PRIVACY POLICY
(Updated & Effective April 8,2020)
The Trust Income Equity Limited Liability Company in partnership with Freedom Living Inc (“Company”, “we”, “us”, and “our”) offers you access to its interactive online websites, applications, voice services, SMS text, and services. This Privacy Policy explains what information may be collected when you access this website www.roteitbeta.com and the Amazon Alexa Skill(s), purchase, install, download, or register in or use any of our mobile or any other application (“Applications”), including our Amazon Alexa Skill(s), or use or register with any other website we place this Privacy Policy on (“Website”); how we and others use this information; under what circumstances we may disclose the information to third parties; and the instances in which we may allow third parties to collect information directly from you. Depending on your activities when using or accessing our Website or Applications (collectively, “Services”), you may from time-to-time be required to agree to additional terms and conditions. For clarity, our Services include any promotion which refers to this Privacy Policy for terms regarding the collection and use of your information.
Please note that this Privacy Policy applies regardless of whether you use our Services via a computer, mobile device or other platform (collectively, your “Equipment”). Also, this Privacy Policy applies only to information we collect through our Services and does not apply to our collection of information from other sources (e.g., across other RoteItBeta affiliated social media platforms such as Facebook, Instagram, Twitter, etc.).
Modifications to this Privacy Policy
We generally keep this Privacy Policy posted on our Website and in our Applications. You should review this Privacy Policy frequently, as it may change from time to time without notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy. WHEN YOU USE OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP USING OUR SERVICES. Please note, however, that if we decide to use your personally identifiable information in a manner materially different than what is provided in this Privacy Policy or what we advised at the time it was collected, we will notify you of this change by e-mail to the last e-mail address provided to us or through our Applications. You will have a choice (by means of an “opt out” opportunity) as to whether we use your personally identifiable information in this different manner. In such case, we will use your personally identifiable information in accordance with the terms in place when the information was collected.
A. INFORMATION WE COLLECT
We typically collect two kinds of information about you when you use our Services: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you, but that we automatically collect or that you provide us.
(1) Personally Identifiable Information: Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, mail address, phone number, etc. As a general policy, we do not automatically collect your personally identifiable information when you visit our Website. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Services. For instance, you may: (a) provide your name, mail/shipping address, email address, credit card number and phone number when registering or in connection with a contest entry; (b) provide certain demographic information about you (e.g., age, gender, purchase preference, usage frequency, etc.) when using our Services or participating in a survey or poll; or (c) post a general comment and/or recommendation on our Website or through our Applications.Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content or features available through our Services.
(2) Non-Personally Identifiable Information: Our definition of non-personally identifiable information is any information that does not personally identify you. Non-personally identifiable information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain non-personally identifiable information about you from information that you provide us, either separately or together with your personally identifiable information. We also automatically collect certain non-personally identifiable information from you when you access our Services through your Equipment. This information can include, among other things, your mobile device, other applications or software you are using, wireless carrier, IP addresses, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, Opera, etc.), the third party website from which your visit originated, the operating system you are using (e.g., Vista, Windows XP, Mac OS, Android, iPhone, etc.), the domain name of your Internet service provider (e.g., CenturyLink, Google, Cox, etc.), the search terms you use; and how much you use our Services.
Location Information: When you use our Services, particularly our Application(s), we may automatically collect certain Equipment (mobile device) specific information. This includes the general or specific location of your Equipment through GPS, Bluetooth or WiFi signals. Before we collect or send location-specific information, it is our practice to ask for your consent. In some instances, your operating system may not allow you to install an Application without giving us consent. In all instances, you may withdraw your consent by disabling location features for your Equipment – the Application will still work though certain location features (e.g., Store Locator) may not function.
B. HOW WE USE & SHARE THE INFORMATION COLLECTED
(1) Personally Identifiable Information: The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of our parent company, subsidiaries or other affiliated companies (“affiliated companies”), or to communicate with you about content or other information you have posted or shared with us via our Services. You may opt-out from receiving future promotional information from us or our affiliated companies, or direct that we not share your information with any affiliated companies, as set forth below.
