I. WHO MAY USE THE WEBSITES
B. Users Outside Of the United States. The Websites are intended for users from the United States and those not governed by privacy policies of other countries. Users from the European Union are advised not to disclose Personal Information to Tuuwa. Information sent to us will be housed on servers located in the state of Tennessee, in the United States. Do not send us information unless you consent to the application of U.S. law and to the use and disclosure of your information consistent with this Privacy Statement.
II. INFORMATION COLLECTION
Tuuwa is the sole owner of the Website, including Replicated Websites. We collect information from Independent Wellness Advisors (“Wellness Advisors”), Customers and visitors to the websites at different points on the websites.
A. Traffic Data. Like most website operators, Tuuwa automatically gathers information of the sort that browsers automatically make available, including: (i) IP addresses; (ii) domain servers; (iii) types of devices accessing the Website; and (iv)types of Web browsers accessing the Website (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you.
C. Personal Information. Through your use of or visits to our websites, you may be required or requested to provide personally identifiable information (hereafter “Personal Information”) to us. Personal Information is any piece of information which can potentially be used to uniquely identify, contact, or locate a single person. Such information includes, without limitation: (1) “Contact Data” (such as your name, mailing address and e-mail address); (2) “Demographic Data” (such as your age, gender, profession, education level, relationship status, religious affiliation, country, state, city and likes and dislikes,); and (3) “Financial Data” (such as your credit/debit card number and expiration date).For certain transactions, we may be required to collect information to comply with legal requirements. In each case, you will be asked to provide Personal Information; the Website will not gather it surreptitiously. Tuuwa may supplement the Personal Information you provide with additional personal information gathered from public sources or from third-parties (e.g., consumer reporting agencies) who may lawfully provide such information to Tuuwa. You are under no obligation to provide Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the features and services available on the Website or from purchasing any of our products.
E. Wellness Advisor and Customer Registration. In order to become a Wellness Advisor, an applicant must provide Personal Information to us. We also may require an applicant’s Social Security Number or Federal Tax ID Number so that we may prepare and file necessary non-employee compensation forms for the IRS. Certain customers may be required to register in order to purchase products directly from us (“Preferred Customers” or “Direct Customers,” both of which are collectively referred to herein as “Customers”). Customers will be required to provide Personal Information. We use this information to maintain contact with Wellness Advisors and Customers, and to process Wellness Advisor and Customer orders.
F. Product or Service Purchases. When a retail customer, Customer, or Wellness Advisor purchases products or services from us through any of our websites, the purchaser must provide us with Personal Information. This information is used for billing and payment purposes and to fill orders.
G. Information that you make Public. The Website may contains features (e.g. public profiles, forums, and message boards) that permit you to upload, post, transmit, display, perform or distribute content, information or other material, including some of your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which Tuuwa is unable to exercise control. You should exercise caution when deciding to disclose your Personal Information by means of such features, and you agree to assume all responsibility for doing so.
III. INFORMATION USE AND DISCLOSURE PRACTICES
❖ allowing you to enter your password less frequently;
❖ remembering your preferences;
❖ presenting information that is targeted to your interests;
❖ measuring the effectiveness of our sites, services, content, and advertising; and
Tuuwa analyzes Traffic Data and information gathered using Cookies to help Tuuwa better understand who is using the Website and how they are using it. By identifying patterns and trends in usage, Tuuwa is able to better design the Website to improve your experience, and to serve you more relevant and interesting content. From time to time, Tuuwa may release Traffic Data and information gathered using Cookies in the aggregate, such as by publishing a report on trends in the usage of the Website. Tuuwa does not attempt to link information gathered using Cookies to Personal Information.
B. Web Beacons. We may also use web beacons. A “web beacon” is an electronic image placed in the code of a web page. Beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our website and other sites were effective. We use web beacons to monitor the traffic patterns of users from one page to another and to improve site performance.
• Disclosure in Connection with Services. Some of our operations, such as our electronic commerce, may be managed by Service Providers who are unaffiliated companies. These companies may share Personal Information with their affiliates and service providers whom they engage to perform services related to our Websites or the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, Website hosting and evaluation, data storage, analysis, or security and, where applicable, data cleansing. These companies may have access to your Personal Information on a confidential basis only to the extent necessary to perform their functions. In no event will we authorize these companies to use your Personal Information for any reason other than to provide you with those specific services. If your purchases are being shipped to you, your shipping information will be shared with our delivery service providers (U.S. Postal Service, UPS, FedEx, or other delivery companies we or you select). Our delivery service providers are asked not to use your Personal Information for any purpose other than making the delivery.
• By Law or to Protect Rights. Tuuwa discloses Personal Information when required to do so by law, or in response to a subpoena or court order, or when Tuuwa believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of Tuuwa, third parties, or the public at large.
• Legally Required Law Enforcement, Judicial and Administrative Agency Disclosures. Tuuwa will provide confidential and personally identifiable information as necessary to comply with judicial and administrative orders, subpoenas, Civil or Criminal Investigative Demands, Administrative and Regulatory Demands and other legal obligations. In order for Tuuwa to conduct business in certain jurisdictions, Tuuwa must disclose certain personally identifiable and confidential information to regulatory authorities in such jurisdictions. Such information may include, but is not limited to, income information and personally identifiable information.
• Unpaid Accounts. If you fail to pay any balance owed in consideration of Services, Tuuwa may, as permitted by law, report your Personal Information, including without limitation your unpaid balance, to consumer credit reporting services, collection agencies and others.
