Cookies & Privacy Policy
Last updated: April 2023.
“Tarotpolis, Inc.”, 2810 N Church St, PMB 30811, Wilmington, Delaware 19802-4447 (“Tarotpolis”, “We”, “Us” or “Our”) values your privacy and is committed to safeguarding the personally identifiable information (“Personal Information”) entrusted to us by our Users and Members (“Your” or “Your”) of our Platforms. Tarotpolis has implemented this Privacy Policy to govern the use of Personal Information that we collect through the Platforms, including Personal Information you send to us. This Privacy Policy does not govern Personal Information collected from any other source or in any other manner. This Privacy Policy is intended to provide you with information as to: (i) the type of information that is collected, (ii) how the collected information is used and with whom it is shared; (iii) how we intend to protect the information; and (iv) how you can access such information and have it modified and/or removed.
This Privacy Policy may be changed from time to time. We will post changes on the Site, and we reserve the right to make changes without prior notice. Such changes are effective upon posting. Please review this Privacy Policy often so that you will remain abreast of our current policies including policies concerning the gathering and use of information that may be collected on our Site. You are responsible for making sure you are aware of the provisions of the Site’s most current Privacy Policy. You can see when the Privacy Policy was last modified by checking the “updated” date.
This Privacy Policy is incorporated by reference in and made a part of our Terms and Conditions of Use of the Site and explains how users’ information and data is collected and used. Capitalized terms here have the same meaning as the one assigned in the Terms.
1. What Data do we collect about you?
When you visit or communicate on the Platforms, we may collect certain information from you (“Personal Data”), including but not limited to:
· Information you provide to us, such as:
Identifiers, such as your name, address, email, telephone number.
Transcripts and recordings of your communications with Advisors, Members, and us.
Responses to surveys that we send and that you respond to.
Information you provide on Tarotpolis message boards.
Your payment information, including credit card number(s) and related billing information.
Any personal information you choose to share through your use of the Platform, such as your health (physical and/or mental) information, sexual orientation, etc. Please note that if you do not wish to disclose this information, you should not do so.
For Advisors, applicable tax forms.
· System-generated data, such as:
Your web browser and usage information, including IP (Internet Protocol) address, browser types, page view tallies, time spent on each page, page browsing information, operating system and type of device used.
2. How do we collect this Personal Data?
We may collect the information in Section 1 when you sign up to use the Platform and when you communicate with other members of the Platform, including through:
Our registration processes.
Chats in which you participate through our Platforms.
Phone calls in which you participate through our Platforms.
Messages that you send or receive though our Platforms.
If you register for the Platforms via a third-party social media platform, we may receive information from that third-party platform about you.
If you sign up as an Advisor, although we are not responsible for vetting Advisors, we may use a third party to confirm your credentials, including relevant licenses and certifications.
Please note that if we receive your information from third parties as mentioned above, the data you provide to such third parties is also subject to the third party’s privacy policy.
In addition, we may collect information through the following methods if you use the Platform or visit our social media pages or other pages located on third-party websites:
Your communications with Tarotpolis,
Your requests for information, news, and other content,
A technical support request you submit, or
Your participation in a Tarotpolis promotion.
We may also collect information from our direct interactions with you, publicly available data or data provided by third-party sources, such as marketing opt-in lists.
3. IP Address
An IP (Internet Protocol) address is a number that is automatically assigned to your computer by your internet service provider when you log on. [The Site anonymizes the collection of IP addresses via Google Analytics, which you can read more about here: https://support.google.com/analytics/answer/2763052?hl=en][1]. Some IP address information is collected, which may help us identify information including, but not limited to, geographic trends and/or usage information. However, full IP addresses identifying individuals are not collected.
4. Other Information
When you access the Site, the Site will automatically receive some information about your use of the Service. The type of information that is automatically collected by the Site includes, but is not limited to, such things as the date and time of access of the Site, the anonymized Internet protocol (IP) address of the computer that you are using, the domain and host from which you access the Internet, your browser software and operating system, the referring website address, and the specific activities you are engaged in while visiting the Site. This aggregate tracking information is used to help us to improve and enhance the Site experience for all its visitors.