In certain instances we may also share your personally identifiable information with third parties performing functions on our behalf (or on behalf of our affiliated companies) or accessing the Service – e.g., vendors that operate our website store/shop, process credit card orders, administer our promotions, provide us marketing or promotional assistance, analyze our data, assist us with customer service, etc. These third parties agree to use this information, and we share information with them, only to carry out our requests or provide Services. In addition, we may share your personally identifiable information with participating sponsors to a program or promotion (e.g., a sweepstakes or contest) you enter via our Services and certain co-promotional partners and others with whom we have marketing or other relationships.
In certain instances we may also share your personally identifiable information with third parties you have selected to offer you services or promotions (e.g. subscriptions to newsletters, etc.). These third parties agree to use this information, and we share information with them, to provide services and promotions to you.
Except as provided in this Privacy Policy or in our Terms of Use, your personally identifiable information will not be shared or sold to any third parties without your prior approval.
(2) Non-Personally Identifiable Information: We use non-personally identifiable information in a variety of ways. For example, we may use non-personally identifiable information to evaluate use of and improve our Services (e.g., visits to our Website, use of Amazon Alexa Skill(s), etc.), track purchases, gauge coupon redemption rates, understand customer needs and trends, evaluate and analyze learner progress or performance, carry out targeted promotional activities, and to improve our services. We may use your non-personally identifiable information by itself or aggregate it with information we have obtained from other customers or other sources. We may, among other things, share your non-personally identifiable information with our affiliated companies, allow third parties to collect such information directly from you, and/or sell the non-personally identifiable information to third parties to achieve these and any other business objectives (e.g., generate revenue, form alliances, anonymously participate in education development studies etc.). However, it is important to remember that your non-personally identifiable information (whether standing alone or combined with other non-personally identifiable information) is anonymous information that does not personally identify you.
C. COOKIES AND PREFERENCE BASED ADVERTISING
(1) Cookies and Web Beacons: We automatically receive and store certain types of non-personally identifiable information whenever you interact with us. For example, like many websites, we use "cookies" and "web beacons" (also called “clear gifs” or “pixel tags”) and embedded scripts to obtain certain types of information when you use or access our Services. "Cookies" are small files that we transfer to your Equipment’s hard drive, memory or web browser to enable our systems to recognize your browser or Equipment and to provide convenience and other features to you. "Web beacons" are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.
Examples of the information we collect and analyze in this manner include the Internet Protocol (IP) address used to connect your Equipment to the Internet; computer and connection information such as browser type and version, operating system, and platform; your activities on our Website, including the products or services you viewed or searched for, as well as the URL you come from and go to next (whether this URL is on our site or not); and cookie number. It is important to note that the cookies and web beacons that we use do not contain, and are not tied to, and are not used to automatically collect any personally identifiable information about you.
If you are concerned about the storage and use of cookies, you may block or limit the storage of cookies via browser controls or other software (we do not make any promise that our Services will recognize or be able to work with any such browser controls/software – e.g., see below for Do Not Track options). You may also be able to delete cookies manually from your Equipment through your internet browser, operating system or other programs. Please note, however, that some portions of our Services will not function properly or be available if you are able and do block and/or delete cookies.
(2) Preference-Based Advertising: We may with third parties, including advertising companies and website analysis firms, who use cookies and web beacons to collect non-personally identifiable information when you visit our Website and third-party sites. This non-personally identifiable information, collected through cookies and/or web beacons, is typically used by these companies (e.g., advertising networks) to serve you with advertisements while you are on third party sites that are tailored to meet your preferences and needs. For more information on how this type of advertising works, go to www.aboutads.info.
Opting Out: If you do not wish to participate in preference-based advertising via these third-party advertising networks, go to www.aboutads.info and follow the simple opt-out process. A couple of important notes about this opt-out tool: (1) it includes all the advertising networks that we may work with, but also many that we do not work with; and (2) it may rely on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – an explanation of how Opt-out Cookies work can be found on www.aboutads.info. Therefore, if you use different Equipment, change web browser or delete these Opt-out Cookies, you will need to perform the opt-out task again.
(3) Do Not Track Features: Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Unfortunately, given how preference-based advertising works, DNT Notices may not be effective in communicating your preferences. For this and a variety of other reasons, with respect to our Website, we do not take any action based on browser based DNT Notices. Rather, if you do not wish to participate in preference-based advertising activities, you should follow the simple opt-out process identified above.
