Privacy Policy
This Privacy Policy was last updated on 15.05.2024.
We appreciate your visit to the TONE TERRACE website. We, at TONE TERRACE ("TONE TERRACE," "we," "us," and related derivatives), respect your privacy and want to make it clear how we collect, use, and disclose data about you. This Privacy Policy describes our data collection practices and your rights regarding your personal data.
Unless we provide a link to other provisions or state otherwise, these Privacy Policy terms apply when you access or use TONE TERRACE's websites or related services (the "Services"). They also apply to potential customers.
By using the Services, you agree to the terms of use of this Privacy Policy. If you do not agree with the Privacy Policy or any other agreement governing the use of the Services, you should refrain from using the Services.
Table of Contents
1 Data We Collect
2 How We Receive Data from You
3 What We Use Your Data For
4 Who We Share Your Data With
5 Security
6 Your Rights
7 Updates and Contact Information
1.Data We Collect
We collect certain data directly from you, including information you enter, data about your content usage, and data from third-party platforms connected to TONE TERRACE. We also automatically collect some data, including information about your device and the services you interact with or use. For all data listed in this section, the following processing steps may be performed: collection, recording, structuring, storage, alteration, retrieval, encryption, pseudonymization, deletion, combination, and transmission.
1.1 Data You Provide Us
The data we collect from or about you depends on how you use the Services. Below are examples illustrating the data we collect.
When you create an account and use the Services, including via a third-party platform, we collect all data you directly provide, including:
Account Data
To use certain features (such as accessing content), as an Educator (Event Organizer), you must create a user account. For this, we need to collect and store your email address, password, and account settings. When using specific features on the website, you may be prompted to provide additional information, such as your occupation, details from your official ID, a photo as proof, your birthdate, ethnicity, skills of interest, and your phone number.
Profile Data
You can also provide profile information, such as a photo, a headline, a biography, language, country, or other data. Your profile data is publicly visible.
Shared Content
Parts of the Services allow you to communicate with other users or publicly share content. Depending on where it is posted, such shared content may be publicly accessible to others.
Participant Payment Details
If you make a purchase, we collect specific data about your purchase (e.g., your name, billing address, and ZIP code) required to process your order and may be optionally stored for handling future orders. Certain payment and billing information must be directly provided to our payment partners, including name, credit card details, billing address, and ZIP code.
Payment Details - Educator (Event Organizer)
If you are an Educator (Event Organizer), you can link a payment account to receive payments. When linking a payment account, we collect and use specific information, including the email address associated with your payment account, account number, mailing address, and other data required to transfer payments to your account. In some cases, we may collect ACH or wire information to send payments to your account. To comply with applicable laws, we also collaborate with trusted third parties who collect tax data according to legal requirements. Tax data may include information about your residence, tax identification numbers, and other personal data required for tax purposes. For security reasons, TONE TERRACE does not collect or store sensitive bank account data. The collection, use, and disclosure of your payment, billing, and tax data are subject to the privacy policies and other terms of use of your payment account provider.
Communication and Support
If you contact us for support or to report issues or concerns (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you, such as your name, email address, messages, location, TONE TERRACE user ID, refund transaction IDs, and other data you provide or that we automatically collect (as explained below). We use this data to respond to you and address your questions or concerns in accordance with these terms.
1.2 Data Automatically Collected by Us
When you access the Services (including browsing content), we automatically collect certain data, including:
System Data
Technical data about your computer or device, such as IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other system data, as well as platform types.
Usage Data
Usage statistics about your interactions with the Services, such as accessed content, time spent on specific pages or in the service, visited pages, used features, your search queries, click data, date and time, and other data about your use of the Services.
Approximate Geographical Data
Your approximate geographical location is calculated based on your IP address. This includes, among other things, the country, location, and geographic coordinates.
The above data are collected through server log files and tracking technologies.
1.3 Data from Third Parties
If you are a potential business user of TONE TERRACE, we may additionally collect certain business contact information from commercial third-party providers.
