Published March 9, 2020
Effective March 9, 2020
Table of Contents
1. SCOPE AND APPLICATION: What and who this Policy covers.
2. COLLECTION OF INFORMATION: The sources of and methods by which we, our service providers and our advertisers collect information from and about you, including information about your interaction with the Two Rule Foundation.
3. USE AND DISCLOSURE: How we use the information we collect from and about you, and who we might share it with and why.
4. INFORMATION SECURITY: How we protect your information from loss or misuse.
5. USER ACCESS AND CONTROL: How you can access and control the information we maintain about you.
6. OTHER IMPORTANT INFORMATION: Other things you should know about this Policy and how we handle your information.
7. THE GDPR AND ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (“EEA”): What we are doing to meet the obligations of the General Data Protection Regulation and other important information for individuals in the EEA.
8. CONTACT US: How to contact us about this Policy.
1. Scope and Application
2. Collection of Information
Information You Provide Directly to Two Rule Foundation Partners
If you are interested in obtaining information, products or services from the Two Rule Foundation, or participating in certain activities through the Services, you may need to provide us or our service providers with information about yourself. For example:
· If you register for a Service to become a member, receive a newsletter, or get information about Two Rule Foundation promotions or events, you may be asked for your name, email address, mailing address, phone number and other information.
· If you order a product from us or one of our business partners, you may be asked for your name, postal address, email address, telephone number and your credit card number.
· If you are ordering a product as a gift for another person, you may be asked for that person’s name, postal address and phone number in order to enable us to deliver the gift to the recipient.
· If you participate in an activity such as a survey or sweepstakes, you may be asked for your name, email address and birth date, and also to provide other types of information such as gender and personal interests, which may be associated with other personal information that has been obtained from or about you.
Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise.
Information We May Collect AutomaticallyIn addition to information you choose to provide to us, the Two Rule Foundation and our service providers also use standard technologies to automatically collect certain additional information. For example:
- IP Address and Other Identifiers. When you access and interact with our Services and our service providers may collect information about your visits in order to permit you to connect to and obtain the Services and to understand the frequency with which specific visitors visit various parts of our Services. For example, we may collect your Internet Protocol (“IP”) address, which identifies the computer or service provider that you use to access the Services, or information about your browser type, authentication identifiers, and other software and hardware information. If you access the Services through a mobile or other device we may collect your mobile device identifier, geolocation data (including your precise location), or other transactional information for that device. We may combine this information with other information that we have collected to make our Services and our communications to you more targeted to your interests.
- Web beacons and other tracking technologies. The Services may use other tracking tools, including so-called “pixel tags,” “web beacons,” “web bugs,” “clear GIFs,”etc. (collectively “Web Beacons”) to collect user activity information about your activities on the Services. These are small electronic images embedded in web content (including online ads) and email messages and are ordinarily not visible to users. Like Cookies, Web Beacons enable us to track pages and content (including ads) accessed and viewed by users. Also, when we send HTML-formatted (as opposed to plain text) emails to you, Web Beacons may be embedded in such emails to allow us to monitor readership levels so that we can identify aggregate trends and individual usage to provide our audiences with more relevant content or offers. Web Beacons in emails may recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web Beacons cannot be declined when delivered via a regular web page. However, Web Beacons can be refused when delivered via email. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
- Third Party Tracking. Third parties that support the Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate the Services usage statistics, may also use these technologies to collect similar information when you use the Services (such as websites and emails). These third parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. The Two Rule Foundation does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices.
Information Contained in User ContentSome parts of our Services may allow users to post or transmit messages, comments, screen names, computer files and other materials. You should be careful about what personal information you choose to make public through these Services.
Information from Other SourcesTo the extent permitted by law, the Two Rule Foundation and our service providers may supplement the information we collect from and about you with information from other sources, such as publicly available information about your online and offline activity from social media services, commercially available sources and information from the Two Rule Foundation or business partners.
