Effective date: 1^st December 2023

Policy Summary

Introduction:

• Ownership: Owned by 75 Oaks LLC, a US-registered company.
• Scope: Applies to www.nathantierney.com website and any future mobile app.
• Commitment: Emphasizes the importance of user privacy.

Information Collection:

• Voluntarily Provided Information: Includes name, email, address, phone number, payment details, order information, preferences, feedback.
• Automatically Collected Information: IP address, device type, browser, operating system, referral URL, pages visited, date/time of visit, cookies, and tracking technologies.
• Sensitive Data: No collection of sensitive personal information unless explicitly consented to by the user.

Usage of Information:

• Purposes: To provide services, process transactions, communication, marketing, personalization of experience, performance analytics, fraud prevention, legal compliance, rights and safety protection, and other consent-based uses.

Sharing of Information:

• Shared With: Affiliates, service providers, business partners, app developers, other users, law enforcement (if required), and other parties in business transactions.
• No Selling: Personal information is not sold for marketing purposes.

Protection Measures:

• Security Measures: Includes encryption, firewalls, limited access, staff training, and policy reviews.
• Responsibility: Users are responsible for maintaining the confidentiality of their account details.

User Rights and Choices:

• Rights: Access, update, correct, delete, restrict, object, withdraw consent, data portability, and complaint to authority.
• Opt-Out: Option to unsubscribe from marketing emails.

Special Provisions:

• General Data Protection Regulation (GDPR): Detailed rights for EU residents.
• California Consumer Privacy Act (CCPA): Detailed rights for California residents.
• US Privacy Provisions: Compliance with COPPA, GLBA, and FTC Act.

International Transfers:

• Transfer to the U.S.: Information may be transferred, stored, and processed in the U.S. Compliance with this policy and applicable laws ensured.

App Store Considerations:

• Apple and Google: Subject to the privacy policies of Apple App Store and Google Play Store.

Policy Updates:

• Revision Notification: Updates will be posted on the website with the revision date.

Contact Information:

• Contact Details: Queries can be directed to the75oaks@gmail.com

Full Privacy Policy

Thank you for visiting www.nathantierney.com. This website and any associated mobile app, is owned and operated by 75 Oaks LLC (“we”, “us”, or “our”), a company registered in the United States.

Your privacy is important to us. This privacy policy (“Policy”) describes how we collect, use, share, and protect your personal information when you visit our website or use our services. It also explains your rights and choices regarding your personal information and how you can contact us if you have any questions or concerns.

Please read this Policy carefully before using our website or services. By accessing or using our website or services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. If you do not agree with this Policy, please do not use our website or services.

What information do we collect?

We collect personal information that you voluntarily provide to us when you register on our website, place an order, subscribe to our newsletter, contact us, or otherwise interact with us. The personal information that we collect depends on the context of your interaction with us, but may include the following:

• Name
• Email address
• Postal address
• Phone number
• Payment information
• Order details
• Preferences and interests
• Feedback and reviews

We also collect some information automatically when you visit our website or use our services. This information may include the following:

• IP address
• Device type
• Browser type and version
• Operating system and version
• Referral URL
• Pages visited
• Time and date of visit
• Cookies and other tracking technologies

We do not collect any sensitive personal information, such as health, biometric, or genetic data unless you explicitly consent to provide it to us.

How do we use your information?

We use your personal information for various purposes, such as:

• To provide and deliver our products and services to you
• To process and complete your transactions and orders
• To communicate with you about your account, orders, and inquiries
• To send you newsletters, promotions, and marketing materials
• To personalize and improve your experience on our website and services
• To monitor and analyze our website and services performance and usage
• To prevent and detect fraud, security breaches, and illegal activities
• To comply with our legal obligations, policies, and procedures
• To protect and defend our rights, property, and safety, and those of our customers, partners, and third parties
• To exercise, establish, or defend our legal claims
• To fulfill any other purpose for which you provide your consent

How do we share your information?

We may share your personal information with the following parties, for the purposes described above:

• Our affiliates and subsidiaries
• Our service providers, contractors, and vendors who perform services on our behalf, such as payment processing, shipping, hosting, analytics, marketing, and customer service
• Our business partners and third parties who offer products or services that may be of interest to you
• Our mobile app developers and distributors, such as Apple and Google, may access your personal information to provide and improve their services
• Other users of our website and services, such as when you post a review, comment, or testimonial
• Law enforcement, regulators, courts, and other authorities, when required by law or to protect our rights, property, and safety, or those of our customers, partners, and third parties
• Other parties in connection with a merger, acquisition, sale, or other business transaction involving our company or assets
• Other parties with your consent or at your direction

We do not sell your personal information to third parties for their marketing purposes.

How do we protect your information?

We take appropriate technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Using encryption, firewalls, and other security technologies
• Limiting access to your personal information to our employees, agents, and service providers who need it to perform their duties
• Training our staff on data protection and privacy practices
• Reviewing and updating our policies and procedures regularly

However, no method of transmission or storage is 100% secure and we cannot guarantee the absolute security of your personal information. You are responsible for keeping your account password and other login details confidential and for notifying us immediately if you suspect any unauthorized access or use of your account.

What are your rights and choices?

Depending on your location and applicable laws, you may have certain rights and choices regarding your personal information. These may include:

• The right to access, update, correct, or delete your personal information
• The right to restrict or object to the processing of your personal information
• The right to withdraw your consent to the processing of your personal information, where applicable
• The right to receive a copy of your personal information in a portable format, where applicable
• The right to complain with a supervisory authority, where applicable

To exercise any of these rights, please contact us using the contact details below. We may ask you to provide proof of your identity and sufficient information to locate your personal information. We will respond to your request within a reasonable time and in accordance with applicable laws.