2 How We Receive Data from You
We collect the above data using tools such as cookies, web beacons, and similar tracking technologies. Some of these tools offer you the option to decline data collection (also known as "opt-out").
2.1 Cookies and Data Collection Tools
We use cookies. These are small text files stored by your browser to collect, store, and transmit data about your activities on websites (such as the TONE TERRACE website). They also allow us to store certain information about your visits to TONE TERRACE, such as your preferred language, making it easier and more enjoyable for you to use the website. For more information about cookies, visit https://cookiepedia.co.uk/all-about-cookies. We may also use transparent pixels in emails to track delivery and open rates.
TONE TERRACE and acting service providers (such as Google Analytics and third-party advertising partners) use server log files and automated data collection tools such as cookies, tags, scripts, custom links, device or browser fingerprints, and web beacons (collectively "data collection tools") when you access and use the Services.
2.2 Why We Use Data Collection Tools
TONE TERRACE uses the following types of data collection tools for the described purposes:
Necessary: These data collection tools enable you to access the website, provide basic functions (such as logging in or accessing content), secure the website, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are necessary for the proper functioning of the services. Disabling them will interrupt parts of the website or make them unavailable.
Functional: These data collection tools store data about your browser and preferences, provide additional website features, customize content to be more relevant to you, and store settings that affect the appearance and behavior of the services.
Performance: These data collection tools help measure and improve the services by providing usage and performance data, visitor numbers, traffic sources, or data on where an application was downloaded from. These tools help us test different versions of TONE TERRACE to see which features or content participants prefer and determine which email addresses are opened.
Social Media: These data collection tools enable social media features, such as sharing content with friends and networks. These cookies may track a participant or device across other sites and create a profile of participant interests for targeted advertising purposes.
You can configure your browser to warn you about attempts to place cookies on your computer, restrict the types of cookies you allow, or reject cookies altogether. However, if you reject/disable cookies, you may not be able to use some or all of the features of the services, or your experience may change or be functionally restricted.
3. What We Use Your Data For
We use your data, among other things, to provide our services, communicate with you, resolve problems, prevent fraud and abuse, improve and update our services, analyze the use of our services, display customized advertising and to comply with legal requirements or to ensure security and integrity to the extent necessary. We retain your data for as long as necessary for the purposes for which it was collected.
We use the data we collect through your use of the Services for the following purposes:
Providing and administering the Services, including enabling the use of learning content, issuing certificates of completion, displaying customized content, and enabling communication with other users (account data, shared content, learning data, system data, usage data, approximate geographic data);
Processing of payments to Educators and other third parties (payment data of participants, payment data of Educators);
Processing your requests and orders for educational content, products, certain services, information or functions (account data, learning data, payment data of participants, system data, communication and support);
Communicating with you about your account (account data, shared content, learning data, system data, communication and support)
- Answering your questions and other concerns
- Sending administrative messages and information to you, such as messages from Educators, participants and teaching assistants; notifying you of service changes and updates to our agreements.
Management of your account and account settings, personalization of your user experience (account data, learning data, payment data of participants, payment data of Aducators, system data, usage data, data on cookies)
Providing the technical functions of the service, e.g. troubleshooting, securing the services, preventing fraud and abuse (account data, payment data of participants, payment data of Aducators, communication and support, system data, approximate location);
Verifying the identity of Educators (account data, payment data of Aducators);
Obtaining user feedback (account data, communication and support);
Marketing of products, services, surveys and promotions (account data, learning data, promotions and surveys, usage data, cookie data);
Cross-device identification of unique users (account data, system data, cookie data);
Cross-device personalization of advertising (cookie data);
Improvement of our services and development of new products, services and functions (all data categories)
Analyzing trends and traffic, tracking purchases and usage data (account data, learning data, subscriber payment data, communication and support, system data, usage data, approximate geographic data, cookie data);
Advertising for the services on the websites and in third-party apps (account data, cookie data);
As required or permitted by law (all categories of data); or
As we, in our discretion, otherwise deem necessary to protect the safety or integrity of our users, employees, third parties, the public or our Services (all categories of data).
