Last Updated: September 24, 2020
In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we, Tolstoy (together, “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. "Personal Data" or "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.
Table of contents:
1. What Information We Collect, Why We Collect It, And How It Is Used
2. How We Protect And Retain Your Information
3. How We Share Your Personal Data
4. Storage Of Personal Data
5. Your Privacy Rights.
6. Use By Children
7. Interaction With Third Party Products
8. Log Files
9. Analytic Tools
10. Your Choices
11. How to contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website and/or Platform or by other means.
When you browse, or visit, our Website or Platform, we collect data about you through Cookies, analytic tools and log files.
When you are our Customer and you have signed up to and are using our Platform, you will provide us with your sign up information which may include email addresses, names, phone numbers, payment information and/or IP addresses. While using our Platform you may provide us with other information such as videos, pictures and/or any other content that you choose to upload to our Platform. We collect this information in order to allow you to use and access our Platform, create content using our Platform and to otherwise use the services provided by the Platform. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.
When you are a user and you are viewing, accessing, interacting or otherwise using the content created via our Platform, we may collect information from you which may include email addresses, names, phone numbers, comments, IP addresses, the time you spent interacting with the content created by our Platform and/or any other information you choose to share with us. We collect this information in order to allow you to interact, view, access and/or otherwise use the content created by our Platform. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel, Segment and/or with our customers who may engage with you using the content created on our Platform.
When you contact us (e.g. customer support, need help, submit a request), you will provide us with the following information: name, email address, country, and any messages or other information you wish to share with us. We use this information to answer your questions and to provide support (e.g. to solve problems, bugs or issues). We may also use your name and email details that you provide us with in order to send you marketing communications. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.
When you attend a marketing event, provide us with your business cards and/or provide us with your personal data for marketing purposes, we collect personal data that you provide us with, such data contains the following types of Personal Data: name, email address, phone number, company name, job title, country, and any other information you may wish to share with us. We use this information to establish a business connection and to send you marketing communications. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.
When we use the Personal Data of our service providers, we collect the following Personal Data from our service providers: name, email address, phone number, company name, job title, country, and any other data our service providers may choose to share with us. We collect this information in order to communicate with and perform the applicable agreement with our service providers. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn), we collect the following Personal Data: name, email address, phone number, company name, job title, country, and any other data you may choose to share with us. We collect this information in order to communicate with you, respond to your questions and/or requests and/or to otherwise engage with you. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.
Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
We share your Personal Data as follows:
We may also share your Personal Data as follows:
Rights: You may have certain rights under applicable privacy laws, such as accessing, correcting and deleting Personal Data, objecting to processing of Personal Data, withdrawing of consent to processing Personal Data. To the extent such privacy laws apply to you, we will respect your rights and comply with such laws.
You can exercise your rights by contacting us at privacy@gotolstoy.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen, do not provide any Personal Data to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at: privacy@gotolstoy.com.
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a "Third Party Service"). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website and/or Platform, track users’ movement around the Website and/or Platform, and gather demographic information.
We reserve the right to remove or add new analytic tools.
You have certain choices about your Personal Data. Where you have consented to the processing of your Personal Data, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Data regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@gotolstoy.com.