TULA PRIVACY POLICY
Last Updated: December 07, 2022
California Privacy Policy
European Privacy Policy
TULA Life, Inc. and its subsidiaries and affiliates (“TULA,” “we,” or “us”) recognizes the
importance of data privacy, and this Privacy Policy sets forth the terms and conditions with respect to how we process
personal information. This Privacy Policy describes, among other issues, the types of personal information that we
collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and
responsibilities you may have with respect to such personal information.
This Privacy Policy applies to the personal information you provide us when you (i) visit any website that we own,
license, or otherwise operate and that links to this Privacy Policy (each, a “Site”), (ii) purchase or receive
products, goods, or services through the Site, or (iii) visit our offices or otherwise contact or engage with us. For
purposes of this Privacy Policy, the Site and all products, goods and services sold or furnished by the TULA through a
Site shall be referred to collectively as the “Services.”
PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY
ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS
OF THIS PRIVACY POLICY AND OUR TERMS & CONDITIONS AND ANY
APPLICABLE COOKIE POLICY ON A SITE.
You must be at least eighteen (18) years of age to access the Services. TULA is headquartered in the United States,
and the personal information you provide to TULA may be processed and stored in the United States and other
jurisdictions. For more information on our data transfer practices, please see Section 9 (Data Retention and
Localization).
Scope
This Privacy Policy applies to personal information that TULA receives during its business operations as a “data
controller” - which means we determine the purpose and means of processing such personal information. For
purposes of this Privacy Policy, the term “personal information” means any information that, alone or in
conjunction with other information or data, identifies or is linked to a particular individual or household and that
is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term
“personal information” does not include anonymized or de-identified data that is not attributable to a particular
individual or household and that is not otherwise subject to a data protection law, statute, or regulation. TULA may
anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and TULA may use
such data for any purpose.
TULA collects personal information in order to provide our Services, comply with our legal obligations, promote our
business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal
information to TULA, we may not be able to provide you the Services or to complete a transaction you requested.
Generally, we collect the following types and categories of personal information during our business operations:
Personal Information |
Category |
Description/Examples |
Personal Identifiers |
Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer
identification number. |
Registration Data |
Information provided when you register for an account to use the Site, including usernames and passwords. |
Online Identifiers (For more information, see “Technical Data” below) |
Persistent identifiers that can be used to recognize you or your device over time and across different services,
including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad
identifiers, and similar technology. |
Commercial Information |
Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories
or tendencies with respect to our Services. |
Business Contact Data |
Information related to employees, owners, directors, officers, or contractors of a third-party organization
(e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct,
or possibly conduct, business activities. |
Health Data |
You may furnish us with health-related information in the event you, or a third party, has an adverse reaction
to the use of our products or goods. |
Marketing and Communications Data |
Information with respect to your marketing preferences and your subscriptions to our publications and alerts.
|
Internet and Electronic Network Data |
Data pertaining to your access or use of the Site, including browsing history, search history, and information
regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and
information derived from any device that connects to our WiFi services. |
Your Feedback |
Information you provide about our Services, which may include data gathered from any TULA surveys or reviews
submitted by you. |
Visitor Information |
Information an individual provides when visiting any physical location or premises of TULA (e.g., visitor logs
and registries, vehicle and parking information). |
Video and Images |
In some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video
camera (e.g., on-premises security systems) or through video teleconferencing. |
Geolocation Data |
Information about the general city, state, or region in which a user of the Site is located. |
Professional or Employment Data (For more information, see “Employment Applications and Talent Management”
below) |
If you apply for a job with TULA, we collect information set forth in a resumé, curriculum vitae, cover letter,
and similar documentation, including contact details, employment history, skills, or qualifications,
education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and
information provided about or by your references. |
Inferences |
Inferences drawn from some of the personal information categories identified herein and used to create a
consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior. |
Technical Data
When you access the Site, we collect certain data automatically using technical means and tools. This data relates to
your device, as well as your experience on the Site and other websites, including the following:
- Usage and Device Data. When you access and use the Site, we automatically collect details of your access to
and use of the Site, including traffic data, usage logs and other communication data, and the resources that you
access and use on or through the Site (e.g., browsing history, search history). We may also collect information
about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi
MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic”
data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate,
or energy use), and any other data collected for the purposes of measuring technical diagnostics.
- Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a
small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating
the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site
may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as
web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on
your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity).
The Site may collect data about the advertisements you have seen or engaged. For more information, see, where
available, the Cookie Policy on each Site.
- Site Monitoring. Please be aware that we use cookies and other tracking technologies within the Site to
monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard,
improve, and analyze usage of, the Site, and for the other purposes listed in this Privacy Policy. For the avoidance
of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording.
We collect the personal information identified herein directly from you when you use our Services, through automated
means when you are using the Site, and from third parties. More specifically, we collect personal information from the
following sources:
- First Party / Direct Collection. We collect personal information directly from you when you use our
Services (e.g., registering accounts, completing purchases, signing up for subscriptions), when you provide a
Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or
premises or otherwise contact us.
- Automated Collection. As described above, we may collect information and data, such as usage data and
cookies, through automated means when you use the Site (see “Technical Data” above).
- Third-Party Sources. We collect personal information from third parties, such as publicly available
databases, social networking providers, advertising companies, our service providers, and third-party references.
We may use the personal information we collect about you in order to perform our Services, comply with our legal
obligations, and promote our business interests.
How Your Personal Information Is Used |
Provide, operate, maintain, improve, and promote our Services. |
Enable you to access and use our Services. |
Process and complete transactions, and send you related information, including purchase confirmations and
invoices. |
Send you messages and communications related to our Services (e.g., responses to your comments, questions, and
requests, customer serivces). |
Furnish technical notices, updates, security alerts, and support and administrative messages to you about our
Services. |
Provide you promotional and marketing communications (e.g., information about our Services, features, surveys,
newsletters, offers, promotions, contests, and events). |
Process and deliver contest or sweepstakes entries and rewards. |
Monitor and analyze trends, usage, and activities in connection with our Services to promote our business
interests. |
Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other
illegal activities. |
Personalize our Services, including providing features or advertisements that match your interests and
preferences. |
TULA may collect and use your personal information for any other purpose for which we obtain your consent. |
Mobile Messaging Program.
In the event you opt-in to receive SMS/text messages from us (“
Mobile Messaging
Program”), we will collect and use your mobile telephone number to maintain and administer our Mobile Messaging
Program. With your permission, we may send text messages about our store, new products, and other updates, including
“Checkout Reminders,” and we use webhooks to trigger the Checkout Reminders messaging system. Please review the
TULA Messaging Terms and Conditions for more information about the
Mobile Messaging Program, including information on how to unsubscribe or update your personal information therein and
your responsibilities and liabilities related thereto.
For the avoidance of doubt, you hereby agree that TULA may contact you via any means, including via SMS/text message
and email and through the use of autodialing systems and serivces, to furnish you information regarding a product
order, shipping status, warranty-related information, and similar data and information pertaining to a commercial
transaction
We may share your personal information with certain organizations and third parties in accordance with applicable
law, including as set out below. However, we do not share personal information with third parties that we have reason
to believe use such information for their own direct marketing purposes.
Service Providers.
We may share your personal information with companies that provide services on our behalf,
such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions
(including rebates and returns), tracking and responding to consumer questions or complaints, and performing analyses to
improve the quality of our Services.
Payment Card Transactions.
All payments for purchases made through the Site are completed using a third-party
vendor’s online payment system. TULA does not have access to your credit card information and does not store or disclose
your full credit card information. Any personal or financial information you provide to our online payment system is
subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before
providing any personal or financial information. If you have any questions about payments or would like to dispute a
charge, you can contact us at
help@tula.com.
Distributors and Business Partners.
We may share your personal information with third parties that distribute
our goods, products, and marketing materials.
Business Restructuring.
Circumstances may arise where, for strategic or other business reasons, TULA decides to
sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent
reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or
sale of all or a portion of TULA’s assets.
Legal; Compliance; Legitimate Interests.