5. Your Consent and Personal Information.
We will ask for your consent when we collect your Personal Data, such as when we ask for your e-mail address or for your consent to our use of cookies, as explained below. Your consent may also be given implicitly for a particular purpose. For example, when you submit your Personal Data to us by emailing us or providing us with reviews, you are consenting to the collection, handling, use and disclosure of your Personal Data for the purposes of responding and/or posting your reviews.
6. How do we use your Personal Data?
We will only collect and use your information when we have a legitimate reason for doing so. In that case, we will only collect information reasonably necessary to provide our Services through our Platforms. We may use your Personal Data for the following purposes:
· to deliver materials, information, and our Services to you,
· to give you notice of and/or resolve any problems that may arise in connection with our services,
· to better understand the needs and interests of our customers,
· to analyze the success of our products and Services and Platforms,
· to manage our Platform’s interactive functionality,
· to help the Platforms improve and enhance the experience for all of its visitors, and customize the content on our Platforms,
· for compliance with our legal and regulatory obligations,
· as otherwise reasonably required to provide customer services and maintain the Platforms,
· to investigate potential breaches of the Terms,
· to investigate potentially unlawful activity,
· for any other purpose outlined in this Privacy Policy and/or the Terms and Conditions of which this Privacy Policy is a part,
· and as permitted by law.
We may, under certain circumstances, also use your Personal Data to contact you via direct postal mail and/or electronically to the extent such activity is permitted by law and, with your consent, regarding your relationship with us. This information may also be used to help the Platform and its commercial partners deliver targeted advertisements, promotions, and other initiatives to you, but only if you affirmatively consent to such uses.
7. What is our legal basis for using your Personal Data?
Your Personal Data can only be used if we have a legal basis for doing so. Our legal basis will be one of the following:
Keeping our contracts and agreements with you. We may need your Personal Data to provide our Services.
Legal obligations. We may have a legal responsibility to collect and store your information.
Legitimate reasons. We may sometimes collect and use your Personal Data if we have a legitimate reason to do so and if it is reasonable in light of your rights and freedoms.
Substantial public interest. We may process your Personal Data in accordance with government regulations or guidance.
Consent. When you agree to us collecting your Personal Data, or sensitive Personal Data, for example when you check a box that indicates you agree that we may use your personal data in a certain way.
8. Information Sharing and Disclosure
a. Affiliated Entities: In order to provide you with efficient and reliable Services and to improve product and Platform options available to you, we may share your Personal Data with our affiliated entities with your prior consent, in which case your Personal Data will be collected, used, disclosed, managed, and stored in accordance with this policy as set forth herein. Our affiliates are companies controlled or owned by us, or companies that control us, or are under common control with us. If you use the Platforms from any country outside the United States, the various communications will necessarily result in the transfer of information across international boundaries, and by visiting the Site, you consent to these transfers as required or permitted by applicable law.
b. Trusted third-party service providers: From time to time, we may hire third parties to assist us with certain functions and services, such as data processing, computer software and website maintenance and development, promotional and marketing services, customer service, professional, legal, or accounting services and/or business and sales analysis. We may share your Personal Data, without restriction (and regardless of whether you have chosen to limit our sharing of your Personal Data as collected on the Site) with companies that we hire to perform services for us. In such situations, we require that these companies agree to maintain the confidentiality of your Personal Data and to comply with the safeguards described in this Privacy Policy. These companies have access to the Personal Data needed to perform their functions but are not permitted to share or use such information for any other purposes. Furthermore, in compliance with privacy laws, we also provide our opt-out lists to non-affiliated third-party companies so that communications sent by these companies on our behalf do not get sent to addresses appearing on our opt-out lists.
c. Business transfers: We may share your Personal Data with other parties in connection with a company transaction, such as a merger, sale of a company or assets, due diligence, change or control or acquisition of all or a portion of our business by another company, or in the event of bankruptcy or related proceedings.
d. Legal requirements. Your Personal Information may be disclosed to non-affiliated third parties as either permitted by or to comply with applicable laws and regulations. We may disclose Personal Data if we believe it is necessary to investigate, prevent, or take action regarding suspected illegal activities or fraud, situations involving the physical safety of any person, violations of our Terms and Conditions, or otherwise in accordance with applicable law. For example, Tarotpolis may disclose your Personal Data to comply with investigations by regulatory authorities or enforcement agencies in the United States of America or elsewhere, or to protect against or prevent actual or potential fraud. Furthermore, Tarotpolis may disclose your Personal Data if it has a reasonable, good faith belief that it is required to do so by law, court order or legal process, or necessary and/or appropriate to: (i) protect the rights, property and/or safety of Tarotpolis or any other person or entity or (ii) prevent or take action concerning any alleged illegal activity or breach of the Terms and Conditions or Privacy Policy of the Platforms.
e. Services Improvement: We may use cookies and similar tracking technologies to collect and analyze information about your use of our Services and to improve and personalize your experience. By using our Platform and Services, you agree to our use of cookies as described in this Privacy Policy.
