PRIVACY POLICY
Jan [10], 2024
1. OUR COMMITMENT TO PRIVACY
TRC Defense, Medical and Industrial, LLC, a Texas limited liability company (“TRC”, “we,” “our,” or “us”) respects and protects your privacy. This privacy policy (“Privacy Policy”) discloses the information that is collected by TRC or its 3rd parties, the ways in which TRC, or our 3rd parties processes and, sometimes, shares such information, and your rights and options with respect to such information.
This Privacy Policy covers information collected from users of any of TRC’s websites, applications, online services and other interactive properties, including for example, Flock of the Low God, that links to this Privacy Policy and all features, content, and other services that we own, control and make available through such websites, applications, services and properties (each an “Experience” and collectively, the “Experiences”). Before using or submitting information to the Experiences please review this Privacy Policy carefully, as well as the terms of use related to each of the specific Experiences, which governs your use of the Experiences. A specific Experience may have additional terms and policies regarding privacy for that specific Experience, so in that instance, those additional privacy terms and policies will also apply. Should there be a conflict between this Privacy Policy and those additional privacy terms and policies, then the additional privacy terms and policies will control.
Adverts, Content, Promos and Experiences. The Experiences may include, without limitation, advertisements and promotions, displayed on or through such Experiences (collectively, “Adverts”), text, images, photos, audio, music, videos, materials, comments, or other content displayed on or shared through the Experiences, whether provided by or on behalf of TRC, or uploaded or posted by users (collectively, “Content”), and sweepstakes, contests, rewards programs, special offers or other promotions (collectively, “Promos”).
Except where otherwise expressly indicated herein or on the Experiences, this Privacy Policy applies only to information collected on the Experiences and does not apply to information collected outside of the Experiences by other websites or mobile applications or by other 3rd parties, including any 3rd parties with whom you may have a contractual relationship. Before using or submitting information to other websites or mobile applications or such 3rd parties, please review their privacy policies carefully.
Certain areas of an Experience contain information intended only for users who create an account, join or otherwise register to use these areas on such Experience (“Registered Users”) and TRC reserves the right to limit these areas to Registered Users. This Privacy Policy addresses TRC’s privacy practices relating to general use of the Experiences, as well as use of the Experiences by Registered Users.
2. INFORMATION TRC COLLECTS
TRC collects one or more of the following types of information from users of one or more of the Experiences:
TRC may collect and process any information that you choose to enter on an Experience or provide to TRC in any other way that would allow TRC to identify you or contact you (collectively “PI”). The PI that you supply will be used by TRC only in accordance with this Privacy Policy. Examples of PI TRC may collect from you and use are:
a) the information you supply to become a Registered User;
b) the e-mail addresses of those who upload, post or share Content on an Experience ;
c) the names and e-mail addresses of those who communicate with TRC by e-mail;
d) information you supply to TRC in surveys and polls on an Experience ;
e) information you supply to TRC in an entry form for some Promos offered on an Experience and information provided by winners or recipients of those Promos for a required background check or for tax purposes;
f) in certain circumstances, payment and identity verification information, such as credit card number or other payment information in connection with a purchase made through an Experience; and
g) information about other people that you supply in connection with your use of an Experience or Experiences or sharing Content.
You can choose not to provide TRC with certain PI, but then you may not be able to take advantage of many features of an Experience, such as posting comments, uploading or sharing Content, registering to use certain restricted areas of an Experience, participating in TRC’s online communities, entering or participating in Promos, or receiving e-mail alerts or newsletters.
Additionally, TRC may collect and process certain types of information whenever you interact with TRC through the Experiences. Information that TRC automatically receives and records may, at any time, include your browser information, gameplay activity, motion sensor information, motion tracker information, operating system information, IP address, device ID, type of virtual reality equipment used, specific virtual reality platform, cookie information and the page you requested. This information will not be stored in a manner that is personally identifiable with you.
In connection with your visit or use of the Experiences, TRC may automatically collect usage information, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and the Tracking Pixels, each as discussed below.
When you send an e-mail to TRC, either through a clickable link, interactive Experience or otherwise, TRC may retain your e-mail address and the contents of the e-mail that you send. When you post, upload or share Content through the Experiences or communicate with other users through an Experience, TRC may retain copies of your Content. Should you want to keep the information in your e-mail(s), posting(s), upload(s), share(s) or communication(s), private or proprietary, please do not send, post, upload, share, or communicate, such information or Content to TRC or through any Experience. To help TRC make its e-mails more interesting and helpful, TRC also may receive a confirmation when you open e-mail from TRC if your computer or device supports this type of program.