We may disclose personal information (i) if required by law or
government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent
circumstances, to protect the health and personal safety of any individual. In addition, TULA may disclose your personal
information with any third party when we believe such disclosure is necessary to defend or protect our legal,
regulatory, or business interests. We may also disclose your information upon your express consent.
Consent.
In addition to the reasons for disclosure set forth herein, we may also disclose your personal
information upon your consent.
In the event that you facilitate a transaction with TULA, or request information from or otherwise engage with us,
and such activities require TULA to share your personal information with a service provider or other third party, you
hereby consent to such disclosure and/or direct TULA to intentionally disclose your personal information to the
service provider or third party.
We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you
contact us on a social media platform for customer support or for other reasons, we may contact you via the social
media’s direct message tools. Certain social media platforms may also automatically provide us with your personal
information, the information we receive will depend on the terms that govern your use of the social media platform(s)
and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook
Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect
your IP address and which Site page you are accessing 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 the Site. Your interactions
with these features are governed by the privacy statement of the relevant social media platform that provides them.
Links to Other Websites; Your Direct Third-Party
Disclosures
As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose
information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such
third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any
data, including personal information, to third parties via the Services. For a description of the privacy protections
associated with providing information to third parties, you should refer to the privacy statements, if any, provided
by those third parties.
Data Retention and Localization
The period during which we retain your personal information varies depending on the purpose for the data processing.
For example, we retain personal information needed to provide you with our Services, to facilitate transactions you
have requested, to comply with our legal obligations (e.g., tax filings, export control laws), to engage in marketing
activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain
your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.
TULA is based in the United States, and the personal information that we collect and process is retained and stored
in the United States. TULA uses service providers that store personal information on our behalf in the United States
and in other third countries. Please be aware that the United States, and these other third countries, may not provide
the same level of protection of personal information as in your country, state, or other jurisdiction of residence or
nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by,
or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative
orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such
information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in,
the United States and in such other third countries.
Security
We seek to protect the security of your personal information and use a variety of security technologies and
procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO
INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION.
MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES
OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY
PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE
RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR
PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on
you. Where we have given you (or where you have chosen) a username and password to access our Services, you are
responsible for maintaining the security and confidentiality of those credentials and not revealing them to others.
You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that
your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via
email or other electronic communications in the event we are legally required to notify you of a data security
incident or event related to your personal information.
No Data Collected from Children
The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of sixteen
(16), you are prohibited from accessing or using the Services (including the Site) or with providing us with your
personal information.
Publicly Posted Information; Product Reviews
You may, from time to time, have the ability to submit via the Site a comment on, provide an opinion about, rate, or
otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us
feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you
post in a Product Review or in your Feedback may be available to other users of the Site (and our social media
platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or
share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy
and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential.
Any third party with access to your information via the Site will be permitted to use the information in the same
manner as if you submitted the information directly to that third party. Publicly posting any information on the Site
is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make
publicly available. As between you and TULA, any and all Product Reviews and Feedback shall be considered our
confidential and proprietary information. In order for TULA to utilize such Product Reviews and Feedback, you grant to
TULA a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all
relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner
we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of TULA’s and our
sub-licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we
choose, without reference to the source. TULA shall be entitled to use Product Reviews and Feedback for any purpose
without restriction or remuneration of any kind with respect to you and/or your representatives.
Your Responsibilities
You are permitted, and hereby agree, to only provide personal information to TULA if such personal information is
accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any
applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or
privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO TULA, YOU
EXPRESSLY REPRESENT AND WARRANT TO TULA THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE TULA WITH SUCH PERSONAL
INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT TULA’S USE AND PROCESSING OF SUCH
PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO
PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY TULA FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM
YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO TULA.
It is important that the personal information that you provide to us is accurate and reliable. You may have the
ability to update your personal information at “Checkout” when you purchase a good or product. In certain
circumstances, you may have the ability to directly edit your account to update and change your personal information
(e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. You may
review, update, or modify your personal data, including profile and contact information, at any time by logging into
your TULA account. You may request deletion of your personal data or TULA account by emailing privacy@tula.com or by completing our consumer rights webform.