9. Disclosure of Information to Non-Affiliated Third Parties
We do not sell or market the Personal Data collected on the Site to non-affiliated third parties for their marketing purposes without your express consent. Other aggregated and/or anonymous information may be disclosed without your consent. We may disclose aggregated statistics about visitors to our Site, along with anonymous information concerning individual visitors to our Site. We may combine anonymous information and/or aggregate information we collect with additional anonymous information collected from other sources. We may share anonymous information (including aggregate information) we collect regarding our Users with third parties (such as advisors, promotional sponsors, and investors) for various business purposes including conducting general business analysis and developing website content and services.
10. Disclosure of Information to Non-Affiliated Third Parties
We do not sell or market the Personal Data collected on the Site to non-affiliated third parties for their marketing purposes without your express consent. Other aggregated and/or anonymous information may be disclosed without your consent. We may disclose aggregated statistics about visitors to our Site, along with anonymous information concerning individual visitors to our Site. We may combine anonymous information and/or aggregate information we collect with additional anonymous information collected from other sources. We may share anonymous information (including aggregate information) we collect regarding our Users with third parties (such as advisors, promotional sponsors, and investors) for various business purposes including conducting general business analysis and developing website content and services.
11. Retention of Personal Data
We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements, unless we are required by law, regulation or for litigation and regulatory investigations to keep it for longer periods of time. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it, or, if this is not possible, then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
Information posted on the Site may continue to be displayed on this Site, or on any successor website for as long as the Site or any successor Site is available and may be archived by third party websites. You may request access to your Personal Data in order for it to be updated or removed by writing to info@tarotpolis.de. To the extent permitted by applicable law, we reserve the right to refuse requests for the removal of Personal Data from the Site.
12. Your Privacy Rights
Under certain circumstances and in accordance with applicable data protection laws, you have the following rights concerning your Personal Data:
12.1 Your Privacy Rights under United States laws.
a. Right to know. You have the right to know what Personal Data we have collected, sold, or disclosed about you over the past 12 months.
b. Right to access. You have the right to confirm whether we process your Personal Data and request a copy of your Personal Data held by us.
c. Right to rectification. You have the right to request the correction of any inaccurate or incomplete Colleted Data held by us.
d. Right to erasure. You have the right to request the deletion of your Personal Data held by us, subject to certain exceptions.
e. Right to restrict processing. You have the right to request the restriction of the processing of your Personal Data under certain circumstances.
f. Right to data portability. You have the right to move, copy or transfer Personal Data easily from one organization to another.
g. Right to object. You have the right to object to our processing of your Personal Data on grounds relating to your particular situation, in certain circumstances.
h. Right to opt out. You have the right to opt out of targeted advertising, the sale of Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
i. Right to limit the use of sensitive personal information. You have the right to limit the use of your Sensitive Personal Information (as defined in the California Consumer Privacy Act, as amended by the California Privacy Rights Act) to specifically permitted purposes.
12.2 California Privacy Rights
Pursuant to California Consumer Privacy Act of 2018 (“CCPA”), residents of the State of California have the right to request from companies conducting business in California certain information regarding such business’ disclosure of that California resident’s Personal Information (as defined in the CCPA) to third parties (and in some cases affiliates) for their direct marketing purposes within the immediately preceding the request calendar year. Alternatively, the law provides that a company may comply with this requirement, as we do, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing Personal Information with third parties for these third parties’ direct marketing purposes and information on how to exercise that choice. At this time, we do not share Personal Information with third parties for these third parties’ direct marketing purposes. However, if we do so in the future, we will provide you with a choice prior to sharing your Personal Information with third parties for their direct marketing purposes. If you do not opt-in or if you do not choose to opt-out at the time the Site offers that choice, we will not share your information with that identified third party for its direct marketing purposes.