Should your interactions with an Experience include purchasing goods or services, TRC may retain the information regarding your purchase, but TRC will not retain any credit card information (although such credit card information may be retained by a 3rd party which processes transactions for TRC).
Should you interact with TRC, an Experience , Content, or Promos through a social network or by connecting your Registered User account with your social network account, then you may be permitting TRC to access certain information from your social network profile (such as your name, e-mail address, your friend list, photos, age, gender, location, birthday, social networking ID, current city, or the people/sites you follow). Should you not want a social network to share such information with TRC and other 3rd parties, please review the privacy settings and instructions of the applicable social network before you connect your Registered User account with your social network account.
3. INFORMATION COLLECTED BY THIRD PARTIES
TRC may allow 3rd parties to display or provide Adverts, Content, Promos or other services on or through a particular Experience, such as, for example, our website or within gameplay. TRC, its partners and/or advertisers, or social networks, may use 3rd party servers to serve or present the Adverts, Content, Promos or the Experiences and to conduct research about the Adverts, Content, Promos or Experiences. Any of these 3rd party servers may collect non-personal information, such as your browser, operating system, date/time of viewing, IP address, device ID, or clickstream data. TRC cannot control the activities of such 3rd parties, websites or social networks. Furthermore, TRC may use 3rd party services to enable e-commerce functionality, which involves the sale of TRC’s or 3rd party products and services. These 3rd party services may provide credit card or other payment processing services where they collect PI and other financial information from you.
PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY ANY THIRD PARTY SERVICE PROVIDERS, SERVICES, SERVERS OR SOCIAL NETWORKS. SUCH 3RD PARTY INTERACTIONS ARE GOVERNED EXCLUSIVELY BY THE PRIVACY POLICIES OF EACH SUCH APPLICABLE 3RD PARTY. TRC HEREBY EXPRESSLY DISCLAIMS AND REJECTS ANY DUTY OR OBLIGATION TO YOU WITH RESPECT TO ANY SUCH 3RD PARTY INTERACTION.
4. TRACKING TECHNOLOGIES
TRC or its 3rd parties may use tracking technologies, such as cookies and Tracking Pixels, to collect information about users who visit or use the Experiences and view or interact with Adverts, Content, Promos, and/or cookies. TRC uses “cookies” to help you access and navigate the Experiences more efficiently and to statistically monitor how many people are using an Experience.
a) A “cookie” is a small file or tool stored on your computer or device containing information that allows TRC to deliver customized information to you. TRC uses both “session” and “persistent” cookies on the Experiences. Session cookies are temporary bits of information that are erased once you exit your web browser or turn off your computer or device. Persistent cookies are more permanent bits of information that are placed on the hard drive (or other storage media) of your computer or device and stay there unless you delete the cookie. Persistent cookies store information on your computer or device for a number of reasons, such as retrieving certain information you have previously provided (i.e., username and password), helping to determine what areas of an Experience you find most valuable and customizing such Experience based on your preferences on an ongoing basis.
b) You may set your browser to notify you of or decline the receipt of cookies. Certain features of an Experience , including certain Content or Promos, may not, however, function properly or be available if your browser is configured to disable cookies. Many companies offer programs that help you to visit websites or mobile versions of such sites anonymously. While TRC will not be able to provide you with a personalized experience if TRC cannot recognize you, TRC wants you to be aware that these programs are available.
During your use of an Experience , you may encounter Tracking Pixels, which may come from TRC or from 3rd parties that display or provide Adverts, Content, or Promos or services on such Experience.
c) A “Tracking Pixel” is a small graphic image in a web page, a web-based document or an e-mail message that generally allows the party that set the Tracking Pixel to monitor certain information about the viewer of the web page, web-based document or e-mail message and may allow access to certain cookies. Tracking Pixels are usually invisible to the user because they are very small (generally 1-by-1 pixel). In general, however, any electronic image viewed as part of a web page, including an Advertisement or Content, can act as a Tracking Pixel.
d) Tracking Pixels on the website typically collect the URL of the page from which the Tracking Pixel originates, the type of browser requesting the Tracking Pixel, the IP address of the computer or device ID of the device to which the Tracking Pixel is sent and the time that the Tracking Pixel was viewed.
e) Certain Tracking Pixels used by 3rd party advertisers, content providers or other service providers may collect information that allows such 3rd parties to determine how many people are viewing and/or clicking on certain Adverts or viewing certain Content, Promos or Experiences for purposes of helping these parties serve and manage their Adverts, Content, Promos and Experiences. These Tracking Pixels do not collect or store PI but they may, however, be used in conjunction with cookies to identify certain aggregate information about users.