Canada Privacy Rights
Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada
(“PIPEDA”)) will be collected, stored, used and/or processed by TULA in accordance with this Privacy Policy and
TULA’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you
have a right to request access to your personal information and to request that inaccurate personal information be
corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected,
please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction
of, your personal information, we will require that you verify our request via email, and we will request specific
data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search
our records and databases. We may charge you a fee to access your personal information, provided that we advise you of
any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow
you to access certain personal information in certain circumstances (e.g., if the information contains personal
information of other persons or it is subject to legal privilege). In the event that we cannot provide you with access
to, or the ability to correct, your personal information, we will use reasonable means to inform you of the reasons
why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or
email), please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data
processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about
the Office of the Privacy Commissioner of Canada, please access its website.
European Union (EU), Switzerland, and United Kingdom
(UK)
Data Protection Rights.
If you are located in the EU, Switzerland, or the UK, you have the following data
protection rights:
-
Right to Know. The right to know about what personal information TULA collects and processes about you,
including the types and categories of personal information we collect and process, the sources of such personal
information, our retention criteria, with whom we share your personal information, cross-border data transfers, and
how to file complaints and inquiries. Such information is set forth in this Privacy Policy.
-
Automated Decision Making. TULA does not engage in any activity that subjects our customers, Site users,
survey participants, or others to a decision based solely on automated processing, including profiling, which
produces legal effects, or similarly significant results, impacting them.
-
Access Rights. You may ask us whether we process any of your personal information and, if so, receive access
to such personal information. When complying with an access request, we will also provide you with additional
information, such as the purposes of the processing, the categories of personal information concerned as well as any
other information necessary for you to exercise the essence of this right.
-
Rectification. You have the right to have your personal information corrected/rectified in case of inaccuracy
or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account
the purposes of the processing, update any incomplete personal information, which may include the provision of a
supplementary statement.
-
Erasure. You have the right to have your personal information erased, which means the deletion of your
personal information by us and, where possible, any other controller to whom your data has previously been
disclosed. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your
personal information is no longer necessary in relation to the initial purposes for which it was processed, your
personal information was processed unlawfully).
-
Restriction of Processing. You have the right to obtain the restriction of the processing of your personal
information, which means that we suspend the processing of your personal information for a certain period of time.
Circumstances which may give rise to this right include situations where the accuracy of your personal information
is contested, but we need time to verify the inaccuracy (if any) of your personal information.
-
Data Portability. You have the right to request us to provide you with your personal information in a
structured, commonly used and machine-readable format and to have such data transmitted directly to another
controller, where technically feasible.
-
Right to Object. You have the right to object to the processing of your personal information, which means you
may request us to no longer process your personal information. This only applies in case the “legitimate interests”
ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”).
However, at any time (and free of charge) you can object to having your personal information processed for direct
marketing purposes.
-
Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent
for the processing of your personal information. However, this will not impact our legal basis to process such
personal information prior to the withdrawal of your consent.
To exercise any of these data privacy rights, please complete our privacy webform or contact us, or have your designated agent contact us, in
accordance with the “Contact Us” section listed below. To the extent permitted by law, we will need to verify your
identity (or the identity of your agent) and ensure the authenticity of your request.
Legal Basis for Processing.
We process your personal information in accordance with the legal bases set forth
in law. For example, our processing of personal information (as described herein) is justified based on the following
legal grounds:
- Consent. Processing is based on your consent (e.g., you register to receive our marketing materials, you
voluntarily contact us).
- Legitimate Interests. Processing is necessary for our legitimate interests as set out herein (e.g.,
monitoring your use of the Site and your compliance with the terms and conditions governing the same, improving our
Services).
- Contract Undertaking. Processing is necessary for the performance of a contract to which you are a party
(e.g., you purchase or consider purchasing our Services).
- Legal Compliance. Processing is required to comply with a legal or statutory obligation (e.g., tax
disclosures).
Complaints. In the event you have concerns about our data processing, you have the right to file a complaint
with your data protection authority. For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
For the data protection authority in Switzerland, please contact the Federal Data Protection and Information
Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the
data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns
before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.
California Privacy Rights
Data Privacy Rights.