In addition, if you are a California resident, you have the right to delete Personal Information we have collected from you.
If you are a California resident who would like information on how to exercise your rights concerning third party disclosures or the deletion of your Personal Information, you may send an email to this address:
info@tarotpolis.de
or mail your request to
Attn: Privacy Officer
Tarotpolis Inc.
2810 N Church St
PMB 30811
Wilmington, Delaware 19802-4447
In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days.
We have a duty as the holder of certain Personal Information to verify your identity when completing requests to provide or delete Personal Information to ensure that dissemination of that information would not cause harm to you if the request was submitted by another person. To verify your identity, we will request and collect additional Personal Information from you to match it against our records. We may ask for additional information or documentation if we feel it is necessary to confirm your identity with the necessary degree of certainty. We may communicate with you through email, a secure message center, or other reasonably necessary and appropriate means. We do have the right to deny requests under certain circumstances. In such cases, we will notify you of the reasons for denial. We will not provide you with specific pieces of Personal Information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that Personal Information, your account with us, or the security of our systems or networks. In no event will we disclose, if we have collected it, your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.
The CCPA requires specific disclosures for California residents which are set forth below -
Categories of Personal Information We Collect
· Identifiers, such as your name, alias, address, phone numbers, IP address.
· Internet or other electronic network activity information;
· inference data, such as information about your preferences.
Categories of Personal Information Shared with Third Parties (Service Providers)
· Identifiers, such as your name, address, phone numbers, IP address.
· Internet or other electronic network activity information; and
Business Purpose for Which Information May Be Used or Disclosed
· Maintaining our services. We use information to ensure our services are working as intended, such as tracking outages or troubleshooting bugs and other issues that you report to us.
· Auditing and measurement. We use information for analytics and measurement to understand how our Services are used, as well as to fulfill obligations to our partners like publishers, advertisers, developers, or rights holders. We may disclose non-personally identifiable information publicly and with these partners, including for auditing purposes.
· Protecting against security threats, abuse, and illegal activity. We use and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity.
· Research and development. We use information to improve our services and to develop new products, features and technologies that benefit our users and the public.
· Use of service providers. We share information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures.
· Legal reasons. We also use information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement.
12.3 Rights under the General Data Protection Regulation (2016/679) (“GDPR”)
Where the GDPR applies and in accordance with any other applicable law, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we may require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please contact us at info@tarotpolis.de. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case. For the purposes of GDPR, the data controller is: Tarotpolis, Inc.
· Access - You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. In order to obtain information and access to data held by you, please contact us at info@tarotpolis.de.
· Portability - You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal information or its processing once received by the third party.
· Correction - You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
· Erasure - You may request that we erase the personal information we hold about you in the following circumstances:
· where you believe it is no longer necessary for us to hold the personal information;
· we are processing it on the basis of your consent and you wish to withdraw your consent;
· we are processing your data on the basis of our legitimate interest and you object to such processing;
· you no longer wish us to use your data to send you marketing; or
· you believe we are unlawfully processing your data.
· Restriction of Processing to Storage Only - You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:
· You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
· We wish to erase the personal information but you want us to simply restrict the use of that data;
· We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
· You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
· Objection - You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
· Withdrawal of Consent - Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by emailing us at info@tarotpolis.de.
12.4 Your Privacy Choices – Exercise of Rights.
You may exercise your privacy rights listed in 12.1 – 12.3 above by writing to info@tarotpolis.de. Additionally, you may write to info@tarotpolis.de to check, change, or confirm a privacy choice. You may make your privacy choice at any time, which will remain in effect until you instructed otherwise by you.
13 Use of Cookies
The Site makes use of “cookies” – small data files which we may send to your computer on the basis of the information that we have collected about your visit. They contain information allowing us to recognize when you are visiting the Site and to keep track of your preferences. Through the use of a cookie, we also may automatically collect information about your online activity on our Site, such as the web pages you visit, the links you click, and the searches you conduct on our Site. Cookies are stored in your computer’s browser or on your hard disk and can then be retrieved by the Site.
Cookies Employed by the Site:
· Site functionality cookies. These cookies enable you to browse our online Services and use features such as shopping baskets and wish lists.
