Privacy Policy for tlooto

1. Personal Information We Collect

A. Personal Information You Provide

1. Account Information: Collected when you create an account. This includes your name, contact details, account credentials, payment card information, and transaction history.
2. User Content: Includes personal information in inputs, file uploads, or feedback provided while using our Services.
3. Communication Information: Gathered when you communicate with us, including your name, contact details, and the contents of your messages.
4. Social Media Information: Collected from interactions on our social media pages (Instagram, Facebook, Medium, Twitter, YouTube, LinkedIn), including any contact details you provide. Additionally, aggregate social media activity data provided by these platforms.
5. Other Information You Provide: Information from participation in events or surveys, or information provided to establish your identity.

B. Personal Information We Receive Automatically

1. Log Data: Information automatically sent by your browser or device when using our Services, including your IP address, browser type and settings, date and time of requests, and interaction details with our Services.
2. Usage Data: Automatically collected information about your use of the Services, such as content viewed, features used, actions taken, time zone, country, access times, user agent, device type, and computer connection specifics.
3. Device Information: Includes the name of the device, operating system, device identifiers, and the browser used. The collected information may vary based on the device type and settings.
4. Cookies: Used to operate, administer, and improve our Services. Cookies are small data files sent to your browser. You have the option to accept, reject, or be notified about cookies. Refusing cookies may impact your use of our website or its features.
5. Analytics: We use various analytics tools that employ cookies to analyze user interactions with our Services, enhancing user experience.
6. Advertising Measurement (Meta Pixel and Conversions API): On tlooto.com we use the Meta Pixel of Meta Platforms, Inc. It sets cookies and sends Meta the pages you visit, sign-up, checkout and purchase events, and your IP address and browser information. When a payment is completed, we also send Meta the amount and currency with a hashed (SHA-256) email address and account ID, and the Meta cookies, IP address and user agent recorded when you opened checkout, so that Meta can measure and optimize our ads. We keep those browser identifiers for at most 90 days. We never send the content of your research, files or messages. If your browser sends a Do Not Track or Global Privacy Control signal, we do not load the pixel or send these events. You can also block cookies in your browser or manage ad personalization in your Meta account's Ad preferences. Questions: help@tlooto.com.
7. Advertising Measurement and Personalized Ads (Google Tag and Google Ads): On tlooto.com we use the Google tag of Google LLC (Google Analytics 4 linked to Google Ads). The tag sets cookies and sends Google the pages you visit, usage events such as button clicks and features used, sign-up, checkout-start and purchase events (including the purchase amount and currency), your IP address and browser information, and, when you are signed in, your tlooto account ID. We use this information to measure our ads and to show tlooto ads to people who have visited tlooto, on Google Search, Google Display Network sites and other Google ad placements (remarketing). We never send the content of your research, files or messages. You can block cookies in your browser or turn off ad personalization in Google My Ad Center (https://myadcenter.google.com). Questions: help@tlooto.com.
8. Google Customer Match (Hashed Member Email Addresses): To show tlooto ads to existing members on Google services, or to exclude them from our ads, we may normalize member email addresses, hash them with SHA-256 and upload them to Google Ads Customer Match. Google uses this data only to match it with Google accounts and deletes the data that does not match. If you do not want your email address to be used this way, contact help@tlooto.com and we will exclude it from the next upload.

2. How We Use Personal Information

A. Primary Uses

1. Service Provision and Maintenance: To provide, administer, maintain, and analyze the effectiveness of our Services.
2. Service Improvement and Research: To improve our Services, develop new programs and services, and conduct research.
3. Communication: To communicate with you, including sending information about our Services and events.
4. Security and Fraud Prevention: To prevent fraud, criminal activity, or misuse of our Services, and to protect the security of our IT systems, architecture, and networks.
5. Business Transfers: To support and facilitate business transfers.
6. Legal Compliance: To comply with legal obligations and processes, and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
7. Advertising and Marketing: To measure the performance of ads for tlooto services, to show personalized ads to past visitors and members, or to exclude members who already use tlooto from our ads.

B. Aggregated or De-Identified Information

1. Use of Non-Personally Identifiable Data: We may aggregate or de-identify Personal Information so it can no longer be used to identify you. This information is used to analyze the effectiveness of our Services, improve and add features to our Services, conduct research, and for similar purposes.
2. Sharing Aggregated Data: We may share such aggregated information with third parties, publish it, or make it generally available. This includes general user statistics and behaviors.

C. Use of Content in Service Improvement

1. Content Utilization: Content you provide may be used to improve our Services, such as to train the models that power services like tlooto.
2. Opt-Out Options: Instructions are provided on how you can opt out of our use of your Content for model training purposes.

3. Disclosure of Personal Information

A. Vendors and Service Providers

1. Purpose of Sharing: We may share Personal Information with vendors and service providers for business operational needs and specific services.
2. Types of Services and Functions: Includes hosting services, customer service, cloud services, email communication, web analytics, advertising platforms (Google, Meta) for ad measurement and ad targeting, and other IT-related services.
3. Condition of Use: These parties are authorized to access, process, or store Personal Information solely to perform their duties to us, according to our instructions.

