Privacy Policy

Introduction

4TLH Inc. (referred to as “Company,” “we,” “our” and “us”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy (this “Policy”) describes the types of information we may collect from you or that you may provide when you access or use our websites or other services that link to this Policy, including www.4TLH.org (collectively, the “Services”), and discusses our practices for collecting, using, maintaining, protecting and disclosing that information.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.  This Policy applies to any personal information, and, in certain applicable instances, other information, collected on our Services. We use the information we collect from you to improve our Services and to provide you with a more personalized experience on our Services.  If you do not agree with our policies and practices, your choice is not to use our Services.  By accessing or using our Services, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Information We Collect About You

When we collect information from you, our primary goal is to provide you with an efficient and more personalized experience on our Services.  We may collect information about you, including Personally Identifiable Information (“PII”), from the information you voluntarily provide to us and through automatic data collection technology.  PII is any information that can be used on its own or with other information to personally identify you as an individual.  In some jurisdictions, PII may also include technical information such as Internet Protocol (“IP”) addresses.  PII that you may voluntarily provide to us includes, without limitation, the following:

  • Name;
  • E-mail address;
  • Mailing address;
  • Phone number; and
  • Billing information.

Information that we may collect through automatic data collection technology includes, without limitation, information about your internet connection, IP address, referrers, search terms, page views, operating system and browser type.

If you submit any PII relating to other people to us in connection with our Services, you represent that you have the authority to do so and to permit us to use such PII in accordance with this Policy.

How We May Collect Your Information

We may collect information in several ways, including:

  • Directly from you:  If you contact us, then we may collect information, including PII, through records and copies of your correspondence with us.  We may also collect your information, including your PII, when you (i) inquire about Services, (ii) report a problem with our Services, (iii) make a donation, or (iv) respond to our questions via e-mail or feedback forms.  If we collect information directly from you, then you have the option to refuse to provide us with such information.  However, if you decline to provide us information, then this may impact your ability to use our Services.  For other choices you may have, please see the Choices and Access section of this Policy.
  • Offline:  You may provide information, including PII, to us when you contact a website representative or contact customer support.
  • Through cookies (or browser cookies): A cookie is a piece of data stored on the user’s computer tied to information about the user. Cookies allow our Services to serve the user with specific information tied to the user and help facilitate ongoing access to our Services.  You may refuse to accept cookies by activating the appropriate setting on your browser.  However, if you select this setting, then you may be unable to access certain parts of our Services.  This Policy covers the use of cookies by only us.  We may use the following types of cookies on our Services:
    • Essential Cookies – These cookies allow you to browse our Services and use certain features.  If you disable these essential cookies, then you may be unable to use certain features.
    • Advertising Cookies – These cookies gather information about your use of our Services so that we can improve your experience and provide you with more relevant content and advertising.  These cookies are also used to gather feedback on certain marketing materials.
    • Preference Cookies – These cookies allow us to recognize your device so that you do not have to provide us with the same information more than once.  If you disable these preference cookies, then our Services may not be able to remember certain choices that you previously made or personalize your browsing experience.
    • Performance Cookies – These cookies collect information about how you use our Services, such as which pages you most frequently visit.  We use performance cookies to provide you with a high-quality experience by doing things such as tracking page load, site response times and error messages.
  • Through Flash cookies:  Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Services.  Flash cookies are not managed by the same browser settings as are used for browser cookies.  For information about managing your privacy and security settings for Flash cookies, please see the Choices and Access section of this Policy.  
  • Through server log files: Our Services may use log files to collect information about your computer and internet connection, which may include information about your IP address, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, and number of clicks. This information may be used to analyze trends, administer our websites, track your movement in the aggregate, and gather broad demographic information for aggregate use.
  • Through web beacons:  Web beacons are small electronic files that permit us, for example, to count the number of users who have visited certain pages of our Services, open a particular e-mail or other related website statistics.
  • Through internet tags:  Internet tags are smaller than cookies and tell our Services server information such as the IP address and browser type related to your computer.
  • Through third parties:  We may collect information, including PII, from third party sources, including, without limitation, our business partners and service providers.