• Invite a Friend. When you invite family or friends to join the Tuuwa network or to attend a Tuuwa home party, Tuuwa will send an email on your behalf to the indicated recipient. Your name and email address will appear in the “From” line of such email.
• Lead Assignment and Wellness Advisor Locator Features. Tuuwa occasionally will assign prospective sales and new Wellness Advisor leads to Wellness Advisors. In these cases, we will provide the lead with the appropriate Wellness Advisor’s name and contact information and/or provide a distributor with the prospective lead’s name and contact information. In addition, Tuuwa has a Wellness Advisor Locator feature on its website. Pursuant to this feature, a prospective customer or new Wellness Advisor can locate a nearby Tuuwa Wellness Advisor. In order to make the Wellness Advisor Locator feature and the lead assignments effective, the company will provide the prospective customer or new Wellness Advisor with the Wellness Advisor’s name and contact information, which may include his/her telephone number, address, and/or email address.
• To help Wellness Advisors in Tuuwa’s network marketing program manage their independent businesses, we provide your Tuuwa sponsor and other upline Tuuwa Wellness Advisors with your name, rank, address, telephone number, and email address as well as data relating to your sales and recruitment activity through the Back-Office to the Website. We also provide downline Wellness Advisors with the names, rank, address, telephone number, and email address of their sponsor and certain specified upline Wellness Advisors.
IV. COMMUNICATIONS FROM US
A. Special Offers and Updates. By enrolling as a Wellness Advisor, registering as Customer, or making a purchase or other inquiry through the Website, you consent to receive periodic email and other communications from us and from Tuuwa Wellness Advisors. For example, Tuuwa sends all new Wellness Advisors and Customers a welcoming email to verify password, username, and acceptance of the Wellness Advisor Agreement or Customer Agreement. All Wellness Advisors and Customers will occasionally receive information on products, services, special deals, and a newsletter. Customers who have not registered with Tuuwa and who grant permission will also receive occasional information on products, services, special deals, and the like.
B. Service Announcements. On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send Wellness Advisors and/or Customers an email. Generally, Wellness Advisors may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
C. Wellness Advisor and Customer Service. Tuuwa communicates with Wellness Advisors and Customers via email, regular mail and telephone on a regular basis to provide requested services and in regards to issues relating to their Tuuwa business. Tuuwa communicates with other Customers with respect to products or services purchased by such Customers from Tuuwa. Such communications may be by email, regular mail, or telephone.
D. Privacy Preferences/Opt-Out. We now offer an on-line preference page located within the My Account section on www.Tuuwa.com where you can register and change your preferences to receive or not receive marketing materials. You may also update what product/lifestyle preferences you prefer, which may determine what offers and promotional materials you may receive. You may update these preferences at any time, but you must first register by creating an account before you can update any of your preferences. Please allow sufficient time for your preferences to be processed. You may also change your marketing preferences or remove yourself from our mailing list by clicking on an “unsubscribe” hyperlink contained in promotional emails we send you or by contacting us at: Tuuwa, Customer SupportDepartment,235 Germantown Bend CV, Cordova, Tennessee38018, Attn: Privacy Manager or by e-mailing us at privacyconcerns@Tuuwa.com.
A. Links. Tuuwa’s websites may contain links to other sites. Please be aware that Tuuwa is not responsible for the privacy practices of such other sites. We encourage users to be aware when they leave our site and to read the privacy statements of each and every website that collects Personal Information. This privacy statement applies solely to information collected by Tuuwa websites.
B. Security of Personal Information. We maintain administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control. We also are committed to employing reasonable technology in order to protect the security of our Websites. However, even with the best technology, no website is 100% secure. We will take reasonable measures which we believe are appropriate to protect your Personal Information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer such information to take comparable steps to protect that security.
C. Secure Shopping. When you place orders on our Websites, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our Websites from capturing and viewing your Personal Information. Since any order information you provide to us on our Websites will be transmitted using a secure connection, if your Web browser cannot support this level of security, you will not be able to order products through our Websites. The most recent versions of Google Chrome, Netscape Navigator, Apple Safari, and Microsoft Internet Explorer can support a secure connection and can be downloaded for free from the Google, Netscape, Apple, or Microsoft website respectively.
D. Passwords. To provide you with an increased level of security, online access to your Personal Information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. Tuuwa will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or e-mail messages).
E. Lost or Stolen Information. You must promptly notify us if your credit, banking, other financial information, user name or password is lost, stolen or used without permission. In such an event, we will remove that credit card number, bank account information, other financial institution information, user name or password from your account.
H. Making Changes to Your Personal Information. Wellness Advisors and Customers may update their personal information as necessary by logging into their Tuuwa online Back Offices or Customer Accounts, which allows them to access and edit their registration account information. In addition, Wellness Advisors and Preferred Customers may contact us at email@example.com to update their profiles.
I. Information Sharing Disclosure Requests. If you are a California resident, you have the right to request one Notice of Information-Sharing Disclosure per year which will identify the third parties with whom Tuuwa or any of our affiliates has shared the Personal Information we have collected from you. You may request the Notice of Information-Sharing Disclosure by writing to us at. Tuuwa, 235 Germantown Bend CV, Cordova, Tennessee38018, Attn: Privacy Manager or by e-mailing us at customerservice@Tuuwa.com. We will respond to your request for a Notice of Information-Sharing Disclosure within 30 days.