B. Business Transfers

1. Circumstances of Sharing: In the event of strategic transactions such as reorganization, bankruptcy, receivership, or transition to another service provider.
2. Process and Transfer: Personal Information may be disclosed during the diligence process and transferred to a successor or affiliate as part of the transaction.

C. Legal Requirements

1. Compliance with Law: Personal Information may be shared with government authorities, industry peers, or third parties if legally required.
2. Protection and Defense: To protect and defend our rights or property, or in response to violations of our terms, policies, or laws.
3. Fraud Prevention and Safety: For detecting or preventing illegal activities and ensuring the safety and security of our products, employees, users, or the public.
4. Legal Liability: To protect against legal liability.

4. Your Rights

A. Statutory Rights

1. Access: Obtain access to your Personal Information and details about how it is processed.
2. Deletion: Request deletion of your Personal Information from our records.
3. Rectification: Rectify or update inaccurate or incomplete Personal Information.
4. Data Portability: Transfer your Personal Information to a third party.
5. Restriction: Limit how we process your Personal Information.
6. Consent Withdrawal: Withdraw consent for processing, where consent is the legal basis for processing.
7. Objection: Object to the processing of your Personal Information.
8. Complaints: Lodge a complaint with your local data protection authority.

B. Exercise of Rights

1. Via tlooto Account: Some of these rights can be exercised directly through your tlooto account.
2. Direct Requests: For rights that cannot be exercised through your account, please submit requests via privacy.tlooto.com or email to help@tlooto.com.

C. Note on Model Accuracy

1. Limitations of tlooto: Responses generated by tlooto are based on predicting likely word sequences and may not always be factually accurate.
2. Factual Inaccuracies: If tlooto outputs factually inaccurate information about you, you can submit a correction request through the mentioned channels.
3. Technical Constraints: Due to the complexity of our models, we may not always be able to correct inaccuracies. In such cases, you may request the removal of your Personal Information from tlooto’s outputs using a specific form.

D. Data Collected from the Internet

1. For exercising rights related to data we have collected from the internet to train our models, refer to the specific help center article provided.

5. Children: Policy on Children Under 13

1. Service Not for Children Under 13: Our Service is not intended for children under the age of 13.
2. No Collection of Children's Personal Information: tlooto does not knowingly collect Personal Information from children under 13.
3. Reporting Concerns: If you believe a child under 13 has provided us with Personal Information, please contact us at help@tlooto.com for investigation and potential deletion of the information.
4. Users Between 13 and 18: If you are over 13 but under 18, you must have permission from a parent or guardian to use our Services.

6. Links to Other Websites: Third Party Sites

1. Presence of External Links: Our Service may contain links to Third Party Sites, including social media platforms.
2. Privacy Policies of Third Party Sites: Information shared with Third Party Sites is governed by their privacy policies and terms, not by this Privacy Policy.
3. No Endorsement Implied: Providing links does not imply endorsement or review of these sites. Contact Third Party Sites directly for their privacy practices and policies.

7. Security and Retention

A. Security Measures

1. Protection of Personal Information: We implement reasonable technical, administrative, and organizational measures to protect Personal Information.
2. Limitations of Security: No internet or email transmission is completely secure. Caution is advised when transmitting information to us, especially via email.
3. Responsibility for Security Breaches: We are not responsible for circumventing any privacy settings or security measures on the Service or third-party websites.

B. Retention of Personal Information

1. Duration of Retention: Personal Information is retained only as long as necessary to provide our Service, for legitimate business purposes, or to comply with legal obligations.
2. Factors Influencing Retention Duration: The retention period depends on various factors, including the nature of the information, potential risks, processing purposes, and legal requirements.

8. International Users

A. Processing and Storage of Personal Information

1. International Data Processing: Your Personal Information will be processed and stored in the United States, and may be disclosed to service providers and affiliates in other jurisdictions.
2. Understanding and Acknowledgment: By using our Service, you acknowledge this international processing and storage of your Personal Information.

B. Legal Bases for Processing

1. Performance of a Contract: Processing of Account Information, Content, and Technical Information is necessary to provide and maintain our Services.
2. Legitimate Interests: Protecting our Services from abuse, fraud, or security risks, and in developing, improving, or promoting our Services, including training our models.
3. Consent: Specific processing activities may be based on your consent, which you can withdraw at any time.
4. Compliance with Legal Obligations: Using Personal Information to comply with laws or protect rights, safety, and property.

C. Data Transfers

1. Safeguards for International Transfers: Appropriate safeguards are used for transferring Personal Information outside of certain countries, pursuant to legally valid mechanisms.

D. Data Protection Officer

1. Contact: You can contact our data protection officer at help@tlooto.com for issues related to Personal Information processing.

9. Changes to the Privacy Policy

1. Periodic Updates: This Privacy Policy may be updated periodically.
2. Notification of Changes: Updated versions will be posted on this surface, or other types of notices will be provided as required by law.