· Site analytics cookies: We use these cookies to measure and analyze how our customers use our online Services. An example is counting the number of different people visiting our Site or using a particular feature rather than the total number of times the Site or feature is used. This allows us to continuously improve our online Services and your shopping experience.
· Customer preference cookies. When browsing or shopping online, our online Services will remember preferences you make (for example your username, language, or location). This improves your experience and makes your browsing simpler, easier, and more personal to you.
· Social sharing cookies. We use cookies to allow you to share content directly on social networking/sharing sites like Instagram, Facebook, and Pinterest. Examples would be if you wanted to ‘like’ or ‘tweet’ about a product advertised on our online Services.
· Advertising cookies. We place adverts on a number of third-parties’ websites. We use cookies to control how often you are shown a particular advert on these websites, so you do not see the same advert too frequently. We do not collect any personal data within these cookies.
· Third-party cookies. Some of the cookies described above are stored on your machine by third parties when you use our online services. We have no control over these cookies or how the third parties uses them. They are used to allow third parties to provide a service to us, for example analytics. For more information on these cookies and how to disable them, please see the individual third party’s privacy policy listed below.
[insert Third Party Type of cookie Link to Privacy Policy]
Facebook
(Facebook Custom Audience) Interest-based Advertising
This cookie allows us to target the advertising we do on Facebook more effectively by matching data we hold with that held by Facebook.
http://www.facebook.com/about/privacy/
Google (AdWords Remarketing) Interest-based Advertising
This cookie facilitates post-visit messaging to drive return visits. https://www.google.com/settings/u/0/ads/authenticated?hl=en
Google (Google Analytics) Analytics]
Google Analytics collects information anonymously, uses cookies, and anonymized IP addresses, and reports website trends without identifying individual visitors. https://tools.google.com/dlpage/gaoptout
Link to Privacy Policy
http://www.facebook.com/about/privacy/
https://www.google.com/settings/u/0/ads/authenticated?hl=en
https://tools.google.com/dlpage/gaoptout
14 How To Reject or Opt Out of Receiving Cookies
If you want to delete any cookies that are already on your computer, please refer to the help and support section on your internet browser for instructions on how to locate the file or directory that stores cookies. Please note that our Site cannot always control third-party cookies stored on your machine from our online Services and that setting your cookie preferences with us will not stop those third-party cookies from being stored on your machine. Therefore, you must manage these cookies directly with the relevant third party. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Site.
If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web Consortium’s website (or, for third party cookies, visit http://www.youronlinechoices.com/).
16. Do Not Track Signals
Certain web browsers provide users with an option by which you may have your browser send a “Do Not Track” signal to the website that you are visiting, advising the recipient website that you do not want to have your online activity tracked. However, the way browsers communicate such “Do Not Track” signals are not yet uniform and accordingly, our Site does not take any action in response to such signals. In the event a final standard is developed and accepted, we may reassess how we should respond to such signals.
17. Opting in and opting out of electronic communications
At certain points where Personal Data is collected on our Site, there will be a box to indicate that you wish to receive certain information or communications from us. You may also opt out of receiving electronic communications, such as emails from Tarotpolis at any time using the “Unsubscribe” links provided in these emails. In all of our electronic communications, you will be given the opportunity to opt out of receiving future communications. You may also opt-out or change your preferences by sending an email to info@tarotpolis.de.
18. Use of the Site by Children
You must be 18 years of age to use the Site. Tarotpolis does not knowingly collect or maintain information from children under the age of 13, and no part of the Site is designed with the intention of attracting such children.
19. Links to Other websites and services
The Site may contain links to other websites that are not controlled and/or maintained by us. Please be aware that these other websites may have different privacy policies which may subject you to different privacy practices. Please review the privacy policies of such other websites for information concerning what information is collected on such websites and how it is used. Tarotpolis is not responsible for the contents or privacy practices of any linked site or any link on a linked site.
Our Site also includes social media features, such as Facebook, Twitter, and Instagram. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing the feature, which we encourage you to review.
20. Contact Us
If you have any questions or complaints concerning this Privacy Policy or our handling of your Personal Data you may contact us at
info@tarotpolis.de
or
Attn: Privacy Officer
Tarotpolis Inc.
2810 N Church St
PMB 30811
Wilmington, Delaware 19802-4447