3. Use and Disclosure
The Two Rule Foundation and our service providers may use information that we collect from and about you for a variety of business purposes, including:
- to maintain and manage your account, deliver content and services that you request, improve the Services and enhance your experience on our Services;to process and track your product or service orders and provide the Services and content you request;
- to communicate with you about the content and Services or other products, content or services in which you may be interested, or to respond to your inquiries or comments;
- to contact you. The Two Rule Foundation may periodically send notifications related to the Services such as notifications of changes to the Services or policies;
- to perform business analyses or for other purposes to improve the quality of our business, the Services, and the products and services we offer;
- to complete a merger or sale of assets. If the Two Rule Foundation sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), the Two Rule Foundation may transfer your information to the party or parties involved in the transaction as part of that transaction; or
- in accordance with your consent.
In order to make our content, Services and advertising more interesting and relevant to you, we may use the information we collect from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
- with entities that help us to manage and provide the Services, including development of our websites and applications, maintenance and support, personalization, payment processing, email distribution, measurement and improvement, sweepstakes/contest administration, booking, fulfillment, and operation of travel services and products, and promotions management, only to the extent that these entities need the information to perform their services or as required by law;
- with identified entities whose products or services you specifically use or request to receive while you use the Services;
- with our business partners, such as travel operators. Their use of your personal information will be governed by their own privacy policies;
- with third parties in in the ordinary course of business in order to process your requests and fulfil your orders for video content offered through the Services;
- with your consent, with other selected third parties so that they may send you promotional materials about goods and services that they offer;
- in accordance with your consent.
Two Rule Foundation, service providers, business partners and other individuals described above, may be located outside of your country of residence, including, among others, in the United States (Canada and EEA). These countries may have different data protection regimes than is found in the country where you are based.
When information we collect is aggregated, anonymized or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
4. Information Security
We take a number of commercially reasonable administrative, technical, personnel and physical measures designed to safeguard information in our possession from loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information.
5. User Access and Control
If you would like to access, review, correct, update, suppress, delete or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us using the mechanisms provided below. We will try to comply with your request as soon as reasonably practicable.
You may opt out of having your personal information used or disclosed for certain purposes.
- If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these emails be clicking “Unsubscribe” or “Update my Preferences” at the bottom of any marketing email you receive.
- If you would prefer that we do not share your personal information on a going-forward basis with business partners for their direct marketing purposes, you may opt-out of this sharing via the link at the bottom of any marketing email you receive.
- If you continue to receive our communications in error after expressing an opt-out preference, please let us know so that we can investigate the situation.
- If you are under 18 and a registered user of the Services, you may request removal of content or information that you have publicly posted to the Services. To make such a request, please send us an email to email@example.com. Please identify “privacy” in the description of your request and identify “User Content Removal” as the option that best describes your type of inquiry. Please also provide your name, email address, and a detailed description of your content removal request in the designated spaces. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user. There may also be circumstances where the law does not allow removal of your content even if requested.
6. Other Important Information
Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or record keeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints or, contractual, financial or legal requirements.
7. The GDPR and Additional Information for Individuals in the European Economic Area (“EEA”)
If you are a resident of the European Economic Area (“EEA”) and the Services are targeted to you, please note:
- We may need to collect and process the types of Personal Information listed above in order to provide the Services to you or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the Services. We may use the Personal Information for our legitimate business interests, including those listed above.
- If you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, you may contact us at: firstname.lastname@example.org.
- Regarding the section entitled “Location of Data” in Section 6, above: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting email@example.com and providing your contact information, selecting “Other” from the drop-down menu and providing a brief description in the text box available.
- Regarding the section entitled “Data Retention” in Section 6, above: We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you and provide the Services to you; (ii) as required by a legal obligation to which we are subject; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
- You may lodge a complaint with a supervisory authority competent for your country or region.
8. Contact Us
Two Rule Foundation
Attn: Business and Legal Affairs – Privacy
5975 Castle Creek Pkwy N. Dr,
Castle Creek VI, Suite 475
Indianapolis, IN 46250