Privacy Policy

This policy applies to information we collect:

• In email, text, and other electronic messages between you and Company.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Within the Website.

It does not apply to information collected by: (i) us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or (ii) any third party, including our affiliates, subsidiaries and customers, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Under certain laws, depending on your jurisdiction, Company may be considered a “controller” of certain personal data it has collected data because Company is responsible for determining how that personal data will be handled. This Privacy Policy is applicable to Company’s handling of personal data as a “controller.”

Further, this Privacy Policy also applies to personal data that Company receives in the context of providing its services to its customers. For many of the services that it offers, Company acts only as a “processor” (not a controller), which just means that Company handles the personal data solely pursuant to the relevant customer’s instructions, unless legally required to do otherwise. In instances where we act as a processor, not a controller, you should refer to any agreement or privacy policy you have entered into with the customer for whom we are processing data.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

The Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of the Website or provide any information about yourself to us, including your name, email address, telephone number, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [brandon@twelveNYC.com].

We collect several types of information from and about users of the Website, including personal data and personal information. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name, title, date of birth and gender.
• Contact Data includes mailing/billing address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, purchases or orders made by you (or by your employer on your behalf), your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data which is anonymized, de-identified or otherwise aggregated, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We use different methods to collect data from and about you including: (i) directly from you when you provide it to us; (ii) automatically as you navigate through the site; and (iii) from third parties, for example our business partners; each as described in greater detail below. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through the Website may include:

• Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to our service, including our newsletter, or requesting further services. We may also ask you for information when you report a problem with the Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• Types of content you view within the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or on our social media pages, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to the Website, including traffic data, logs, and other communication data and the resources that you access and use on the Website; and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Website.

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

• Cookies (or browser 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 the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website. Examples of cookies we may use on the Website include:
  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you while you are logged into the Website. This allows us to process your online transactions and requests, and to verify your identity, after you have logged in, as you move through our Website.
  • Persistent Cookies.  Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information or to maintain the security of the Website.
  • Third Party Cookies.  We also may engage third parties, including, without limitation, Google Analytics, to track and analyze non-personally identifiable Website data. We use the data collected by such third parties to help us administer and improve the quality of the Website and Company services and to analyze usage. We do not have access to or control over these third party cookies, nor does this Privacy Policy cover such third parties’ use of data.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages or other portions of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Information About You We May Receive from Third Parties

We may receive personal data about you from various third parties and public sources including:

• analytics providers such as Google;
• advertising networks such as Google, Bing, Facebook and Instagram; and
• Contact, financial and transaction data from providers of technical, payment and delivery services such as Stripe.
• Identity and contact data from publicly available sources.

Some content or applications, including advertisements, in the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

We, and our authorized third party service providers, may use information that we collect about you or that you provide to us, including any personal information:

• To present the Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To notify you about changes to the Website or any products or services we offer or provide through it or other products or services which may be of interest to you.
• To analyze trends and conduct research about improving the Website.
• To correlate information with other commercially available information to identify demographics and preferences to assist us in marketing efforts.
• To contact users for research, informational or marketing purposes.
• To learn about our users’ needs.
• To track traffic patterns and usage of the Website, including customizing our recommendations and promotions to you based on your information.
• To address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues. `
• To investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process.
• To comply with law, or based on our good-faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud and reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website or the public.
• To process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for processing credit cards, billing and collection.
• To allow you to participate in interactive features on the Website, if any.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you and to display advertisements to our advertisers' target audiences. For more information about steps you can take to control how your information is used, see Choices About How We Use and Disclose Your Information.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about the Website users is among the assets transferred.
• To third parties to market their products or services to you. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it. (e.g. sharing payment information with our third party payment processors)
• For any other purpose disclosed by us when you provide the information.
• With your consent.