We will rely on consent, which in some cases may be implied, to use technical information that may be collected through our use of cookies, Flash cookies, server log files, web beacons or internet tags.  You may withdraw consent at any time by contacting us as described in this Policy.  We may also use cookies, Flash cookies, server log files, web beacons and internet tags to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).  Note that your browser settings may allow you to send a “Do Not Track” signal to websites you visit.  If you elect to send a “Do Not Track” signal when you visit our Website, we will not track your visit to our Website.  To find out more about “Do Not Track” signals, visit http://www.allaboutdnt.com.

The information that we may collect automatically is statistical data and may, depending on applicable law, include PII, and we may maintain it or associate it with PII we collect in other ways.  It helps us to improve our Services by enabling us to estimate our audience size and usage patterns, speed up your searches, recognize you when you return to our Services and store information about your preferences.

How We May Use Your Information

To the extent permitted by applicable law, we may use information, including PII, that we collect:

  • To collect donations.
  • To send you newsletters.
  • To manage your relationship with us.
  • To create and review data about our users and how they use our Services.
  • To test changes in our Services and develop new features and products.
  • To fix problems you may have with our Services.
  • To manage the Services platform, including support systems and security.
  • To prevent, investigate and respond to fraud, unauthorized access to or use of our Services, breaches of our policies or other wrongful behavior.
  • To supply information to you upon your request.
  • To present our Services and its contents to you in a fashion customized to match your preferences.
  • To personalize your experience on our Services.
  • To allow you to participate in interactive features on our Services.
  • To send administrative information to you, including, without limitation, information regarding our Services and changes to our terms, conditions, features and policies.
  • To help connect you with other supporters, and to solicit volunteers, donations, and support for the Company and for issues, events, and organizations that we support.
  • To carry out obligations and enforce our rights arising from any contract entered into between you and us.
  • To pursue our legitimate interests.
  • To comply with legal process.
  • To respond to request from public and government authorities.
  • To enforce our Terms and Conditions located at www.4TLH.org/terms (the “Terms and Conditions”).
  • To protect our operations or those of any of our subsidiaries or affiliates.
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, subsidiaries, you or others.
  • To allow us to pursue available remedies or limit the damages that we sustain.
  • For any other purpose with your consent.
Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

To the extent permitted by applicable law, your PII may be disclosed as follows:

  • Service Providers:  We may disclose your PII with service providers, contractors and other third parties that we have retained to perform certain services and functions on our behalf, and these service providers, contractors and other third parties have agreed to use any PII solely as necessary to perform the services and functions in accordance with this Policy and our instructions and subject to appropriate nondisclosure limitations.
  • Subsidiaries and Affiliates:  We may disclose your PII to our subsidiaries and affiliates for the purposes described in this Policy.
  • Law Enforcement:  We may disclose your PII to comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • Reorganization:  We may disclose your PII to any third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of any or all portion of our business, assets or equity interests, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.  Any PII that an individual submits or that is collected after a reorganization may be subject to a new privacy policy adopted by the successor entity, of which we will inform you, when required.
  • Fraud Protection and Protection of Legal Rights:  We may disclose your PII to the appropriate legal, judicial or law enforcement authorities and our advisors and investigators: (i) when we believe, in our sole discretion, that such disclosure is necessary to investigate, prevent or respond to suspected illegal or fraudulent activity or to protect our safety, rights or property and those of each of our donors, service providers, business partners, representatives, website visitors, prospective employees, or others; (ii) when we suspect abuse of our Services or unauthorized access to our Services or any system, spamming, denial of service attacks, or similar attacks; (iii) to exercise or protect legal rights or defend against legal claims; or (iv) to allow us to pursue available remedies or limit the damages that we may sustain.
  • Payment Processing:  We may disclose your PII to our payment processing partner to process certain donations. If you make a donation using a credit card, our payment processing provider may store your full name and credit card details.
  • Enforcement of Agreements:  We may disclose your PII to enforce or apply our Terms and Conditions and other agreements that we may have with you.
  • Consent:  We may disclose your PII with your consent and for any other purpose disclosed by us when you provide your PII.

We do not disclose or sell any PII to any unaffiliated third party for direct marketing purposes.

Third party Collection, Use, and Disclosure of your Information

In some cases, we may process your PII pursuant to an agreement with a third party.  In these cases, the terms of that agreement may govern how we process your PII.  If you believe a third party has asked us to process your information on their behalf, then please consult with such third party as they will be responsible for how we process your information.

