Privacy Policy

Privacy Notice

PRIVACY POLICY

Last Revised: June 24, 2024

Tustin Media, Inc. (“Tustin Media” “we” or “us”) (“Tustin Media” “we,” “us,” or “our”), know that data privacy is very important to you. We have created this privacy policy (the “Privacy Policy”) to describe what kinds of personal information we may obtain and process through:

Our website (https://www.TustinMedia.com ) (the “Site”);

Our mobile application, which is accessible through tablets, smart phones, and other devices (the “App”);

Any other website, mobile application, or digital property that links to this Privacy Policy; and

When you interact with us in person, electronically, or any other way.

By accessing or using the Site, the App, or any other website, web application, or digital property that links to this Privacy Policy (collectively, the “Digital Properties”), you may access or use our technology platform (“Platform”), our products and services, and/or open an account (each, an “Account”) (collectively, with the Platform and Digital Properties, the “Services”).

By accepting this Privacy Policy, accessing and/or using any Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy. If you are accepting this Privacy Policy on behalf of your employer or another organization, you hereby certify that you are authorized to bind such party to the terms of this Privacy Policy. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy, then you may not access or use the Services.

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in the applicable Terms of Service or Terms of Use. BY ACCESSING AND/OR USING THE SERVICES, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THIS PRIVACY POLICY, INCLUDING OUR TERMS OF SERVICE AND/OR TERMS OF USE, AS APPLICABLE, WHICH ARE INCORPORATED HEREIN BY REFERENCE.

IMPORTANT NOTICE TO RESIDENTS OF CERTAIN U.S. STATES

California Residents: You may have additional rights regarding your personal information under the California Privacy Rights Act. Please review the CPRA Privacy Notice for further information.

Virginia Residents: You may have additional rights regarding your personal information under the Virginia Consumer Data Protection Act. Please review the VCDPA Privacy Notice for further information.

Nevada Residents: You may have additional rights regarding your personal information under the Nevada Revised Statutes. Please review Section IX of this Privacy Policy for further information.

This Privacy Policy will help you understand the following:

TABLE OF CONTENTS

I. INFORMATION WE COLLECT

  1. Contact Information
  2. Information You Provide
  3. Information Obtained Automatically From Your Online Activity
  4. Information Obtained From Other Sources
  5. Information Obtained From Third-Party Analytics Services
  6. Information Collected by or Through Third-Party Advertising Companies

II. INFORMATION USE AND SHARING

III. INFORMATION THAT IS NOT COVERED BY THIS PRIVACY POLICY

IV. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES

V. HOW WE PROTECT YOUR INFORMATION

VI. CHILDREN’S PRIVACY

VII. EXTERNAL WEBSITES AND THIRD PARTIES

VIII. DO NOT TRACK

IX. NOTICE TO NEVADA RESIDENTS

X. IMPORTANT NOTICE TO NON-U.S. RESIDENTS

XI. UPDATES TO THIS PRIVACY POLICY

XII. HOW TO CONTACT US

I. INFORMATION WE COLLECT

In the course of providing the Services and/or interacting with you, Tustin Media collects and/or receives the following types of information, which may include personal information.

1. Contact Information

We collect contact information through our Services, such as when you access content or features, contact us with comments or questions, or otherwise engage or interact with us including (i) name, address, email address, phone number, age, and any information provided in messages to us, and (ii) information used for the purpose of authenticating your identity and/or your Account (collectively, “Contact Information”). In addition to authentication, we use Contact Information to provide information about the Services, responding to your inquiries, sending you email alerts (including marketing emails), and/or providing the Services.

2. Information You Provide

Accounts: Tustin Media provides a variety of Services that may change from time to time. Certain Services may only be accessible to users that have registered for an Account with Tustin Media. During the registration process, Tustin Media may request your full name, email address. If you are approved for an Account, you may be required to enter into one or more additional agreements with Tustin Media and/or our Partner(s) (personally or on behalf of the applicable institution). Your application for an Account may be accepted or rejected at our (and/or our Partner(s)) discretion.

User Content. We also collect information you voluntarily submit when you upload or post User Content through the Services. For example, if you are signed into your Tumblr, Twitter, Facebook, or other social account and you “like” or “comment” on Tustin Media Content (such as the articles found on our blog) or other User Content, your username for the applicable social media account will be displayed and so available to the public. You agree that your username, likes, feedback, and any associated comments may become public information; we therefore urge you to exercise caution when deciding to disclose any Personal Information on the Site, the App or through the Services.

