Privacy Policy

Section 1 – Introduction:

ToriAvey.com (the “Website,” the “Site,” or “ToriAvey.com”) is owned and operated by Tori Avey, LLC (the “Company”, “us” or “we”). The purpose of this Privacy Policy is to explain how we collect, use, store, share, and protect the personal information of users (“you” or “your”) of the Website.

When we refer to “personal information” we mean information that identifies, or is reasonably capable of being directly or indirectly linked to, a particular individual or household, such as the individual’s name, postal address, email address, social media profile, and telephone number. Personal information includes “personal information” as defined by the California Consumer Privacy Act of 2018 (the “CCPA”) and “personal data” as defined by the European Union’s General Data Protection Regulation (the “GDPR”). When anonymous information is directly or indirectly associated with personal information, the resulting information is also treated as personal information. Personal information does not include aggregate information that we collect about the use of our Website or about a group or category of users from which individual identities or other personal information has been removed. Nor does it include usage information or device identifiers not connected to personal information.

Your use of the Website, and any personal information you provide via the Website or through other official contact with, us remains subject to the Terms of Service Agreement, which we encourage you to read carefully. Please note, this Privacy Policy does not apply to the privacy practices of third parties. We encourage you to review the privacy policies of any third-party application or website before providing any information to, or through, them.

Section 2 – Information We Collect:

Information You Provide. Personal information that we collect or have access to includes information you supply when you (i) contact us or submit online forms through the Website, (ii) sign up for or gift any subscriptions or memberships through the Website (“Memberships”), or (iii) participate in any online forums or communities offered through the Website or our social media accounts.

Information You Provide through the Website. In operating the Website, we may include registration opportunities, comment forms, online surveys, and other online forms that ask users to provide their names, email addresses, and other contact information, such as a mailing address. When you sign up for a Membership or purchase a Membership as a gift to someone else, we collect your name, email address, mailing address, and in the case of gifts, the name and email address of the recipient, as well as any information you choose to include in a personal message, and we collect credit card numbers and related information, such as the expiration date of the card and the billing address (“Credit Card Information”). When the Credit Card Information is submitted to us, such information is encrypted and is protected with SSL encryption software. We will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.

Information You Provide When You Participate in Online Forums, Including on Social Media and Other Third-Party Platforms. Our Website does not currently include any comment or chat features, but it does contain links to our social media pages on Facebook, Instagram, Twitter, and Pinterest, as well as our YouTube page. Additionally, our Membership includes access to a private Facebook community to connect with Tori Avey and special guests and other users of our Website. On Facebook and other websites and applications, users can send us messages and post public comments, which can include photos and other personal information users choose to provide. We have access to all personal information that you and other users choose to post on our social media pages. We encourage you to exercise caution and use discretion when posting through those forums and to maintain compliance with all applicable laws and codes of conduct. We also encourage you to review the privacy policies of those third-party applications, as this Privacy Policy does not apply to the privacy practices of third parties, such as Facebook, Instagram, Pinterest, Twitter, and YouTube.

Information Automatically Collected.

Advertising and Third-Party Tracking. Our Website is affiliated with CMI Marketing, Inc., d/b/a CafeMedia (“CafeMedia”) for the purposes of placing advertising on the Website, and CafeMedia collects and uses certain data for advertising purposes. As such, we allow CaféMedia to track the activities of users of our Website, what is known as third-party tracking. Third-party tracking refers to the practice by which a party other than the website visited tracks or assists in tracking the user’s visit to the website. Such tracking is often done through the use of “cookies.” CafeMedia may collect, directly or through its partnership with other service providers, the following information related to our Website users: email addresses (in hashed form), IP addresses, unique devise identifiers, and browser and operating system information. To learn more about CafeMedia’s collection and use of your personal information, click here: cafemedia.com/publisher-advertising-privacy-policy.
- Google Analytics. CafeMedia uses services provided by Google, Inc. such as Google Analytics, to help CafeMedia place interest-based advertisements on our Website. Google Analytics is a web analytics tools that helps website owners and operators understand how visitors engage with their websites. Google Analytics collects information anonymously, and uses cookies, and anonymized IP addresses, and reports website trends without identifying individual visitors. For more information related to Google’s analytics and advertising services go to: https://policies.google.com/technologies/partner-sites
Do Not Track Signals. We do not currently take steps to respond to browsers’ “Do Not Track” signals, as no uniform standard to respond to such signals has been developed at this time.