Our Services contain or may contain links to various third party websites.  These third party websites may collect PII and other related information. This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including any third party operating any website to which our Services contain a link. The inclusion of a link on our Services does not imply endorsement of the linked site by us or any of our subsidiaries or affiliates.

Additionally, some content or applications on our Services are served or serviced by third parties. These third parties may use cookies or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your PII or they may collect information, including PII, about your online activities over time and across different websites and other online services.

We do not control these third parties’ tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Choices

We strive to provide you with choices regarding our use and disclosure of PII. We have created mechanisms to provide you with the following control over your information, including your PII:

  • Marketing Messages:  You can opt out of email marketing messages we send. You can opt out of these messages by clicking on the “unsubscribe” link in the email message or by emailing admin@4tlh.org.  Please note that we may send you one message to confirm you want to opt out. If you are a registered user of our Services, or if you have engaged in transactions (including any donations) with us, we may continue to send transactional or relationship messages after you opt out of marketing messages.
  • Cookies and Other Related Technology:  At this time, we are not in a position to honor “do not track” signals from website browsers. However, you may refuse or delete cookies. If you do so, some of the functionality of our Services may be impaired. Additionally, you may still be identifiable, and your usage may still be trackable by other means. Please refer to your browser’s “Help” instructions to learn more about how to manage cookies and the use of similar technologies.
Your Privacy Rights

You may have certain rights related to your PII, subject to local data protection laws.  These rights may include:

  • You have a right to correct inaccurate PII about you.
  • In certain situations, you can ask that we delete/erase or stop using your PII (and object to use of your PII) or export your PII to another provider. 
  • Where we rely on your consent to process your PII, you have the right to decline consent and/or if provided, to withdraw consent at any time. This will not affect the lawfulness of processing PII prior to the withdrawal of your consent. At any time, you can request that we stop using your PII for direct marketing purposes.
  • If you are unsatisfied with our response to your complaint, you have a right to raise questions or complaints with your local data protection authority.

We will take reasonable steps to verify your identity and may require you to provide additional information from which we can confirm your identity.

You may authorize an agent to make a request to us on your behalf and we will verify the identity of your agent or authorized legal representative by either seeking confirmation from you or documents provided by you that establish the agent’s authorization to act on your behalf.

Security

When users submit sensitive information via our Services, their information is protected both online and offline. Prevention of unauthorized access or disclosure of data is of the utmost importance. Physical, administrative and technical procedures are employed to safeguard all collected information.

All data transactions occurring over a public network (i.e. the Internet) are encrypted using SSL technology.  Specific certifier details can be inspected in your browser during a secure session (see browser-specific help for details).

Access to PII and data by our employees, service providers and independent contractors is limited to those persons or agents that have a specific business purpose for maintaining and processing such PII.  These individuals are made aware of their responsibilities to protect the security of that PII and also uphold the principles of confidentiality and integrity.

Unfortunately, new vulnerabilities arise in the realm of technology every day. Although we strive to protect your information, circumstances beyond our control may compromise that goal. As with any website or mobile application, please be conscious of the data you share.  If you are not comfortable providing any information, it is your right to withhold it.  IN NO EVENT SHALL WE BE LIABLE FOR ANY DAMAGES (WHETHER CONSEQUENTIAL, DIRECT, INCIDENTAL, INDIRECT, PUNITIVE, SPECIAL OR OTHERWISE) ARISING OUT OF, OR IN ANY WAY CONNECTED WITH, A THIRD PARTY’S UNAUTHORIZED ACCESS TO YOUR INFORMATION, REGARDLESS OF WHETHER SUCH DAMAGES ARE BASED ON CONTRACT, STRICT LIABILITY, TORT OR OTHER THEORIES OF LIABILITY, AND ALSO REGARDLESS OF WHETHER WE ARE GIVEN ACTUAL OR CONSTRUCTIVE NOTICE THAT DAMAGES WERE POSSIBLE, EXCEPT AS PROVIDED UNDER APPLICABLE LAWS.

Indemnity

As a condition to accessing or using our Services, you agree to indemnify and hold harmless the Company, its subsidiaries and affiliates and its and their respective directors, managers, shareholders, members, officers, employees and agents against any and all liabilities, expenses (including, without limitation, attorneys’ fees and court costs) and damages arising out of or otherwise in connection with third party claims resulting from or otherwise in connection with your access to or use of our Services, including, without limitation, any claims alleging facts that, if true, would constitute a breach of the terms and conditions stated in this Policy.

