Privacy Policy

Last Updated: May 17, 2021, 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:

You can opt out of being included in Google Analytics at 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:

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.

Social Media Plug-ins

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

Twitter: Twitter, Inc., Attention: Privacy Policy Inquiry, 1355 Market Street, Suite 900 San Francisco, California 94103, USA

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

How Tipofili Uses the Information It Collects

Tipofili uses the information it collects for the following purposes:

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

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:

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:

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:

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.

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

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, 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:

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 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.


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.


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