Section 3 – How We Use Information We Collect:

Personal Information. We may disclose your personal information, as well as non-personal information, such as aggregate user statistics, demographic information, and usage information, to companies and individuals who perform business functions on our behalf. Such functions may include hosting our Website, completing transactions, analyzing data, providing technical assistance, or providing content for our Website. All such parties are required to keep your personal information secure and only process it in accordance with our instructions. We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or the users of the Website, or (3) act under circumstances to protect the safety of the public or users of our Website. We, or our service providers, may use your personal information to do the following:

enhance our Website, Content, and offerings;
personalize your experience with our Website or Membership based on your individual usage habits;
provide content, services, products, or information you request, including processing your purchases and identifying you when you sign into an account;
provide notifications;
recommend recipes, articles, and other content we think would be of interest to you;
communicate with you about content, services, promotions, and events we offer;
solicit your feedback;
post testimonials;
improve our marketing and promotional efforts;
respond to your emails, submissions, questions, inquiries, requests, and comments;
monitor and analyze views and trends and otherwise measure the appeal and effectiveness of our Website and Memberships;
verify your account or monitor suspicious or fraudulent activity;
identify, fix, and troubleshoot bugs and service errors;
send you confirmations, updates, security alerts, and support-related messages; and
protect against, identify, investigate, and respond to misuse of our Website or Memberships, or other unlawful behavior.

With your consent, we may use your personal information for a specific purpose not listed above. We do not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Anonymous Information. We use anonymous information to analyze our Site traffic, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.

Use of Cookies. We may use cookies to deliver Content specific to your interests. Promotions or advertisements displayed on our Site may contain cookies. We do not have access to or control over information collected by outside advertisers on our Site.

Retention of Your Personal Information. We retain your personal information for so long as we have an ongoing legitimate business or legal need to do so. Additionally, you have the ability to unsubscribe from, or opt-out of, our subscriber list for our automated emails at any time, and to disable cookies and other tracking functions through your device or browser.

Section 4 – Security:

We strive to maintain adequate technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. ToriAvey.com has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration. We are not liable for unauthorized disclosure of information that occurs through no fault of our own. If we learn of a data breach that is likely to result in a high risk to your rights and freedoms, we will immediately notify you of such data breach and inform you of (a) the nature of the data breach, (b) the point of contact regarding the data breach, (c) the likely consequences of the data breach, and (d) the measures being taken to address the breach and mitigate its possible risks.

Section 5 – Accuracy of Your Information:

Although we work to ensure that the information we hold about you is accurate and up-to-date, unless we receive an indication otherwise, we can only assume that the information you provide to us is accurate. If you inform us that any of your information processed through our Website or App or email marketing is incorrect, or if we learn that any such information is incorrect, we will work to promptly correct, or if appropriate, erase, such information.

Section 6 – Your California Privacy Rights and Notice at Collection:

This portion of the Privacy Policy is provided under California law, including the California Consumer Privacy Act of 2018 (“CCPA”), and supplements this Privacy Policy by providing certain disclosures to California residents and explaining the privacy rights of California residents.

Categories of Personal Information Collected and Disclosed. In the preceding 12 months, we have collected the following categories of personal information and shared them with the following categories of third parties:

Identifier, such as, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf
- Business partners, such as when we partner with a third party to offer products or services on a co-branded basis
- Advertisers and marketing-related service providers

Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80I), and overlaps with other categories listed here.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf

Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf
- Business partners, such as when we partner with a third party to offer products or services on a co-branded basis
- Advertisers and marketing-related service providers
- Social media platforms

Commercial information, including purchases and engagement with the Website, Membership, and content.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf
- Business partners, such as when we partner with a third party to offer products or services on a co-branded basis
- Advertisers and marketing-related service providers
- Social media platforms

Internet activity and network activity, including your interactions with the Website, Membership, or content and what led you to the Website or to purchase a Membership.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf
- Business partners, such as when we partner with a third party to offer products or services on a co-branded basis
- Advertisers and marketing-related service providers
- Social media platforms

Sensory information, such as pictures posted on our Website.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf

Geolocation data provided through location enabled services such as WiFi and GPS.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf
- Business partners, such as when we partner with a third party to offer products or services on a co-branded basis
- Advertisers and marketing-related service providers
- Social media platforms

Inferences, including information about your interests, preferences, and favorites.
Parties with whom we disclose this category of personal information:

- Service providers that perform services or handle transactions on our behalf
- Business partners, such as when we partner with a third party to offer products or services on a co-branded basis
- Advertisers and marketing-related service providers
- Social media platforms

Additional Information, that you choose to share with us through our Website or on social media platforms.
Parties with whom we disclose this category of personal information:

- Service providers that perform services on our behalf
- Social media platforms
- With other users – when you share your personal information or otherwise interact in public areas, such as third-party social media platforms, with other users, such information may be viewed by all users and might be shared by other users.