D. OTHER USES & INFORMATION
(1) IP Addresses: An IP address is a number that is automatically assigned to your Equipment whenever you access the Internet. Web servers (computers that "serve up" web pages) automatically identify your Equipment by its IP address. When visitors request pages from our Website, our servers typically log their IP addresses. We collect IP addresses for purposes of system administration, to report non-personal aggregate information to others, and to track the use of our Services. IP addresses are considered non-personally identifiable information and may also be shared as provided above. It is not our practice to link IP addresses to anything personally identifiable; that is, the visitor's session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor at the request of the visitor or when we feel it is necessary to enforce compliance with our Service rules or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Services, or other users; or (d) in an emergency to protect the health and safety of our customers or the general public.
(2) Social Networks: We may offer you the ability to create or login to your account with us through accounts you may have with various social network platforms, such as Google, Facebook, Instagram, or Twitter (each, a “Social Network Account”). To do so, you may be required to provide, or allow our Services to access, your Social Network Account login information. By granting us access to your Social Network Account, you understand and agree that we may access, make available and store any content that you have provided to and stored in your Social Network Account (e.g., friends, mutual friends, contacts, etc.). We may make this information available on or through our Services and to our users. You may be able to restrict what information is shared and how it is used through privacy and other settings. Also, depending on the privacy settings you have set in your Social Network Account, personally identifiable information may be shared with us and made available through our Services and to our users.
(3) Email Communications: If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. We may send you emails for a variety of reasons – e.g., emails in response to your request for a particular service or your registration for a feature that involves email communications, emails that relate to purchases you have made with us (e.g., product updates, customer support, etc.), informational emails about our other products, services or events, or when you consent to being contacted by email for a particular purpose. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications but not others. You may "opt out" of receiving future commercial email communications from us by clicking the "unsubscribe" link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as order confirmations and customer service communications.
(4) Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and non-personally identifiable information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
(5) Other: Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, of our Services, or other users; or (d) in an emergency to protect the health and safety of our customers or the general public.
(6) Your California Privacy Rights: Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing as provided in Section I below.
(7) International Users: Our Services are located in the United States. If you are using our Website or Amazon Alexa Skill(s) from outside the United States, you should be aware that the information collected on this Site may be stored and processed in the United States, or any other country in which Company, or its affiliates, subsidiaries or agents maintain facilities, including hosting services or servers. By providing your information to our Website or our Application(s), you are consenting to the transfer of your information outside of your country in accordance with this Privacy Policy. You are also consenting to the application of United States law in all matters concerning our Website, Application(s) and Services.
E. PUBLIC FORUMS
We may offer chat rooms, blogs, message boards, or similar public forums where you and other users of our Services can share information and communicate – e.g., places where you can post quiz results and/or profile information. The protections described in this Privacy Policy do not apply when you provide information (including personal information) in connection with your use of these public forums. We may use personally identifiable and non-personally identifiable information about you to identify you with a posting in a public forum. Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Services.
F. CHILDREN
The Children's Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “Parents”) about our practices for collecting, using, and disclosing Personally Identifiable Information from children under the age of 13 (“Children” or “Child”). COPPA also requires us to obtain verifiable parental consent from the Parent of a Child prior to collecting any Personally Identifiable Information from the Child.
This section notifies Parents of: (a) the types of Personally Identifiable Information we may collect from Children; (b) how we use such information; (c) our practices for disclosing that information; (d) our practices for notifying and obtaining verifiable parental consent when we collect Personally Identifiable Information from Children, including how a Parent may revoke consent; (e) operators that collect or maintain the Child’s Personally Identifiable Information through our Services, including our Website and Applications.
(1) Information We Collect from Children: Children can access some parts of our Services and its content and use some of its features without providing us their Personally Identifiable Information. However, some content and features are available only to registered users or require Children to provide us certain Personally Identifiable Information. In addition, we use certain technologies, such as Cookies, to automatically collect information (typically, Non-Personally Identifiable Information) from all users (including Children) when visiting our Website or using our Applications.