DO NOT TRACK DISCLOSURES
TRC or its 3rd parties may also use tracking technologies to collect information about your visits over time and across 3rd party websites or other online services. The Network Advertising Initiative (NAI) is a cooperative group of ad serving providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations of Internet advertising practices and how they affect you and the Internet generally. For more information about the NAI, 3rd party ad servers generally and the opt-out options offered through the NAI, visit http://www.networkadvertising.org/index.asp.
Similarly, for residents of the European Union, Your Online Choices at http://www.youronlinechoices.eu is written and funded by the internet advertising industry and supports a pan-European industry initiative to enhance transparency and control for online behavioral advertising. Please visit the website and select the country option for which you are a resident to find out more information about your opt-out options.
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how TRC responds to “Do Not Track” browser settings. TRC does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. TRC continues to review new technologies and may adopt a standard once one is created.
5. HOW TRC USES INFORMATION
When you supply TRC with your PI, TRC may use it to manage TRC’s registry of Registered Users, facilitate communication between TRC and you and/or between Registered Users of an Experience, notify you of features or special events and provide you with other information TRC feels may be of interest to you. TRC also uses information collected to customize, analyze, adjust and improve our Experiences, Content, and Promos and to meet TRC’s users’ needs and expectations. TRC also may use the information to oversee adherence to TRC’s guidelines for user content which are provided in the terms of use for the Experiences to enforce TRC’s agreements with you, to prevent fraud and other prohibited or illegal activities and for other legally permissible purposes. These uses of your PI may include, without limitation, the following:
An Experience may feature groups, discussions, member profiles, comment areas, blogs and similar areas where users can share information about themselves and their opinions, as well as post questions and Content that may contain PI (“Public Forums”). Other visitors to an Experience may view information posted in Public Forums. Further, TRC may include all or a portion of the information posted in Public Forums in the newsletters described in this Privacy Policy. By using the Public Forums, you hereby acknowledge and agree that any information you share in a Public Forum (including, without limitation, PI) is available to the public. Information you post to a Public Forum may be viewed, accessed, or collected by, or disclosed to, 3rd parties and may be used by others in ways neither you nor TRC are able to control or predict, including, without limitation, to contact you for unauthorized purposes.
An Experience may offer the ability to share Content or communicate directly with other users via e-mail and other communications. Should you use e-mail or other communications, TRC will use the recipient’s e-mail address or other means of identification in order to send the Content and TRC will also ask for your e-mail address or other means of identification. TRC does not use the recipient’s e-mail address or other means of identification for any other purpose unless the recipient gives TRC permission to do so.
Should you have access to certain areas of an Experience because you are a Registered User (“Registered User Forums”), the Registered User Forums may contain groups, discussions, member profiles, comment areas, blogs and similar areas where Registered Users can share information about themselves and their opinions, as well as post or share Content. PI or Content you post or share through a Registered User Forum may be viewed, accessed, or collected by, or disclosed to, other Registered Users and may be used by other Registered Users in ways neither you nor TRC are able to control or predict, including, without limitation, disclosure of your PI or Content to the public or to contact you for unauthorized purposes. TRC uses the PI you supply when registering to become a Registered User to send you TRC publications, information about Registered User benefits and special offers, features included in the Registered User Forums and other information that TRC believes is relevant and useful to its Registered Users. By using the Registered User Forums, you hereby acknowledge and agree that any information you share in a Registered User Forum (including, without limitation, PI) is available to other Registered Users and to TRC for use as provided herein.
Should you register to become a Registered User of an Experience , the information that you supply to TRC may be associated with one or more profiles, which may be stored on our or 3rd party servers. These profiles, or a portion thereof, may be viewed by other Users of an Experience, including, but not limited to those who are not Registered Users of such Experience.
Should you register at an Experience or subscribe to any features or services, you may choose to receive a newsletter via e-mail from TRC or other notifications via a mobile application which may include information such as highlights from different areas on an Experience, and information about new features, Content, Promos or other Experiences. You can unsubscribe from the newsletter at any time by following the instructions, or clinking the links, as applicable provided at the bottom of any e-mail newsletter sent to you and following the instructions. You also may unsubscribe at any time by logging in to the applicable Experience where you created your profile and changing your preferences. Furthermore, you may elect to turn off notifications in a mobile application.