You may also opt-out of receiving marketing emails from us by following the unsubscribe link or instructions in the email. Please note that opting-out of marketing emails does not affect our ability to send you service-related communications, such as order confirmations, shipping notifications, or account updates.

California Consumer Privacy Act (CCPA)

This Privacy Policy is designed to comply with the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with specific rights regarding their personal information. These rights include:

• The Right to Know: You have the right to request information about the personal information we collect, use, disclose, and sell, as well as the categories of sources from which we obtain it.
• The Right to Access: You have the right to access and receive a copy of the personal information we hold about you.
• The Right to Deletion: You have the right to request that we delete the personal information we have collected about you, subject to certain exceptions.
• The Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
• The Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise any of these rights, please contact us using the information provided in the “How Can You Contact Us?” section of this Privacy Policy.

Other Applicable US Privacy Provisions

In addition to the CCPA, we also comply with other applicable US federal and state laws and regulations regarding data privacy and security, including:

• Children’s Online Privacy Protection Act (COPPA): We comply with COPPA by not knowingly collecting, using, or disclosing personal information from children under the age of 13 without verifiable parental consent.
• Gramm-Leach-Bliley Act (GLBA): We comply with GLBA by implementing appropriate safeguards to protect the privacy and security of non-public personal information of our customers.
• Federal Trade Commission (FTC) Act: We comply with the FTC Act by protecting the privacy and security of consumer information.

GDPR Compliance

75 Oaks LLC, in its operation of www.nathantierney.comand the Runaway Farms mobile app, acknowledges the importance of complying with the General Data Protection Regulation (GDPR), which applies to the processing of personal data of individuals in the European Union (EU).

Data Subject Rights Under GDPR:

• Right to Access: You have the right to request access to your personal data that we process.
• Right to Rectification: You are entitled to correct data that is inaccurate or incomplete.
• Right to Erasure (Right to be Forgotten): You may request the deletion of your data, subject to certain conditions.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data, particularly for marketing purposes.

Legal Basis for Processing:

• Consent: We will process personal data based on consent for specific purposes.
• Contractual Necessity: Processing is necessary for the performance of a contract or to take steps at your request before entering a contract.
• Legal Obligation: Where required by EU or Member State law.
• Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.

Data Protection Officer (DPO):

• We have appointed a Data Protection Officer (DPO) to oversee our data protection strategy and ensure compliance with GDPR requirements.
• Contact details of the DPO will be provided on our website.

Data Transfers Outside the EU:

• Personal data may be transferred to countries outside of the European Economic Area (EEA). We will ensure appropriate safeguards and legal frameworks, such as Standard Contractual Clauses, are in place for these transfers.

Automated Decision-Making and Profiling:

• We do not use automated decision-making processes, including profiling, which produce legal effects concerning you or similarly significantly affect you.

Data Breach Notification:

• In the event of a personal data breach, we will notify the appropriate supervisory authority within 72 hours, unless the breach is unlikely to result in a risk to your rights and freedoms.
• Affected individuals will be notified without undue delay if the breach is likely to result in a high risk to their rights and freedoms.

GDPR Complaints:

• If you believe that our processing of your personal data infringes the GDPR, you have a right to lodge a complaint with a supervisory authority responsible for data protection in your country of residence, place of work, or place of the alleged infringement.

Changes to Our GDPR Compliance:

• Any changes to our GDPR compliance will be communicated through updates to our privacy policy.

Contact Us:

• For any questions or concerns regarding our GDPR compliance, please contact us at the75oaks@gmail.com or reach out to our Data Protection Officer directly.

Cookies

While the policy mentions the use of cookies and other tracking technologies, it lacks specifics. Users would benefit from understanding the types of cookies used (e.g., session cookies, persistent cookies, advertising cookies) and their purpose. Additionally, providing instructions on how users can manage cookies through browser settings, or a dedicated cookie management tool would enhance transparency and user control.

Data Retention

The current policy does not specify how long personal information is retained. Users deserve clarity regarding data retention periods and the criteria used to determine them. Specifying the duration of data storage for different types of information would demonstrate commitment to data minimization and responsible data handling.

Data Breach Notification

The policy should include a clear procedure for notifying users in case of a data breach. This should detail the type of information that would be communicated, the timeframe for notification, and the contact channels that will be used. A data breach notification plan demonstrates responsible data handling and safeguards users’ interests.

Children’s Privacy

The policy does not explicitly address the collection and handling of children’s personal information. It is crucial to clarify how the company complies with relevant child protection laws and protects the privacy of young users. This could include outlining age verification procedures, obtaining parental consent for data collection, and limiting the types of data collected from children.

How do we handle international transfers?

Our website and services are hosted and operated in the United States. If you are located outside of the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States, where our servers and central database are located. The data protection and privacy laws of the United States may differ from those of your country of residence.

By using our website or services, or by providing us with your personal information, you consent to the transfer, storage, and processing of your personal information in the United States. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with this privacy policy and applicable laws.

Apple App Store and Google Play Store

When you download the App from the Apple App Store or Google Play Store, you will be subject to the privacy policies of those app stores. We are not responsible for the collection, use, or disclosure of your information by Apple or Google.

How do we update this privacy policy?

We may update this privacy policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other purposes. We will notify you of any material changes by posting the updated privacy policy on our website and indicating the date of revision. Your continued use of our website or services after the updated privacy policy becomes effective constitutes your acceptance of the updated privacy policy.

How can you contact us?

If you have any questions or comments about this privacy policy or our privacy practices, please contact us by:

• Email: the75oaks@gmail.com