Togal.ai, LLC (“Togal.ai”) respects your right to privacy. As such, we have outlined the following policy. This details what information we collect, how we use it, and what rights you have with regards to such information.
E.U. GENERAL DATA PROTECTION REGULATION
Togal.ai has taken steps in an effort to comply with the EU GENERAL DATA PROTECTION REGULATION (“GDPR”) as set forth by the Council of the European Union and European Parliament, which became enforceable May 25, 2018, regarding the collection, use, transmission, processing, and retention of personal identifiable data of natural persons from European Union member countries. Togal.ai are committed to protecting your data in a secure and transparent manner. Togal.ai processes, uses, and exchanges personal data for our legitimate business purposes only in the limited uses described herein.
INFORMATION COLLECTED FROM OUR SITES AND SERVICES
Information You Provide: If you contact us or register to receive more information about our Services, create an account with us, purchase products or services, send us an email, or share personal information with us in any other way, we collect the information you share. Depending on what information you choose to provide, this may include your name, email address or billing information. You do not always have to share this information with us, but without it, you may not be able to access certain content or features or use certain Services.
Posted: If you post information on public areas of the Sites, the Services (or elsewhere on the Internet) that information may be collected and used by anyone, including Togal.ai.
Information from Other Sources: We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. This information allows us to verify information that you have provided to Togal.ai and to enhance our ability to provide you with information about our business, products, and Services.
HOW DO WE USE THE INFORMATION WE COLLECT?
The short answer is that we generally use this information to help Togal.ai provide you with better service, which in turn helps cover the cost of providing our Sites and our Services. Among other things, the information we collect can enable Togal.ai to: to provide the Services fulfill your requests for Services and validate your user rights provide access to certain areas, functionalities, and features of Togal.ai’s Services contact and communicate with you, conduct research and analysis on behalf of Togal.ai and/or Togal.ai’s clients, provide anonymous reporting for internal and external clients, customize the content and advertising you see, provide you with additional information we think is of interest to you, measure interest in Togal.ai’s Services, research and develop new products and Services, ensure internal quality control, provide you with customer or technical support, process payment for products and services, prevent potentially prohibited or illegal activities, when we have a legitimate interest, such as direct marketing, research purposes (including marketing research), network and information security, fraud prevention and enforcement of legal claims, use information for purposes which you otherwise consent to.
WHEN DO WE SHARE OR DISCLOSE YOUR INFORMATION?
Anonymous Information: The Services may track the total number of visitors to the Services, the number of visitors to each page of the Services, browser type, IP addresses, external websites linked to and other usage statistics collected and used in aggregate form collected through the Services and we may analyze this data for trends and statistics in the aggregate but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Services, track users’ movement, and gather broad demographic information for aggregate use. We may freely share anonymous user information with others, such as clients, advertisers, sponsors and business partners.
Personally Identifiable Information: In more limited circumstances, we may share personally identifiable information we have collected. For example: Your personal information may be transferred to any service providers who assist us in providing the Services, like technical agents, payment processing vendors, companies that help us market and advertise to you, other subcontractors, and our affiliates, agents and consultants. If you give us permission, we may share your personally identifiable information with third parties who may send you marketing and promotional information. As in any transaction, if you provide your credit card information to us for purchases, your credit card company will be provided with relevant information about us, services purchased, cost and other information necessary to process the transaction. We may disclose your personal information if permitted or required by law, or where we reasonably believe such action is necessary in order to protect or defend our interests or the interests of our employees or users or business partners, such as to protect, establish or exercise our legal rights or defend against legal claims, or when we believe in good faith that such disclosure is necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, threats to our property, suspected fraud, or violation of Togal.ai’s Terms of Service. We may share personally identifiable information during due diligence or in connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or Togal.ai.
INTERNATIONAL DATA TRANSFERS
You agree that all personal information submitted to or collected via or by Togal.ai may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request. We will endeavor to ensure that international transfers of personal information are supported by an adequacy mechanism (where required by law).
OPT-OUT (RIGHT TO OBJECT TO PROCESSING) COMMUNICATIONS, OPT-OUT AND ACCESS
You have the right to object to and opt out of certain uses and disclosures of your personal information. Where you have consented to Togal.ai’s processing of your personal information, you may withdraw that consent at any time and opt out of further processing by sending an email to email@example.com. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
THIRD PARTY SITES AND SERVICES
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Togal.ai does not endorse or make any representations about third-party websites, services or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
RIGHTS OF ACCESS, RECTIFICATION, ERASURE AND RESTRICTION
Although Togal.ai makes good faith efforts to provide Individuals with access to their personal information, there may be circumstances in which Togal.ai is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question, where the request is manifestly unfounded or excessive, or where it is commercially proprietary. If Togal.ai determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Togal.ai will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
We take your security seriously and take reasonable steps to protect and secure your personal information from unauthorized access, use, and disclosure, including through secure sockets layer, password protection and, for certain transmissions to our Services, encryption. Any information collected by Togal.ai is stored on servers that Togal.ai manages, using standard security procedures and practices appropriate to the nature of the information. Although we take reasonable security measures to protect your personal information, please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Togal.ai cannot guarantee or warrant the security of any information you transmit on or through the Sites or Services and you do so at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
The Services are not directed to children under 18 years of age, and Togal.ai does not knowingly collect personal information from children under 18 years of age. If you learn that your child has provided us with personal information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any personal information from children under 18 years old, we will promptly take steps to delete such information.
Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” any of our users who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information we share with third parties or corporate affiliates for their direct marketing purposes. That notice will identify the categories of information shared, the third parties and affiliates with which it was shared, and their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to email@example.com. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty days for a response.
Revised February 28, 2020