Often times, Promos offered on an Experience are sponsored by unaffiliated 3rd parties. Information that you supply as part of an entry into a Promotion sponsored by an unaffiliated 3rd party will be shared with the sponsor if TRC advises you of such in the Promos official rules. Some Promos also may require consent to the release of information contained within the entry form for background check purposes or tax purposes if you become a winner. You should carefully review the official rules of each Promotion that you enter as they may contain additional important information about TRC’s or the sponsor’s use of your PI.
TRC may retain other 3rd parties and individuals to provide features and Experiences consistent with TRC’s Privacy Policy on TRC’s behalf. Examples include customer support specialists, web hosting companies, fulfillment companies (e.g., companies that fill product orders or coordinate mailings), data analysis firms and e-mail service providers.
TRC also may use your PI in response to a solicitation for editorial, online or for marketing and promotional purposes in connection with such solicitation. If such information is used online, on a mobile application or in a telecast, no PI, other than name, city and state, will be disclosed without your consent.
TRC and the Content, Promos and Experiences, may include features that connect to social networks and allow you to share or like Content, Promos or Experiences with your friends or other users of the social networks. These social networks may collect information, such as your IP address, which page you are visiting on an Experience, the videos you viewed, or the Content, Promos or Experiences that you shared, and may set a cookie to enable the features to function properly. The social network providing the features on an Experience may be able to collect information about you, even if you don’t use those features. To control this sharing of information, please review the privacy policy of the relevant social network.
TRC may also use cookies to enable you to use a “shopping cart” if you want to enroll in a subscription or purchase goods or services while on an Experience, to store your preferences associated with purchased goods or services or other Content offered from an Experience and to offer you products, programs, or Promos based on purchases, subscriptions and Experience usage behavior that you and/or other customers have exhibited. Should you purchase a subscription or goods and services through an Experience, your PI and payment information (other than credit card or debit card information) will be collected and stored by us with your account.
Certain cookies that are set when some video products are accessed on an Experience, called local shared objects or Flash cookies, may not be managed using the settings in your web browser. Should you set your browser options not to accept cookies or local shared objects, you may not be able to take advantage of certain ecommerce Experiences, videos on an Experience. You agree that TRC may share your viewing of videos with, or obtain information about your viewing of videos from, analytics providers and advertising partners and third-party social media sites unless you withdraw your consent.
The aggregate information collected by TRC may also be used to create profiles of the audience for an Experience that include anonymous statistical demographic information but no PI. This aggregated information is used to, among other things, determine trends and needs and supply market research to potential advertisers and partners to help them understand our Experiences’ audiences. For example, TRC may create a report that tells advertisers that 30% of TRC’s Registered Users are males under 30 years, so that they can determine which of their Content, Promos or Experiences are most appropriate for TRC’s Registered Users.
From time to time, in TRC s sole discretion, TRC may use your PI to send you important administrative information regarding the Experiences or changes to TRC’s terms and policies. Because this information may be important to your use of the Experiences, you may not opt out of receiving such communications.
6. WITH WHOM TRC SHARES INFORMATION
TRC may share your PI with 3rd parties, as follows:
Should you “opt in” to receive information about identified advertisers or their services or products, TRC may share your PI with them. Should you have questions about how these companies use your PI, TRC encourages you to review and understand their respective privacy policies. You may at any time “opt out” of having your PI as part of TRC’s marketing mailing list or otherwise.
You can send an e-mail to info@toprightcorner.com; or you can send mail to the following postal address:
Top Right Corner
2021 Lakeshore Drive Suite 510
New Orleans, LA 70122
Attention: Legal
Adverts appearing on an Experience may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer or device each time they send you an online Advertisement to compile information about you or others who use your computer or device. This information allows ad networks to, among other things, deliver targeted Adverts believed to be of interest to you. This Privacy Policy covers the use of cookies by the Experiences and does not cover the use of cookies by any 3rd party, including any advertiser, each of whom maintain their own privacy policy.
TRC engages service providers to perform functions and provide services to us or on our behalf, including Promos, Adverts, and other programs. TRC may share your PI with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the 3rd parties use your PI only on our behalf and pursuant to our instructions.