4. To whom we disclose your data
We disclose certain data about you to the following parties: Educatorss, companies providing services on our behalf, TONE TERRACE affiliate partners, our business partners, analysis and data enrichment providers, providers of the social media platforms you use, companies assisting us in conducting promotions and surveys, and advertising companies tasked with promoting our services. We may also disclose your data for security reasons, due to legal requirements, or as part of a corporate restructuring. Finally, we may also disclose data in other ways if they are aggregated or anonymized, or if we have obtained your permission.
We may disclose your data under the following circumstances, or as otherwise outlined in these privacy policies:
- To your Educators: We share data provided by you, including your email address, with Educators or teaching assistants whose content you have accessed or from whom you have requested information, so they can improve their content for you and other participants. This data may include information such as your country, browser language, operating system, device settings, the website through which you accessed TONE TERRACE, and specific activities on TONE TERRACE (e.g., enrolled learning content or course reviews).
- To other participants and Educators: Your shared content and other profile data may be publicly visible, depending on your settings, for other participants and Educators, including when you ask a question to an educator or teaching assistant, and your personal details (including your name) may be publicly visible. (Account data, profile data, shared content)
- To service providers, contractors, and agents: We disclose your data to third-party providers who perform services on our behalf, such as payment processing, abuse/fraud prevention, data analysis, marketing and advertising services (including retargeting), email and hosting services, as well as customer service and support. These service providers may have access to your personal data and are only allowed to use it according to our instructions to provide the requested service. (All data categories)
- To TONE TERRACE affiliate partners: We may share your data within our family of companies connected by joint ownership or control to enable or support the provision of services. (All data categories)
- To business partners: We have contractually agreed with other websites and platforms to distribute our services and direct traffic to TONE TERRACE. Depending on your location, we may share your data with these partners.
- To analysis and data enrichment services: As part of our use of analytics tools such as Google Analytics and third-party data enrichment services like ZoomInfo, we may disclose certain contact information or anonymized data as needed. Anonymized data is information from which we have removed details like your name and email address, replacing them with a string of characters. This allows these providers to offer analytics services or match your data with publicly available database information (e.g., contact and social information from other sources). This is done to make our communication with you more effective and personalized.
- For the use of social media features: Social media features in the services (e.g., Facebook's "Like" button) may allow external social media providers to collect information such as your IP address and the page you visited on the services, and set a cookie to activate the feature. Your interaction with these features is subject to the privacy policies of the respective third-party providers. (System data, usage data, cookie data)
- To conduct promotions and surveys: We may disclose your data to the extent necessary for the conduct, marketing, or sponsorship of promotions and surveys in which you voluntarily participate, as required by law, or as outlined in the rules of the promotion or survey. (Account data, promotions and surveys)
- For advertising purposes: If we decide to use an ad-supported revenue model in the future, we may use certain system and usage data and share it with external advertising partners and networks to provide general information about the demographics and preferences of our participants. We may also allow advertising partners to use data collection tools to gather data for targeted advertising, making their user experience more personalized (through targeted advertising) and conducting web analytics. Advertising partners may also share the data they collect about you with us. For more information or to opt out of participating in the usage-based advertising of advertising networks, please see "Your choices regarding the use of your data." Please note that after opting out, you will still see ads, but they will not be based on your usage behavior. (System data)
- For security reasons and to comply with legal regulations: We may disclose your data to third parties (all data categories) if we (at our discretion) believe in good faith that disclosure meets the following criteria:
Occurs within the scope of a judicial, administrative, or legal investigation or order or a similar proceeding.
Is reasonably necessary under a valid subpoena, warrant, or other legal order.
Is necessary to enforce our terms of use, privacy policies, and other legally binding contracts.
Is required for the detection, prevention, or rectification of fraud, misuse, improper use, potential violations of laws (or regulations or ordinances), or security and technical issues.
Is, in our discretion, reasonably necessary to protect the rights, property, or safety of TONE TERRACE, our users, employees, members, the public, or our services from imminent harm.