Other Information: You may voluntarily provide additional information to us by entering a contest, promotion, or sweepstakes sponsored by us, completing surveys for marketing, research, or other purposes, or contacting us for additional information (using forms on our Digital Properties, via email or otherwise). Tustin Media may collect additional information that you provide voluntarily through the Platform or Services, or when you otherwise engage with us, such as household income range, personal interests, and any of your product or services preferences.

Acknowledgement: By using the Services, you acknowledge and agree that personal information may be accessed, collected, or otherwise processed by our third party partners pursuant to their respective privacy policies. and that you expressly agree to the terms of such privacy policies. You hereby expressly grant us the right, power, and authority to access and transmit your information as reasonably necessary for the Partner(s) their services to you in connection with your use of our Services. You are responsible for ensuring the accuracy of all information you submit to us.

3. Information Obtained Automatically From Your Online Activity

When you access or use any of our Services, we may use browser cookies, pixels, web server logs, web beacons, and similar technologies (collectively, “Tracking Technologies”) to recognize you, save your preferences, customize your experience, and serve advertisements. The Tracking Technologies also automatically collect or receive certain standard technical information and other data (such as IP address, the URLs of sites you visit and use to access our Site, browser type and language, access times, operating system, mobile provider, mobile device, your ISP, traffic data, location data, logs and other communications data) sent by your computer, mobile device, tablet, or any other device over time on our Digital Properties, and track your online activity across third party websites, apps, and devices. We may use such information to better understand how users navigate our Digital Properties, analyze trends, administer the Digital Properties, prevent fraud, and gather broad demographic information. Tustin Media may also evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services.

We may enable advertisers and ad servers to promote third party products and/or services by placing advertisements on our Digital Properties. When you access or use any of the Services, advertising companies, analytics networks and providers, and other third parties may also use Tracking Technologies to monitor information related to served advertisements (to improve targeted advertising), collect information about your online activities over time on our Digital Properties and across different websites, apps, online services, digital properties and devices.

The data we or third parties collect automatically is typically statistical data that may not identify you personally; however, we or third parties may maintain, associate and/or combine it with personal information collected in other ways or received from third parties. We and third parties use this information to (i) personalize your experience with the Services, understand how you use the Services, maintain a persistent session, and improve and further develop our Services, and (ii) serve targeted and other advertising, and provide custom experiences, across other sites, apps, online services, digital properties, and devices.

Cookies (browser cookies), a commonly used Tracking Technology, consist of small packets of data that a website or device stores on browser, hard drive or device so that your device will “remember” information about your visit. In addition to collecting information, cookies are used to help us authenticate users, provide content of interest to you, analyze which features you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we or third parties may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. This Privacy Policy only covers the use of cookies and other Tracking Technologies by Tustin Media. Any use of cookies and other Tracking Technologies on our Digital Properties by third parties (and the data collected) is governed by their own privacy policies that Tustin Media does not control.

If you do not want cookies placed on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this. We and third parties may also use (i) flash cookies (local stored objects) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies; and (ii) web beacons (small electronic files, also referred to as clear gifs, pixel tags, and single-pixel gifs) to count users who have visited pages on our Digital Properties, or for other related statistics, such as recording the popularity of certain content and verifying system and server integrity. If you decide not to accept cookies or other Tracking Technologies, the Services may not function properly.

4. Information Obtained From Other Sources

Social Media: We maintain a presence on [insert names] and other social media and third-party sites, including our accounts, pages and related activities. We may collect personal information when you visit or use social media, including when you access our Services from social media. We will do so in accordance with the terms of use and privacy policies of those sites, apps and applicable law. For example, we may collect the information you shared on our social media pages through an application or form, which will have a link to this Privacy Policy. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about visitors’ use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. Overall, this information may be used to help us understand the types of visitors and users of our social media pages and use of the content. This Privacy Policy does not cover personal information collected by such third-party social media sites. For more information on their privacy and security practices please review the privacy policies and terms of use on their respective websites.

Inferences: We may collect or receive inferences, which are assumptions or extrapolations that have been drawn from your information to create a profile which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Acquired from Third Parties: We may purchase or receive information from third parties including information related to you. We may combine your information with such acquired information and use it to improve your experience, personalize our services and content, and/or for targeted advertising.

Text Messaging Program: Our Services may include text messaging programs (SMS and/or MMS) from time to time, which will require collection and use of your name, mobile phone number, and texting preferences (opt-ins and opt-outs). We will use this information to send you text messages and manage our text messaging program. Please note that your mobile phone carrier may collect data about your wireless device usage, and that its practices are governed by the mobile provider’s own policies. Our text messaging program is administered and operated by a third-party service provider (currently, SlickText) (the “SMS Provider”).