Categories of Sources of Personal Information. In the preceding 12 months we have collected personal information from the following categories of sources:

Directly from you
From cookies and similar technologies
From third-party sites or apps, content distribution channels, and platforms
From third-party service providers, data suppliers, and business partners
From social media platforms and similar services
From third-party payment processors
From internet service providers
From operating systems and platforms

Business or Commercial Purposes for Collecting or Sharing Personal Information. See Section 3 – How We Use Information We Collect above for the business or commercial purposes for which we collect or share personal information.

Sale of Personal Information. In the preceding 12 months, we have not sold our users’ personal information. However, the term “sale” is defined broadly under the CCPA. As explained above, we do share with our service providers personal information that is necessary for such service provider to perform a business purpose. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us (contact information below). To our knowledge, we do not sell the personal information of individuals under 16 years old.

Notice of California Residents’ Rights. If you are a resident of California, you have the following rights under the CCPA with respect to your personal information:

The right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions.
- We may deny your deletion request if retaining the information is necessary for us or our service provider to: complete the transaction for which the personal information is collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech or ensure the right of another user to exercise his or her free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with applicable laws; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it.
The right to opt-out of the sale of your personal information to third parties. We do not sell the personal information of users of our Website.However, the term “sale” is defined broadly under the CCPA. We do share with our service providers personal information that is necessary for such service provider to perform a business purpose. This Privacy Policy describes the limited circumstances in which we share your personal information with third parties. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us as provided below. If, in the future, we do sell users’ personal information to a third party, we will provide users with the opt-out and opt-in rights required under the CCPA.
The right to request that we provide you with information regarding the processing of your personal information over the preceding 12 months, including the categories of personal information we have collected about you, specific pieces of personal information we have collected about you, sources from which it was collected, categories of personal information disclosed, the business or commercial purpose for collecting or disclosing personal information, and categories of third parties with whom your personal information is shared.
The right to request that we disclose to you the categories and specific pieces of personal information that we have collected in the preceding 12 months.
The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred under the CCPA.Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or benefits, or imposing penalties, provide you a different level or quality of goods or services, or suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services, based on your exercise of your rights under the CCPA. If we do choose to offer you financial incentives permitted under the CCPA that result in different price rates, or quality levels, such CCPA-permitted financial incentives will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in any financial incentive program requires your consent, which you may revoke at any time.

To request information regarding our processing of your personal information or request that we delete personal information about you that we have collected, you must submit a verifiable consumer request to us via mail, email, telephone or facsimile addressed to us at the address below.

Tori Avey LLC
c/o WB Mandell Group
8447 Wilshire Blvd. Ste. 204
Beverly Hills, CA 90211
(800) 407-1568
info@toriavey.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request twice within a twelve-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Thus, your verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person.

Describe your request in sufficient detail that allows us to properly understand, evaluate, and respond to your request.

We will acknowledge receipt of your request and advise you on how long we expect it will take to respond if we are able to verify your identity. We will work to process your request within 45 days pursuant to the CCPA. If we need additional time in order to process your request, we will provide you with an explanation for the delay. If we are unable to honor your request, we will advise you of this fact and provide the reason why.

We will not provide social security numbers, driver’s license numbers, account passwords or security questions and answers, or any specific pieces of information that could lead to unauthorized access, result in identity theft, fraud, or impose an unreasonable risk to data or systems and network security.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will inform you of the reason for this decision and provide a cost estimate before completing your request.

Section 7 – UK and EU Residents’ Rights:

If you are located in the European Economic Area or the United Kingdom, you have the rights outlined below with respect to your personal information. When we use the term “processing” or “processor” this refers to the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, use, transmission, dissemination, combination, erasure, or destruction of information.

Right to Information Regarding the Processing of Your Personal Information: You have the right to obtain the following information:

confirmation of whether and where we are processing your personal information;
information about the purpose of the processing of your personal information;
information about the categories of personal information being processed;
information about the existence of, and an explanation of the logic involved in, any automated processing of your personal information that has a significant effect on you;
information about the categories of recipients with whom your personal information may be shared; and
information about the period for which your personal information will be stored or the criteria used to determine that period.

This Privacy Policy is intended to provide much of the information listed above.

Right to Access to Your Personal Information: You may request a copy of your personal information that we, or our third-party processors, collect and maintain. Similarly, you have the right to, when technically feasible, have your personal information transferred to another entity to determine the purpose and means of processing your personal information.