Our uses and disclosures of your personal data are also subject to our contractual obligations.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements we have entered into with you, including any subscription agreements as well as for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The laws in many jurisdictions, particularly in the EU, require data controllers, such as Company, to inform you about the legal grounds that allow them to use or disclose your personal data. To the extent any such laws apply to Company’s handling, use or sharing of personal data, Company’s lawful basis of processing is as follows:

• Legitimate interests: We handle personal data because it furthers the legitimate interests of Company, its customers, business partners, and its third party vendors in business activities such as the ones listed below:
  • Fraud prevention and detection
  • By allowing us to enhance our customers’ cybersecurity and the cybersecurity of their online properties and other information technology assets
  • To protect our customers, their business activities and/or their customers
  • Providing customer service, namely collecting the data, analyzing it, and providing risk scores and related data to our customers to assist them with protecting the security of their online properties. Depending on the customer, this processing is also justified by its necessity for the performance of a task carried out in the public interest (i.e., cybersecurity, including the protection of personal data).
  • To improve our promotional and marketing initiatives
  • To analyze trends and conduct research about improving Company’s services and products
  • Identifying business and legal risks and conducting assessments of the same

We do not believe that our handling of data unduly impact your interests, rights, and freedoms.

• Contractual Obligations: In many instances, our handling of personal data is necessary to meet our contractual obligations, or because we are planning to enter into a contract.  
• Consent: When required by law, we will seek and obtain your consent. On other occasions, we may obtain your consent even when not required by law. For example, you may provide us with consent on our website to contact you for the purpose of providing more marketing information about our products and services or for other direct marketing. Sometimes, even if we do not seek your explicit consent, it may be permissible under the law for Company to infer your consent from the circumstances. Additionally if you have a contractual or business relationship with one of our customers, our customer may obtain your consent for the processing of personal data described in this Privacy Policy.
• Legal compliance: Disclosure and use of personal data may be required to ensure our compliance with our legal obligations under applicable laws.

Legal claims: Disclosure and use of personal data may be required to investigate claims (including claims of fraud), and/or legal actions, violations of law or agreements, including this Privacy Policy.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by [checking the relevant box located on the form on which we collect your data/OTHER OPT-OUT METHOD]. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [brandon@twelveNYC.com].
• Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt-out by [checking the relevant box located on the form on which we collect your data /[OTHER OPT-OUT METHOD] or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [brandon@twelveNYC.com] or clicking the “unsubscribe” link contained in the bottom of our marketing emails. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
• Targeted Advertising. We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving certain targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website found at http://optout.networkadvertising.org/ or a successor site.

You can ask us or third parties to stop sending you marketing messages at any time by (i) logging into the Sites and checking or unchecking relevant boxes to adjust your marketing preferences; (ii) by following the opt-out links on any marketing message sent to you; or (iii) by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.

You can review and change certain elements of the personal information provided to Company by logging into the Website and visiting your account profile page.

You may also send us an email at brandon@twelveNYC.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Under certain circumstances, and depending on your jurisdiction, you may have rights under data protection laws in relation to your personal data, which may include rights to the following:

1. Request access to your personal data.
2. Request correction of your personal data.
3. Request erasure of your personal data.
4. Object to processing of your personal data.
5. Request restriction of processing your personal data.
6. Request transfer of your personal data.
7. Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at brandon@twelveNYC.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we can neither guarantee the security of your personal information transmitted to the Website nor can we guarantee that such information will not become publicly available. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices.

If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using the Website or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.

This section applies to our processing of personal data that we collect through the Website and from our customers when we provide our services to them, as described above. We process personal data on the following legal bases: with your consent, to comply with laws applicable to us, and as necessary for our legitimate interests where those interests do not override your fundamental rights and freedoms related to data privacy. Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates, subcontractors, or clients maintain facilities.

Individuals that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

If you are a resident of the EEA or Switzerland, you are entitled to certain rights. Please note: In order to verify your identity, we may require you to provide us with personal data prior to accessing any records containing information about you. These rights include the ability:

• to request from us access to personal data held about you;
• to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
• to ask for data to be erased if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing; and
• to request that we restrict our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

To submit a request to exercise your rights, please contact us at brandon@twelveNYC.com. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Website and this privacy policy to check for any changes. Your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

brandon@twelveNYC.com

or write us at

45 Main St. Ste. 615
Brooklyn, NY 11201

Depending on where you reside you may have the right to make a compliant to your local supervisory authority for data protection issues.  We would, however, appreciate the chance to deal with your concerns first so please contact us.