We may also disclose data about you to our auditors and legal advisors for the purpose of assessing our disclosure obligations and rights under these privacy policies. Or:
This is required or permitted by law.
During a change of control: If TONE TERRACE undergoes a business transaction such as a merger, acquisition, divestiture, or dissolution (including bankruptcy) or the sale of all or some of its assets, all your data may be disclosed or transferred by us to the successor organization or disclosed during consideration of such a change (including due diligence). (All data categories)
After aggregation/anonymization: We may disclose or use aggregated or anonymized data for any purpose.
With your permission: We may, with your permission, disclose data to third parties outside the scope of these privacy policies. (All data categories)
5 Security
We implement security measures that are appropriate for the type and sensitivity of the data. As with any internet-enabled system, the risk of unauthorized access is omnipresent. Therefore, it is crucial that you protect your password and contact us if you suspect unauthorized access to your account.
TONE TERRACE takes reasonable security precautions to protect the personal data we collect and store from unauthorized access, alteration, disclosure, or destruction. Depending on the type and sensitivity of the data, we employ various safeguards. However, achieving complete protection of a system is unfortunately not possible. Therefore, we cannot guarantee that the communication between you and TONE TERRACE, the services, or the information you provide us in connection with the data we collect through the services is entirely immune to unauthorized access by third parties. Your password is a crucial component of our security system, and you are responsible for protecting it. You should never share your password with third parties. If you believe that your password or account may be compromised, you should immediately change your password and contact us with any questions.
6. Your Rights
In connection with the use of your data, you have certain rights. This includes the ability to refuse promotional emails, cookies, and the collection of your data by certain third parties. You can update or cancel your account from our services and also contact us with individual requests regarding your personal data rights. Parents who believe that we have mistakenly collected personal data about minor children should contact us and request assistance in deleting this information.
6.1 Your Choices Regarding the Use of Your Data
You can choose not to provide us with certain data. However, this may mean that you cannot use certain features of the services.
The browser or device you use may allow you to manage cookies and other types of local data storage. For more information on managing cookies, please visit https://cookiepedia.co.uk/how-to-manage-cookies. With your wireless device, you may also be able to control whether location or other data is collected and shared.
If you want more information or want to know more about controlling cookies used for targeted advertising by participating companies, read the pages about consumer opt-out of the Network Advertising Initiative and the Digital Advertising Alliance.
6.2 Our Children's Policy
We recognize the importance of protecting the privacy of children and advise parents and guardians to actively participate in their children's online activities and interests. Individuals under 18 years of age, but who have reached the minimum age to use online services in their place of residence (e.g., 13 in the USA or 16 in Ireland), may not create an account but can have a parent or guardian create an account and assist with accessing appropriate content. Individuals below the minimum age for consent to use online services may not use these services. If we learn that we have collected personal data from a child below these age limits, we will take appropriate steps to delete this data.
Parents who believe that TONE TERRACE may have collected personal data from a child below these age limits can request the removal of this data by contacting us at office@toneterrace.com.
7. Updates and Contact Information
In the event of a significant change to these terms, we will notify users via email, through a notice in the product, or by another legally required method. Changes take effect on the day of their publication. For questions, concerns, or disputes, please contact us via email or by mail.
7.1 Changes to these Privacy Policies
We may change these privacy policies from time to time. If we make fundamental changes to them, we will inform you via email, by posting a notification in the services, or through the legally required method. We will also include a summary of the key changes. Unless otherwise specified, changes take effect on the day of their publication.
If you continue to use the services after the effective date of a change, your access and/or use of the services will be considered, under applicable law, as an acknowledgment that you agree to the revised privacy policies (and commit to comply with and consider them binding). The revised privacy policies supersede all previous privacy policies.
7.2 Interpretation
All basic terms not defined in these provisions are defined as set forth in the terms of use of TONE TERRACE.
7.3 Questions
For questions, concerns, or disputes regarding our privacy policies, you can contact our privacy team (as well as the data protection officer) at office@toneterrace.com.