Right to Have Errors Corrected: You have the right to rectification of inaccurate personal information. If you notify us that any of your personal information is inaccurate or incomplete, we have the responsibility to, either directly or through our third-party processors, ensure that such personal information is erased or corrected.

Right to Have Personal Information Erased or Processing Restricted: You have the right to have your personal information erased when (i) the personal information is no longer needed for its original purpose and no new lawful purpose exists; (ii) the personal information is being processed based solely on your consent and you withdraw your consent; or (iii) the personal information is being processed unlawfully. Similarly, you have the right to limit our use of your personal information when (i) the personal information is no longer needed for its original purpose, but we still need to maintain the personal information to establish, exercise, or defend legal rights; (ii) the personal information is being processed unlawfully; or (iii) the accuracy of the personal information is contested, but then our use of the personal information is restricted for only so long as it takes to verify the accuracy of the personal information.

Right to Object to Processing of Your Personal Information: You have the right to object to our processing of your personal information if the basis for that processing is (a) public interest; or (b) our own legitimate interests in doing so. Additionally, you have the right to object to the processing of your personal information for the purpose of direct marketing or statistical purposes.

Right to Lodge a Complaint with a Supervising Authority: You have the right to lodge a complaint concerning the processing of your personal information with your country’s independent public authority designated to act as its data protection “supervising authority” under the GDPR.

Right to Withdraw Consent to the Processing of Your Personal Information: You have the right to refuse to consent to, and to withdraw your consent to, the processing of your personal information. To the extent we rely on your consent to collect and store your information, when you withdraw such consent we must cease collection and retention of such information. Note, however, we do not require your consent to collect or otherwise process your personal information if (a) such information is not personal information or (b) such information is personal information and we have another lawful basis for processing the information (for instance, processing of such information is necessary for the purpose of a legitimate interest of ours that is not overridden by your interests or fundamental rights and freedoms).

Responses to your requests to us regarding your personal information will be provided free of charge (including copies of materials), except that we may charge a reasonable fee for any repetitive requests, manifestly unfounded or excessive requests, or further copies. Similarly, we may refuse to act upon requests that are manifestly unfounded or excessive.

Lawful Basis for Processing Personal Information. We process personal information of users of our Website and Content, whether directly or through third-party processors, as needed for purposes of our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of our Website users. Our legitimate interests include responding to communications initiated by you, performing services, informing you of relevant content or changes to our Website or Membership offerings, and protecting the security of the Website and your personal information. In some instances, we might request your consent to process your personal information for a particular purpose and in such instances the lawful basis for such processing is your consent.

Section 8 – Notice to Non-U.S. Residents:

Our Website and servers are 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, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Website, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States.

Section 9 – Miscellaneous:

Disputes. If you have any concerns or claims with respect to our data handling practices, please contact us first. We will investigate and attempt to resolve any complaints and disputes regarding our use or disclosure of your personal information. If your complaint or dispute cannot be resolved through our internal process, or if we do not adequately respond to your question, you agree to resolve your dispute through arbitration. If arbitration is necessary, it will be conducted by telephone and email, and if it must be done in person, it will be conducted in Los Angeles, California. The arbitration will be conducted by one arbitrator member of JAMS, and under the rules of commercial arbitration of JAMS or as agreed between you and the Company. Both parties will bear equally the cost of arbitration (exclusive of legal fees and expenses). All decisions of the arbitrator will be final and binding on both parties and enforceable in any court of competent jurisdiction. For additional information you may contact www.jamsadr.com.

Limitation of Liability. We exercise reasonable efforts to safeguard the security and confidentiality of your personal information; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. We will not be liable for unauthorized disclosure of personal information that occurs through no fault of our own including, but not limited to, errors in transmission, access to your account by anyone, use of your credentials (email, username, password) by a third party, your failure to comply with your security obligations, and the unauthorized acts of our employees.

Third Party Websites.ToriAvey.com may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

Children Under 16. We care about protecting the privacy of children. We won’t knowingly allow anyone under 16 to provide us any personally identifying information. Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else. If you’re under 16, please do not provide us with any personally identifying information (such as your name, your email address or your phone number). We have designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”). You may read more about COPPA at http://www.coppa.org. If you become aware that your child, a minor, has provided us with personal information without your consent, you should contact us immediately.

Website Provider – Host Information. Our Website is hosted by:

BigScoots, INC.
Tel: 877-570-3396

You can find the BigScoots Privacy Policy here.

Contacting Us. If you have any questions about this policy, or our practices related to this site, contact us here.

Updates and Changes. We may modify this Privacy Policy from time to time. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices. If we have your email address, we might notify you of any changes to our Privacy Policy when they occur.

This policy was last updated on February 12, 2021.

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