Pursuant to the California Consumer Privacy Act of 2018, as amended by the California
Privacy Rights Act of 2020 (“CCPA”), California residents are entitled to certain data privacy rights:
- Right to Know (Specific Pieces of Personal Information). You have the right to know the specific pieces of
your personal information that we have collected about you.
- Right to Know (Categories of Personal Information). You have the right to know (i) the categories of
personal information we have collected from you; (ii) the categories of sources from which the personal information
is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose;
(iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose;
and (v) the business or commercial purpose for collecting or selling your personal information.
- Right to Delete. You have the right to request that we delete your personal information that we have
collected and retain.
- Right to Correct. You have the right to request that we correct inaccurate personal information that we
have collected and retain.
- Nondiscrimination. You have the right not to be subject to discrimination for asserting your rights under
the CCPA.
Submit a Privacy Request.
To submit a privacy request, complete our
privacy webform or contact us using any of the following means:
(email)
privacy@tula.com, (mail) TULA Life, Inc, ATTN: DATA
PRIVACY, 228 Park Avenue South, PMB 23606, New York, New York 10003-1502. An authorized agent must be registered with
the California Secretary of State to conduct business in California.
Privacy Request Verification Process.
If you (or your authorized agent) make any request related to your
personal information, TULA will ascertain your identity (and the identity of the authorized agent, to the extent
applicable) to the degree of certainty required or permitted under the law before addressing your request. In
particular, TULA will, to the extent required or permitted by law, require you (or your authorized agent) to verify your
request via email, request certain contact information or government identifiers, and we will match at least two pieces
of such personal information with data that we have previously collected from you before granting you access to,
erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request.
We may require written documentation that demonstrates a third party is authorized to serve as your agent for the
purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of
attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and such rights
are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see:
https://oag.ca.gov/privacy/ccpa.
Opt-Out Rights / Do Not Sell My Personal Information.
California residents have the right to opt out of the
“sale” of their personal information. However, TULA does not sell your personal information to third parties for profit
or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of
personal information (because we do not undertake such activities).
Opt-Out Rights / Do Not Share My Personal Information.
California residents have the right to opt out of the
“sharing” of their personal information. TULA uses third-party analytical and targeted advertising features on our Site
and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve
the disclosure of your personal information to third parties and may constitute the “sharing” of your personal
information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please
click on the cookie management tool (sometimes visible as a “Privacy Choices” or a “Do Not Sell/Share My Personal
Information” link on the footer of the Site) to set your cookie preferences. You, or your authorized agent, may also
contact us in accordance with the “Contact Us” section listed below.
Children.
The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and
therefore TULA does not knowingly sell or share the personal information of minors under sixteen (16) years of age.
Limit Use of Sensitive Personal Information.
TULA does not use or disclose sensitive personal information for
reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit
how we use or disclose such sensitive personal information.
Nevada Privacy Rights
TULA does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the
foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them
to third parties who will sell or license their information to others. If you would like to exercise this right,
please contact us in accordance with the “Contact Us” section listed below.
Virginia Privacy Rights
Data Privacy Rights.
Pursuant to the Virginia Consumer Protection Act, Virginia residents are entitled to
certain data privacy rights:
- To confirm whether or not TULA is processing your personal information, and to access such personal information.
- To request TULA correct inaccuracies in your personal information, taking into account the nature of the personal
information and the purposes of the processing of the personal information.
- To request TULA delete your personal information.
- To obtain a copy of the personal information that you previously provided TULA in a portable and, to the extent
technically feasible, readily usable format that allows it to be transmitted to another entity without hindrance,
where the processing is carried out by automated means.
Submit a Privacy Request.
To submit a privacy request, complete our
privacy webform or contact us using any of the following means:
(email)
privacy@tula.com, (mail) TULA Life, Inc, ATTN: DATA
PRIVACY, 228 Park Avenue South, PMB 23606, New York, New York 10003-1502.
Privacy Request Verification Process.
If you make any request related to your personal information, TULA will
ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty
required or permitted under the law before addressing your request. In particular, TULA will, to the extent required or
permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact
information or government identifiers, and we will match at least two pieces of such personal information with data that
we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or
categories of personal information, or otherwise responding to your request. None of Virginia’s privacy rights are
absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the
Virginia Consumer Protection Act, please see:
https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.
