofili reserves the right, in any of these circumstances, to transfer or assign the information and content it has collected from Users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, Tipofili may not be able to control how your personal information is treated, transferred, or used.

Links to Other Websites and Services

The Website may include links to other websites or services whose privacy practices may differ from Tipofili’s privacy practices as described in this Privacy Policy. When you click or otherwise use a link to an external website or service, the privacy policy and data processing disclosures for that website or service govern.

Data Retention

Tipofili will retain the information collected from or about you as long as necessary to provide you with the Website or Tipofili’s services, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with Tipofili’s legal obligations, resolve disputes, enforce our agreements, and protect Tipofili’s legal rights. Additionally, Tipofili may retain indefinitely any aggregated, anonymized, or pseudonymized information collected, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.

Cross-Border Data Transfers

Tipofili is based in the United States so your information will be collected and processed in the United States, which has its own laws governing data protection and access to it, including by the government. If you reside outside of the United States, be advised that the rules that protect your personal information under United States federal, state, and local law may differ from those of your home country.

With respect to any personal information that may be originally collected and stored in the European Economic Area, if and when Tipofili transfers your personal information to countries outside the European Economic Area, it will do so under the Commission’s model contracts for the transfer of personal information to third countries (i.e., standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate). For a copy of these Standard Contractual Clauses, please contact Tipofili at info@tipofili.com.

Children’s Privacy

The privacy of children is of the utmost importance, and Tipofili is committed to complying with the federal Children’s Online Privacy Protection Act (COPPA). Tipofili does not knowingly collect, use, or disclose personal information from children under the age of thirteen (13). If Tipofili ever discovers that it has inadvertently collected personal information from a child under the age of thirteen (13) on or through the Website Tipofili will delete it from its records as soon as possible. If you are a parent or legal guardian of a child under the age of thirteen (13) and believe that Tipofili has collected personal information from your child, please email us at info@tipofili.com, and Tipofili will take steps to delete such personal information from its records as soon as possible.

Accessing Your Information

Users residing in certain countries, including citizens or residents of the European Economic Area, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of such User’s personal information. Even after you request Tipofili deletes your personal information, Tipofili may retain certain information as required by law or as necessary for its legitimate business purposes.

More specifically, these Users have the following rights:

The right to require free of charge (i) confirmation of whether Tipofili processes your personal information and (ii) access to a copy of the personal information retained;
The right to request proper rectification, removal or restriction of your personal information;
Where processing of your personal information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal information transmitted directly to another company, where technically feasible (data portability);
Where the processing of your personal information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and
The right to take legal actions in relation to any breach of your rights regarding the processing of the personal information, as well as to lodge complaints before the competent data protection regulators.

As far as Tipofili processes your personal information on the basis of its legitimate interests, you can object to processing at any time. You can find a detailed description of Tipofili’s processing activities and the legal basis herein. If you object to such processing, Tipofili will ask you to state the grounds of your objection to examine the processing of your personal information and decide whether to adjust the processing accordingly.

Email Notifications

Tipofili want to communicate with you only if you want to hear from us. Tipofili will send you email relating to your transactions on or through the Website. You may also elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time by adjusting your notification settings. Tipofili will also send you service-related announcements when and as necessary. Tipofili will try to keep emails to a minimum and give you the ability to opt in to any marketing communications.

Tipofili maintains a strict no-spam policy. Tipofili will not use false or misleading subjects or email addresses, identify the message as an advertisement in a reasonable way, include Tipofili’s physical address, monitor third-party email marketing services for compliance, honor opt-out/unsubscribe requests quickly, and allow Users to unsubscribe by using the link at the bottom of each email. If you are having problems unsubscribing, contact Tipofili at info@tipofili.com by forwarding the email communication and including the word “Unsubscribe” in the subject line and Tipofili will use reasonable efforts to remove you within seven (7) business days. Please note that Tipofili will not process any unsubscribe requests submitted as direct replies to any newsletter.

Security

Tipofili takes security seriously, and the security of your personal data is important to us. Tipofili follows industry-standard practices to protect the data Tipofili collects and maintains, including using Transport Layer Security (TLS) to encrypt information as it travels over the Internet.

However, the Internet is, by nature, not a secure environment and the nature of security risks is constantly evolving as are the technical and organizational industry standards relating to management of those risks. While Tipofili strives to keep current our security technology and will review, refine, and upgrade its security technology as Tipofili deems appropriate based on new tools that may become available in the future, the complete security of any information collected, stored or used by Tipofili cannot therefore be guaranteed. In the unlikely event that an unauthorized third-party compromises Tipofili’s security measures, Tipofili will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use, or disseminate such information.

Updates to this Privacy Policy

Tipofili may change the terms of this Privacy Policy at any time. Whenever Tipofili makes a material change, Tipofili will post on the Website or send you an email. The effective date of the most recent version of this Privacy Policy will appear at the top of this page. New versions of this Privacy Policy will never apply retroactively.

Contact

Questions or comments about this Privacy Policy should be sent by email to info@tipofili.com or mail to 310 East 23rd Street, Suite 8F, New York, NY 10010.