We only collect as much information about a Child as is reasonably necessary for the Child to participate in an activity, and we do not condition his or her participation on the disclosure of more Personally Identifiable Information than is reasonably necessary.
• Information We Collect Directly. A Child may be required to provide us with the following information to register with our Services: first name, address, birth date, email address, participating school, and a Parent’s email address. We may also require the Child to create a username and password.
We enable registered users to communicate with others on or through our website forum and social media pages through chat, email, and their Social Network Account and posting to public areas of the Service (“Social Features”). The nature of these Social Features allows Children to disclose Personally Identifiable Information about themselves. We do not moderate (monitor or review) this content before it is posted, and we do not control the actions of third parties with whom your Child shares his or her Personally Identifiable Information. We encourage Parents to educate their Children about safe internet use and to monitor their Children's use of Social Features.
• Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including Children, when they access and navigate through the Services and use some of its features. The information we collect through these technologies may include: (1) one or more persistent identifiers that can be used to recognize a user over time and across different websites and online services; (2) information that identifies a device's location (geolocation information); (3) we also may combine Non-Personally Identifiable Information we collect through these technologies with Personally Identifiable Information about you or your Child that we collect online.
For information about our automatic information collection practices, including how you can opt out of certain information collection, see the “Cookies and Preference Based Advertising” and “Opting Out” sections of our general Privacy Policy.
(2) How We Use Your Child's Information
We use the Personally Identifiable Information we collect from your Child to: (a) register him or her with our Services; (b) communicate with him or her about activities or features of our Services that may be of interest; (c) track his or her performance (e.g. a word quiz, word practice, system usage) or other activities.
We use the information we collect automatically through technology (see Cookies and Preference Based Advertising) and other Non-Personally Identifiable Information we collect to improve our Website, Amazon Alexa Skill(s), and other Applications and to deliver a better and more personalized experience by enabling us to: (v) estimate our audience size and usage patterns; (x) store information about the child's preferences, allow us to customize the content according to individual interests; (y) speed up your searches; (z) collect geolocation information to improve our Services.
(3) Our Practices for Disclosing Children's Information
We do not share, sell, rent, or transfer the Personally Identifiable Information of any Child other than as described in this section. We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose Children's Personally Identifiable Information: (a) to third parties we use to support the internal operations of our Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential; (b) if we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request; (c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Trust Income Equity LLC, our customers or others, including to:
• protect the safety of a Child;
• protect the safety and security of our Services; or
• enable us to take precautions against liability.
• cooperate with law enforcement agencies or for an investigation related to public safety.
(4) Accessing and Correcting Your Child’s Personal Information
At any time, you may review your Child's Personally Identifiable Information maintained by us, require us to correct or delete the Personally Identifiable Information, and/or refuse to permit us from further collecting or using your Child's Personally Identifiable Information. You can review, change, or delete by sending us an email at learners@roteitbeta.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
(5) Operators That Collect or Maintain Information from Children
The following are all operators that may collect or maintain Personally Identifiable Information from Children through our Services:
Freedom Living, Inc.
Trust Income Equity Limited Liability Company
G. KEEPING YOUR INFORMATION SECURE
We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control (e.g., where appropriate, implementing firewalls, encryption, etc.). Please be advised, however, that while we strive to protect your Personally Identifiable Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online or through our Services, and are not responsible for the theft, destruction, or inadvertent disclosure of your Personally Identifiable Information. In the unfortunate event that your "Personally Identifiable Information" (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
H. OTHER SITES/LINKS
Our Services may link to or contain links to third-party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to read the privacy statements of all third-party websites before submitting any Personally Identifiable Information through these websites.
I. CONTACT & OPT-OUT INFORMATION
You may contact us at The Trust Income Equity LLC, Attn: Corey Solivan, Manager, productTIEs@gmail.com if: (a) you have questions or comments about our Privacy Policy; (b) wish to make corrections to any Personally Identifiable Information you have provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; (d) wish to withdraw your consent to sharing your Personally Identifiable Information with others; or (e) you have other privacy related questions or concerns.
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Website and/or Application.
J. SOLE STATEMENT
This Privacy Policy as posted on this Website/Application is the sole statement of our privacy policy with respect to this Website, Amazon Alexa Skill(s), and other Applications; and no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Website/Application.