Privacy Policy

Effective Date: June 28, 2021

Last Updated: June 28, 2021

Tovera, Inc. (referred to herein as “Tovera”, “we”, “our”, or “us”) and its affiliates, recognizes the importance of protecting the Personal Information we may collect from visitors, users and any other individual or entity (“Users”, “you”, or “your”). This Privacy Policy applies to data collection and privacy practices of Tovera and when we collect Personal Information through your use of the website, www.tovera.com, and other Tovera-related sites, software and applications accessible on or by any top-level Tovera domain owned by us (each, a “Site” and collectively the “Sites”), through our social media pages that we control, and through email messages that we may send to you (collectively, the “Services”).

This Privacy Policy describes how we use Personal Information, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.

Specifically, our Privacy Policy covers the following topics:

  1. When This Privacy Policy Applies
  2. Website Terms of Use
  3. Information We Collect
  4. How We Use Information We Collect
  5. Our Legal Basis for Collecting Personal Information
  6. Cookies and Similar Technologies
  7. Your Failure to Provide Personal Information
  8. Our Retention of Your Personal Information
  9. Sharing Personal Information
  10. International Transfer
  11. Your Privacy Choices
    a. European Users’ Rights with Respect to Personal Information
  12. Links to Other Websites
  13. How We Protect Personal Information
  14. Children’s Privacy
  15. Direct Marketing and “Do Not Track” Signals
  16. Privacy Policy Modifications
  17. Contact Us

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

If you have any questions or comments about this Privacy Policy, please submit a request to [email protected].

When this Privacy Policy Applies

Our Privacy Policy applies to all of the Services offered by Tovera, including its affiliates, to Users. Our Privacy Policy is intended to describe our data collection practices and applies unless there is a specific country privacy policy which applies to you. However, because the data protection and privacy laws in some jurisdictions where our Services are located may restrict our data collection and processing practices, our practices may be more restrictive subject to local laws.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Sites or Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Website Terms of Use

By accessing or using the Sites in any manner, you also agree to be bound by Tovera’s Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal information, to provide better Services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata.

You may choose to provide us with Personal Information about yourself, including your name, email, and phone number, when you complete forms on our website, such as when you request information about our services.

  • Website Visitors

You may choose to provide us with Personal Information about yourself, including your name, organization name, title, phone number and email address by completing forms on our website. You may also provide us with Personal Information about yourself when you report a problem or have a question about our services.

When you visit our website, we collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, when you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location.

  • Customers

We may collect the following Personal Information about you when you use our Services: your name and email address. Tovera may also collect your credit card information and billing address when you provide Tovera with such information, such as when you buy products on our Sites; however your payment card information is passed securely to our payment card processor and is not stored by Tovera.

If you provide us or our service providers with any Personal Information relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy. If you believe that your Personal Information has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Information, please contact us by using the information set out in the “How to Contact Us” section below.

How We Use Information We Collect

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

  • Providing services, including to:
    • Register, create, and maintain your account;
    • Allow you to purchase products online;
    • Communicate with you regarding your account or any Services you use;
    • Improve the convenience and functionality of our Site;
  • Manage our business and protect ourselves, you, other persons, and the Services.
  • Provide a personalized experience and implement your preferences.
  • Better understand our customers and how they use and interact with the Services.
  • Market to you and provide personalized services, offers, and promotions on our Sites
  • Comply with our policies and obligations, including, but not limited to, disclosures and responses in response to any requests from law enforcement authorities and/or regulators in accordance with any applicable law, rule, regulation, judicial or governmental order, regulatory authority of competent jurisdiction, discovery request, advice of counsel or similar legal process.
  • Resolve disputes, collect fees, or troubleshoot problems.
  • Provide customer service to you or otherwise communicate with you.

We and our service providers may use IP addresses to understand the locations from which our Users and visitors are accessing the Services. Except where prohibited by applicable law or regulation, we may combine information collected through one source with information obtained through other resources. We also may supplement the information we collect with information obtained from third parties. We will treat any information that we combine with your personal information as Personal Information pursuant to this Privacy Policy.

We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by Tovera. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations.

To the extent we rely on consent for the processing of your Personal Information, we will seek such consent at the time we collect your Personal Information. We may also use the Personal Information we obtain about you in other ways for which we provide specific notice at the time of collection.

Our Legal Basis for Collecting Personal Information

Whenever we collect Personal Information from you, we may do so on the following legal bases:

  1. Your consent to such collection and use;
  2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
  3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
    • Intra-organization transfers for administrative purposes;
    • Product development and enhancement, where the processing enables Tovera to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
    • Fraud detection and prevention;
    • Enhancement of our cybersecurity, including improving the security of our network and information systems; and
    • General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our Sites or Services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google Analytics, Plausible, Cloudflare, and similar partners.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.

Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

Your Failure to Provide Personal Information

Your provision of Personal Information is required in order to use certain Services and programs. In some instances, if you fail to provide such Personal Information, you may not be able to access and use our Services, or parts of our Services.

Our Retention of Your Personal Information

We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal and contractual requirements (such as applicable statutes of limitation).

Sharing Personal Information

Insofar as reasonably necessary for us in delivering our products and services to you and for the purposes set out in this Privacy Policy, we may share your personal information with the below parties. The specific kind of information we share will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent.

  • Our business partners and third parties involved in the delivery of our products and services to you – including those involved in a sale of all or part of our business operations or assets and those for business, operational and general administration;
  • Our marketing and advertisement partners;
  • Third party services providers which process data (including personal information) for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures;
  • Our agents, advisors, consultants, other third party suppliers and/or service providers to assist us to operate effectively and provide you with the best experiences with our services;
  • Other third parties when we have your consent or are otherwise permitted by law to do so.

We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Tovera if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Fulfill any purpose for which you provide it;
  • Meet any applicable law, regulation, legal process or enforceable governmental request;
  • Enforce applicable Terms of Use, including investigation of potential violations;
  • Detect, prevent, or otherwise address fraud, security or technical issues;
  • Protect against harm to the rights, property, assets or safety of Tovera, our Users or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
  • Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of Tovera’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Tovera about its visitors and users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy;
  • For any other purpose disclosed when you provide the information; and,
  • When we obtain your consent to do so.

We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

International Transfer

The Personal Information we collect is stored and/or processed where we or our partners, affiliates, and third-party providers maintain facilities. Please be aware that the locations to which we store, process, or transfer your Personal Information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your Personal Information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred Personal Information in accordance with this privacy policy.

Your Privacy Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to visit our Site or use our Services, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

  • European Users’ Rights With Respect to Personal Information

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Information you have shared with us when we are the data controller. If you are resident in the European Economic Area, you may have the following rights:

  1. The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
  2. The right of access. You have the right to request a copy of your Personal Information which we hold about you.
  3. The right of correction: You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
  4. The right to be forgotten: You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
  5. The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
  6. The right to data portability: You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers / IT environment to another service provider’s servers / IT environment.
  7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
  8. The right to lodge a complaint with a supervisory authority.

You can make these requests by emailing us at [email protected] or by contacting us at the contact information below. We will consider your request in accordance with applicable laws.

  • Changing or Deleting Your Personal Information

You may update or correct information about yourself by emailing us at [email protected]. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

We may contact you to request that you update your Personal Information on a regular basis to ensure its integrity for the purposes of ongoing data management.

  • Our Opt-in/Opt-out Policy

By providing an email address on the Tovera Sites, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

  1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
  2. At any time, you can contact us through [email protected] or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

Links to Other Websites

The Sites may contain links to webpages operated by parties other than Tovera. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Tovera strongly recommends that each User review the third party’s terms and policies.

If you have any questions about the privacy practices of other websites, you should contact the relevant parties controlling these websites for more information.

How We Protect Personal Information

Tovera maintains administrative, technical and physical safeguards designed to protect the user's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.

Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Information or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.

For your own privacy protection, we urge you to keep all passwords confidential. We also recommend that you do not include sensitive information such as passwords, social security numbers or payment information, in any emails that you send to us. If you become aware of any breach of the terms of this Privacy Policy or of the security of the Services, please notify us by email at [email protected].

Children’s Privacy

The Sites and Services are not designed or intended to be used by anyone under the age of 13. If you are under the age of 13, do not use the Services, or make purchases via the Services, use any interactive features of the Services, or post any Personal Information to our Sites or submit any Personal Information via the Services. We do not knowingly or intentionally gather Personal information about children who are under the age of 13. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13 in the applicable jurisdiction, please contact us [email protected]. If we learn that we have inadvertently collected the Personal Information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.

Direct Marketing and “Do Not Track” Signals

Tovera does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to [email protected] with the subject heading “California Privacy Rights,” or (b) a letter addressed to Tovera, Inc. PO Box 1113, Lake Geneva, WI 53147. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

Privacy Policy Modifications

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

How to Contact Us

If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us:

Via e-mail: [email protected]

By writing to us:

Tovera, Inc.Attn: Privacy Policy InquiryPO Box 1113Lake Geneva, WI 53147