PRIVACY POLICY

 
 

Last updated September 18, 2018  

Thank you for choosing to be part of our community at TLA (USA) Inc., doing business as Octaive (“Octaive”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@octaive.com.

When you visit our website https://octaive.com, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as https://octaive.com),and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites"). 

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  

TABLE OF CONTENTS  

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?   

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?      

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?  

7. DO WE COLLECT INFORMATION FROM MINORS?  

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

10. DO WE MAKE UPDATES TO THIS POLICY?

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?  

Information automatically collected 

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes. 

Like many businesses, we also collect information through cookies and similar technologies.  

Information collected from other sources 

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.   

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).  



2. HOW DO WE USE YOUR INFORMATION?  

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.   

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.  

We use the information we collect or receive:                  

To protect our Sites for Business Purposes. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).                           

For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.                             

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?  

 

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.  

We only share and disclose your information in the following situations: 

Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 

Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.  

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.    

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.         

With your Consent. We may disclose your personal information for any other purpose with your consent.    

 

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?  

 

In Short:  We may use cookies and other tracking technologies to collect and store your information.  

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.           

5. HOW LONG DO WE KEEP YOUR INFORMATION?  

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.   

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 90 days. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?   

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.  

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment. 

7. DO WE COLLECT INFORMATION FROM MINORS?  

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.   

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at privacy@octaive.com.  


8. WHAT ARE YOUR PRIVACY RIGHTS?  

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.   

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.   

 If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm      

 

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Sites visit http://www.aboutads.info/choices/.    

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?  

 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.   

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.

10. DO WE MAKE UPDATES TO THIS POLICY?  

 

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.  

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?  

 

If you have questions or comments about this policy, you may email us at privacy@octaive.com or by post to:

TLA (USA) Inc.      

151 West 25th Street, 2nd Floor   

New York, NY 10001      

United States            

If you are a resident in the European Economic Area, the "data controller" of your personal information is TLA (USA) Inc.. TLA (USA) Inc. has appointed Octaive Holdings Ltd to be its representative in the EEA. You can contact them directly regarding the processing of your information by TLA (USA) Inc., by email at privacy@octaive.com or by post to:

Octaive Holdings Ltd.

20 Chapel Street

Liverpool

L3 (AG  

 

If you have any further questions or comments about us or our policies, email us at privacy@octaive.com or by post to: 

TLA (USA) Inc.  

151 West 25th Street, 2nd Floor  

New York, NY 10001     

United States     

Phone: +1 (646) 586-2875   

 

COOKIE POLICY 

Last updated September 18, 2018   

 

This Cookie Policy explains how TLA (USA) Inc., doing business as Octaive ("Octaive", "we", "us", and "our") uses cookies and similar technologies to recognize you when you visit our websites athttps://octaive.com, ("Websites"). It explains what these technologies are and why we use them, as well as your rights to control our use of them.  

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information. In such cases our Privacy Policy (https://octaive.com/privacy) will apply in addition to this Cookie Policy.    

 

What are cookies? 

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. 

Cookies set by the website owner (in this case, TLA (USA) Inc.) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites. 

 

Why do we use cookies?  

We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below. 

The specific types of first and third party cookies served through our Websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):   

 

Analytics and customization cookies:  

 

These cookies collect information that is used either in aggregate form to help us understand how our Website are being used or how effective our marketing campaigns are, or to help us customize our Websites for you. 

 

■ Who serves these cookies:     

Cookie provider: Google Analytics    

  Website URL: https://google-analytics.com      

■ How to refuse: To refuse these cookies, please follow the instructions below under the heading "How can I control cookies?". Alternatively, please visit the relevant opt-out link below:      

Cookie provider: Google Analytics  

  Opt-out Link: Opt Out 

 

What about other tracking technologies, like web beacons? 

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.     

 

How can I control cookies?      

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. 

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.  

 

How often will you update this Cookie Policy? 

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.  

The date at the top of this Cookie Policy indicates when it was last updated.  

 

Where can I get further information?  

If you have any questions about our use of cookies or other technologies, please email us at privacy@octaive.com or by post to:

TLA (USA) Inc.

151 West 25th Street, 2nd Floor  

New York, NY 10001  

United States    

Phone: +1 (646) 586-2875