Retention Period

We may retain your PII for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

Changes to Our Privacy Policy

If we decide to change this Policy, we will post any changes we make on this page with a notice that this Policy has been updated on the home page of our websites.  Any changes to this Policy will become effective when we post the revised Policy on our Services. The effective date for this Policy is identified at the top of this page. You are responsible for periodically visiting our Services and this Policy to check for any changes. Your use of our Services following these changes means that you accept the revised Policy.

Children

Our Services are not intended for children (as defined by local law).  We do not knowingly collect PII from children.  In the event that we learn that we have collected PII from a child, we will delete such PII as soon as possible.  If you believe we might have any PII from or about a child, then please contact us using the contact information listed below (see Contact Information).

California Privacy Rights

For purposes of the California Consumer Privacy Act of 2018 (CCPA), we are generally a service provider to our customers.  In instances in which we have not collected or processed PII as a service provider, you, as a California resident, have the right to make the following requests with respect to your PII:

  • You have the right to request that we disclose to you the categories of PII we collected about you, the categories of sources from which we collected the PII, the categories of PII we sold or disclosed, our business or commercial purpose for collecting and selling PII, the categories of third parties with whom we shared your PII and the specific PII we collected about you during the past twelve (12) months. 
  • Subject to certain exceptions, you can request that we delete your PII that we maintain about you.

California residents can exercise these rights by contacting us in the manner listed below (see Contact Information).  We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.  If you reside in California, you also have the right to ask us one (1) time each year if we have shared your PII with third parties for their direct marketing purposes. To make a request, please contact us in the manner listed below (see Contact Information).

Contact Information

If you have any questions, comments or concerns about this Policy or other privacy-related matters, then you may contact us in the following ways:

Mailing Address:        1427 Piedmont Drive East, Tallahassee, FL 32308

Email Address:           admin@4tlh.org

USERS FROM THE EUROPEAN UNION, UNITED KINGDOM AND SWITZERLAND

This section of this Policy applies to users of our Services from a Member State of the European Union, United Kingdom or Switzerland, and supplements the other information in this Policy.

Lawfulness of Processing

If European data protection law applies and we act as a data controller under such laws, our legal basis for processing your personal data (“Personal Data”) will depend on the Personal Data concerned and the specific context in which we collect or use it.

We normally collect or use Personal Data from you or others only where we have your consent to do so, where we need the Personal Data to process a donation, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain your Personal Data or may need your Personal Data to protect your vital interests or those of another person. For example, when we:

  • Use names and email addresses for email marketing purposes, we do so with your consent (which you can withdraw at any time) or where permitted under applicable law, on the basis of our legitimate interests.
  • Gather and analyze usage data in an effort to improve our Services and/or ensure the security of our Services, we do so based on our legitimate interest in safeguarding and improving our Services.

If you have questions about or need further information concerning the lawful basis on which we collect and use your Personal Data, please contact us in the manner listed above (see Contact Information).  Please note in situations where we acts as a data processor, it is our customer who determines the appropriate legal basis and queries should be directed to them.

Cross-Border Transfer

When Personal Data is transferred out of the country where the owner of that Personal Data lives, such as from citizens of the European Union, United Kingdom and Switzerland to the United States of America, different standards may apply to how your Personal Data is used and protected in those countries.  We have appropriate safeguards in place in accordance with applicable legal requirements to adequately protect your Personal Data irrespective of the country.  If you prefer not to have your Personal Data transferred, then do not access or use our Services.

Your Rights

If you are in the European Union, United Kingdom or Switzerland, then you also have the following data protection rights:

  • The right to access:  You have the right to request copies of your Personal Data.  We may charge a small fee for this service.
  • The right to rectification:  You have the right to request that we (i) correct any information you believe is inaccurate or (ii) complete information you believe is incomplete.
  • The right to erasure:  You have the right to request that we erase your Personal Data, under certain conditions.
  • The right to restrict processing:  You have the right to object to our processing of your Personal Data, under certain conditions.
  • The right to data portability:  You have the right to request that we transfer data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one (1) month to respond to you.  If you would like to exercise any of these rights, then please contact us using the contact information listed above (see Contact Information).