TRC shares your payment information with payment services providers to:
a) process payments;
b) prevent, detect and investigate fraud or other prohibited activities;
c) facilitate dispute resolution such as chargebacks or refunds; and
d) for other purposes associated with the acceptance of credit or debit cards.
If such information is stored with TRC, TRC may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.
TRC may disclose any information, including without limitation PI that TRC deems necessary, in its sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. TRC also may exchange information, including without limitation PI, with other companies and organizations for credit fraud protection, risk reduction and related activities or to protect the rights, property of safety of TRC and its agents, employees or affiliates or others. TRC reserves the right to disclose a user’s PI if TRC believes the user is in violation of TRC’s terms of use, even without a subpoena, warrant or other court order.
7. SALE OR TRANSFER OF INFORMATION
In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets or equity of TRC or the Experiences, PI and/or other information collected about you from the Experiences may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of TRC or the Experience(s) in order to permit the party to continue the operation of the applicable Experience or Experiences. Subject to your ability to opt-out, you consent to the sale and transfer of your information as described in this paragraph.
8. ACCESSING, CORRECTING OR REMOVING YOUR PERSONAL INFORMATION
Should you become a Registered User and would like to review or update your profile, please log in to and select the profile in which you would like to review, modify or delete information (i.e., the PI you have provided to us). Should you would like to delete your profile, please contact us at info@toprightcorner.com
TRC respects the privacy of your PI. Should you tell TRC that you do not wish to have this information used as a basis for further contact with you, TRC will respect your wishes. You also may choose not to provide TRC with certain information, but that may result in you being unable to use certain features of an Experience. You may instruct TRC to stop sending you certain promotional materials (e.g., e-mail messages, newsletters, postcards and letters) by following the unsubscribe instructions provided in those materials or by turning of the notification feature on a mobile application. TRC may, however, continue to contact you to provide service to your account. Please note that if you use more than one name or e-mail address when communicating with TRC or participating on an Experience, you may continue to receive communications from TRC to any name and/or e-mail address which you have not specified in your opt-out request.
For any PI TRC holds, you can request that we correct the data if it is inaccurate or remove the data if we are not required to retain it by law or for legitimate business purposes. For example, under the Data Protection Directive (European Union Directive 95/46/EC of October 24, 1995) you are entitled to obtain information (a) confirmation as to whether data relating to you is being processed and information as to the purposes of the processing, the categories of data, and the recipients to whom the data are disclosed; (b) communication of the data undergoing processing and of any available information as to their source; and (c) knowledge of the logic involved in any automatic processing of data concerning you.
TRC may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Under the Data Protection Directive, we may charge you a €5 fee to comply with your request.
TRC provides you with the following options for correcting or removing your PI from TRC’s database for marketing purposes:
You can send an e-mail to info@toprightcorner.com; or you can send mail to the following postal address:
Top Right Corner
2021 Lakeshore Drive Suite 510
New Orleans, LA 70122
Attention: Legal
To cancel your account or subscription, you can: (a) e-mail info@toprightcorner.com, subject “Cancel My Account” or “Cancel My Subscription” and include the e-mail address that you registered your account or subscription with (if different from the e-mail address you’re sending the e-mail from); or (b) via your online Registered User account page. Remember that even after you cancel your account, copies of some information from your account may remain visible in some circumstances – where, for example, you have shared information with a 3rd party application or website. TRC may also retain backup information related to your account on our servers for some time after cancellation for fraud detection or to comply with applicable law or our internal security policies. Because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.
TRC will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law or unless otherwise limited by law.
9. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
The Experiences may contain links to 3rd-party web sites. Please be aware that TRC cannot control and is not responsible for the information collection practices of such web sites, which may differ from those of TRC. TRC encourages you to review and understand the privacy policies of these websites before providing any information to them.
TRC (either itself or through 3rd party service providers) maintains a variety of commercially reasonable physical, electronic and procedural safeguards designed to protect your PI from unauthorized access and disclosure. For example, TRC uses accepted tools and techniques to protect against unauthorized access to TRC’s systems. You should be aware that TRC has no control over the security of other sites on the Internet that you might visit or with which you might interact even when a link may appear to another site from one of the Experiences. TRC wants you to feel confident using the Experiences but no system can be completely secure. Therefore, although TRC takes steps to secure your information, TRC does not promise, and you should not expect, that your PI, searches or other communications will always remain secure. In the event of a breach of the confidentiality or security of your information, including your PI, TRC will notify you as necessary and if possible so you can take appropriate protective steps. TRC may notify you under such circumstances using the e-mail address(es) that TRC has on record for you and/or by regular mail (if available). You also should carefully handle and disclose your PI.