When you provide us with your mobile phone number, you agree that Tustin Media may send you text messages (including SMS and MMS) to that phone number. You will receive a confirmation text message, and you may need to reply as instructed to complete registration. We may send you up to 23 messages per month. Message and data rates apply. Reply STOP to cancel, HELP for help. You agree to receive a final text message confirming your opt-out. You may opt-out at any time by texting the word STOP to the number 36962. For help, send a text message with the keyword HELP to the number 36962. Texts may be sent through an automatic telephone dialing system. Consent is not required to purchase Tustin Media’s goods or services. You agree to notify us of any changes to your mobile number and update your account us to reflect this change. Your carrier may prohibit or restrict certain mobile features and certain mobile features may be incompatible with your carrier or mobile device. Contact your carrier with questions regarding these issues.

How do I sign up for these text messages? All you have to do is text Tustin Media to 36962. (Up to 23 messages a month, message and data rates may apply, and you can always text HELP for help & STOP to cancel.) When you opt-in to the service, we will send you an SMS message to confirm your signup.

If at any time you forget what keywords are supported, just text HELP to 36962. After you send the SMS message HELP to us, we will respond with instructions on how to use our service as well as how to unsubscribe.

How do I opt out of these text messages? You can cancel the SMS service at any time. Just text STOP to 36962. After you send the SMS message STOP to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.

Will I be charged for the text messages I receive? Tustin Media will never charge you for the text messages you receive however standard message and data rates may apply for any messages sent to you from us and to us from you. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. For all questions about the services provided through the number 36962, you can send an email to help@Tustin Media.com.

United States: Supported Wireless Carriers. We are able to deliver messages to the following mobile phone carriers: Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless).

Canada: Supported Wireless Carriers. Bell (including NorthernTel, Solo Mobile, and Telebec), Fido, MTS, Rogers, SaskTel, Telus (including Koodo Mobile and Public Mobile), Videotron, Virgin Mobile, and Wind.

***This service and the carriers are not liable for delayed or undelivered messages***

Subscribing and Unsubscribing. It is our policy, that just as a user must opt in to a text marketing list, they have the right to opt out of a particular text marketing list as well. When a user opts out of a text marketing list, they will no longer receive any texts unless they, themselves, re-subscribe.

5. Information Obtained From Third-Party Analytics Services

We use third-party analytics services (such as Google Analytics) to evaluate your access and use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to device and internet usage such as: the type of device, the advertising identifier, the operating system and version, carrier and network type; IP addresses (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device); browser type and language; referring and exit pages and URLs; date and time of access; the content viewed; the amount of time spent on particular pages; what features of the Services are used or visited; details of any purchases; click stream information; and precise geolocation data. These third-party analytics services use cookies and other Tracking Technologies to collect, analyze and provide us with the data and related analytics. By accessing or using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. The information used by such analytics services is generally at the aggregate level. Google may associate such data with visitation information collected from our Services.

We may add to or change these third-party analytics services from time to time. For more information on our analytics services, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics

6. Information Collected by or Through Third-Party Advertising Companies

We may share information about you with third parties that we have selected and approved for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect your information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

You may choose to opt-out of this type of tracking and sharing of information at any time by selecting the specific partners you wish to exclude from this website http://www.aboutads.info/choices. You can also limit this type of tracking through the Do Not Track functionality in your web browser and a “Limit Ad Tracking” setting on iOS devices or a setting to “Opt out of Interest-Based Ads” on Android.

II. INFORMATION USE AND SHARING

We may use and share your personal information as set forth below:

To open your Account, including for identity verification and other due diligence efforts;

To operate our business and provide the Services;

To allow you to participate in interactive features of our Services;

To monitor, support, analyze, customize, and improve the Services;

To communicate with you regarding the Services and your Accounts;

To provide you with a safe, smooth, efficient and customized experience;

To provide customer support you request with respect to the Services and your Accounts;

To troubleshoot problems and prevent potentially prohibited or illegal activities;

To tell you about and administer service updates, contests, sweepstakes, rewards and promotional offers based on your communication preferences;

To monitor and enforce our Terms of Use;

To communicate with you about third-party products and/or services you may be interested in;

To verify your eligibility to use the Services;

To fulfill your requests for information regarding new or improved products and services;

To engage in marketing, advertising, and tracking activities, targeted advertising, and to evaluate the efficacy of our efforts, provided that, where required under applicable law, we will obtain your prior opt-in consent to send electronic marketing communications and/or our newsletter;

To engage research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;

To protect the safety and security of our Services, the Accounts, and our business;

To our program participants under confidentiality agreement, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity;

To our promotional partners so they can offer you special products, services, discounts, tickets and other items.