Privacy Requests Appeals Process.
If you would like to appeal a decision TULA has made with respect to your
privacy request, please email
privacy@tula.com with the subject line
“PRIVACY REQUEST: APPEALS” and describe the nature of your request, and the reason requesting an appellate review.
Opt-Out Rights / The Sale of Personal Information.
Virginia residents have the right to opt out of the “sale”
of their personal information. However, TULA does not sell your personal information to third parties for or monetary
consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because
we do not undertake such activities).
Opt-Out Rights / Targeted Advertising.
Virginia residents have the right to opt out of having their personal
information used for targeted advertising purposes. TULA uses third-party analytical and targeted advertising features
on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal
information in these circumstances, please click on the cookie management tool (sometimes visible as a “Privacy Choices”
or a “Do Not Sell/Share My Personal Information” link on the footer of the Site) to set your cookie preferences.
Opt-Out Rights / Profiling.
Virginia residents have the right to opt out of having their personal information
used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, TULA does
not engage in such activities.
Do-Not-Track Signals
Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of
differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for
these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we
currently do not take action in response to these signals.
Persons with Disabilities
TULA strives to ensure that every person has access to information related to our Services, including this Privacy
Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to
meet your needs.
Rewards Programs and Financial Incentives
We collect and use personal information, including personal information provided by a third party (e.g.,
refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs
(“Rewards Programs”). We use the personal information you provide in these programs to verify your identity,
offer unique rewards, track your program status, and facilitate the exchange of program points for products,
promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards
Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section
listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and
conditions. TULA may use personal information gathered from, or related to, participants in our Rewards Programs for
any other purpose or in any other manner set forth in this Privacy Policy.
California Rewards Program Rights.
Pursuant to the CCPA, you may be entitled to be informed as to why financial
incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of
the value of your personal information that forms the basis for offering the financial incentive or price or service
difference, and (ii) a description of the method we used to calculate the value of your personal information. Generally,
we do not assign monetary or other value to personal information. However, in the event we are required by law to assign
such value in the context of Rewards Programs, or price or service differences, we have valued the personal information
collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of
the value is based upon a practical and good-faith effort often involving (i) the categories of personal information
collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards
Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the
product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value
described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business
confidential information, including trade secrets, and does not constitute any representation with regard to generally
accepted accounting principles or financial accounting standards.
Employment Applications and Talent Management
As part of our recruitment and talent management process, we collect personal information with respect to individuals
who are interested in working for us. In this context, we collect employment and application data, such as the
following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email
address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the
type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g.,
medical conditions); information related to your background, education, criminal record, credit history and similar
data; information provided about or by your references or other third parties related to your employment history,
skills, qualifications, or education; and information related to previous applications to us or previous employment
history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our
diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job
applicants; to verify your information; to complete employment, education, background and reference checks; to
communicate with you about the recruitment process and your application; to comply with our legal, judicial,
regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment
process; to accommodate individuals who may have specialized needs during the employment process; and to protect the
rights, interests, and property of our business, other job applicants, employees, or the public, as required, or
permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party
Disclosures”), and we may also use this employment and application data for any other purpose set forth in this
Privacy Policy.
Events and Video Teleconferencing
TULA hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other
programs. We often use online platforms that are owned and administered by a third-party service provider (e.g.,
Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content,
conversations, and discussions thereon, and such records may be stored or retained by our third-party service
providers. By participating in our events and video teleconferencing, you hereby consent to the collection and
retention of any information provided therein, and you hereby consent to the recording of such activities.
Changes to the Policy
We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended
by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy
Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the
Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any
amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages,
about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your
responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.
If you have questions regarding this Privacy Policy or our handling of your personal information, or you would like to
request more information from us, or would like to exercise a data privacy right, please contact our Privacy Office at
the following:
privacy@tula.com
TULA Life, Inc
ATTN: DATA PRIVACY
228 Park Avenue South
PMB 23606
New York, New York 10003-1502.
If you would like to contact us regarding exercising your privacy rights, please complete our privacy webform or contact us at the details above.