The Experiences are intended for general audiences and are not intended for children under seventeen (17) years of age. TRC requires that only persons seventeen (17) years of age or older use any of the Experiences. By using any Experience, you hereby represent that you are at least seventeen (17) years old. TRC does not knowingly market to, solicit information, accept service or collect information from children under the age of seventeen (17). A Experience may ask users for their birth dates to ensure that such Experience is not collecting information from children under age seventeen (17) or to identify when additional steps may need to be taken in connection with information collected from children under age seventeen (17). When TRC has actual knowledge that it collects information from children or offers a service directed toward children, it will comply with applicable laws, including the U.S. Children’s Online Privacy Protection Act of 1998. In the event that TRC learns that we have collected PI from a child under age seventeen (17) without parental consent, we will delete that information as quickly as possible. Should you believe that we might have any PI from or about a child under seventeen (17), please contact us at: info@toprightcorner.com
At any time without prior notice, TRC may update this Privacy Policy to reflect changes in TRC’s practices. When TRC posts changes to this Privacy Policy, TRC will revise the “Last Updated” date at the top of this page. TRC encourages you to bookmark this Privacy Policy and to periodically review it to inform yourself of changes to it or any of TRC’s other policies. Any changes to TRC’s Privacy Policy will become effective upon TRC’s posting of the updated policy.
Use of any Experience that links to this Privacy Policy constitutes your acceptance of the terms of this Privacy Policy then in effect.
CALIFORNIA PRIVACY RIGHTS.
This Privacy Policy for California Residents supplements the information contained above and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.
Information We Collect
TRC collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
a) Publicly available information from government records.
b) Deidentified or aggregated consumer information.
c) Information excluded from the CCPA's scope, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, our Experiences have collected the following categories of personal information from consumers within the last twelve (12) months:
TRC obtains the categories of personal information listed above from the following categories of sources:
a) Directly from you. For example, from forms you complete or products and services you purchase.]
b) Indirectly from you. For example, from observing your actions on our Website or through 3rd party reports relating to use of our Experiences.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following purposes:
a) To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
b) To provide, support, personalize, and develop our Experiences, website, products, and services.
c) To create, maintain, customize, and secure your account with us.
d) To process your requests, purchases, transactions, and payments and prevent transactional fraud.
e) To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
f) To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Experiences, Website, third-party sites, and via email or text message (with your consent, where required by law).
g) To help maintain the safety, security, and integrity of our Experiences, Website, products and services, databases and other technology assets, and business.
h) For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
i) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
j) As described to you when collecting your personal information or as otherwise set forth in the CCPA.
k) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our business is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a 3rd party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding 12 months, Company has not disclosed personal information for a business purpose.
We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding 12 months, Company has not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights (below).
Reselling Personal Information
The CCPA prohibits a 3rd party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete below), we will disclose to you:
a) The categories of personal information we collected about you.
b) The categories of sources for the personal information we collected about you.
c) Our business or commercial purpose for collecting or selling that personal information.
d) The categories of third parties with whom we share that personal information.
e) If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
f) sales, identifying the personal information categories that each category of recipient purchased; and
g) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
h) The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B personal information.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete below), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
a) Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
b) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
c) Debug products to identify and repair errors that impair existing intended functionality.
d) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
e) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
f) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
g) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
h) Comply with a legal obligation.
i) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request to info@toprightcorner.com or by mail to:
Top Right Corner
2021 Lakeshore Drive Suite 510
New Orleans, LA 70122
Attention: Legal
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
a) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
b) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor's identity or authority to make it. For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please resubmit your request via certified mail, return receipt requested to ensure proper delivery..
We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
[HYPERLINKED URL with the title "Do Not Sell My Personal Information"]
Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:
[OPT-IN INSTRUCTIONS OR URL LINK]
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
a) Deny you goods or services.
b) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
c) Provide you a different level or quality of goods or services.
d) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. [
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Experiences and Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [info@toprightcorner.com or write us at:
Top Right Corner
2021 Lakeshore Drive Suite 510
New Orleans, LA 70122
Attention: Legal
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which TRC collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at info@toprightcorner.com or
Top Right Corner
2021 Lakeshore Drive Suite 510
New Orleans, LA 70122
Attention: Legal
If you need to access this Policy in an alternative format due to having a disability, please contact info@toprightcorner.com