To third-party contractors and service providers that provide services to us in the operation of our business and assistance with the Services, such as marketing and advertising companies, consulting service organizations, IT and cloud service providers, among others;

To process and disclose aggregated, anonymous, user statistics and other information to (i) affiliates, agents, business partners, and other third parties; (ii) describe the Services to current and prospective business partners;(iii) operate, maintain, manage, and improve the Services; and (iv) other third parties for lawful purposes;

To share with our parent company, subsidiaries, affiliates and/or other companies under common control with us;

To fulfill our legal and regulatory requirements;

To comply with applicable law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

To create aggregated and de-identified data (“De-identified Data”) and share such De-identified Data with third-party contractors and service providers that provide services to us in the operation of our business and assistance with the Services;

To assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your personal information and De-identified Data will be part of the transferred assets; and

Otherwise, with your consent.

We will take reasonable measures (e.g., by contract) to require that any party receiving any of your personal information from us, including for purposes of providing the Services, undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by applicable law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information. Additionally, certain services may be provided through independent third parties that are not affiliated with Tustin Media and may operate under their own privacy policies including as set forth in Section VII.

III. INFORMATION THAT IS NOT COVERED BY THIS PRIVACY POLICY

You may voluntarily disclose and/or share your information including, any personal information with other users of the Services or third parties that provide certain parts of the Services. None of the information you provide in the foregoing manner is protected by this Privacy Policy. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE TO OTHER USERS OF THE SERVICES OR THIRD PARTIES THAT PROVIDE CERTAIN PARTS OF THE SERVICES. ALL SUCH INFORMATION MAY BE SUBJECT TO THE PRIVACY POLICIES OF SUCH THIRD PARTIES AND WE HAVE NO CONTROL OVER THE PRIVACY POLICIES OF SUCH THIRD PARTIES. WE ARE ALSO NOT RESPONSIBLE FOR ANY USE OF YOUR INFORMATION MADE BY SUCH OTHER USERS AND THIRD PARTIES. WE ENCOURAGE YOU TO REVIEW THE PRIVACY POLICIES OF SUCH THIRD PARTIES OR ASK THEM ANY QUESTIONS YOU MAY HAVE BEFORE DISCLOSING AND/OR SHARING YOUR INFORMATION WITH THEM.

IV. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES

If the personal information we have for you changes, or if you no longer desire our Services, you may correct or update it by making the changes in your Account, or by contacting us under Section XII (“How to Contact Us”) of this Privacy Policy.

You cannot opt out of receiving transactional e-mails related to your Accounts. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” hyperlink located on the bottom of any of our marketing emails or by contacting us directly at founders@Tustin Media.com. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

The email messages we send you may contain code that enables our database to track your usage of the emails we send you; such usage includes whether the email was opened and what links (if any) were clicked.

V. HOW WE PROTECT YOUR INFORMATION

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Services may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

VI. CHILDREN’S PRIVACY

Our Services are only available to individuals aged 13 or older, and we do not knowingly collect personal information from any person under the age of 13. If an individual under the age of 13 has provided us with personal information, a parent or guardian of that child may contact us and request that such information be deleted, and we will endeavor to delete that information from our databases.

VII. EXTERNAL WEBSITES AND THIRD PARTIES

Unless explicitly stated otherwise, our Privacy Policy addresses only our use and disclosure of information we collect from and/or about you in your interactions with Tustin Media and the Services. If you choose to disclose information to third parties, the use and disclosure restrictions contained in this Privacy Policy will not apply, as we do not control the privacy policies of such third parties, nor are we subject to them.

The Services may also contain hyperlinks to third-party websites, apps or advertisements (“External Websites”) including, for example, opportunities to purchase third party products or services that are offered and provided by independent companies. If you click on a link for any External Site, you will be redirected to a third-party site. The information collected by such third parties or that you choose to provide, is governed by the third-party site’s privacy policy and practices. We have no control over the privacy policies or practices, the content, or the products and services, of any External Websites we provide or allow hyperlinks on our Services including but not limited to our business partners, advertisers, and sponsors. As such, we are not responsible for the content or the privacy policies of those External Websites. You should check the applicable third-party privacy policy and terms of use when visiting any External Websites.

VIII. DO NOT TRACK

We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

IX. NOTICE TO NEVADA RESIDENTS

We do not sell your personal information as defined under Nevada law. Nonetheless, if you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by completing this WebForm. We may request additional information to assist with locating your personal information in our records. If we are unable to do so, we may decline your request.

X. IMPORTANT NOTICE TO NON-U.S. RESIDENTS

The Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to access or use the Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy, and you do so at your own risk.

XI. UPDATES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing any of the Services after we change this Privacy Policy, you are deemed to have accepted such changes.

XII. HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, our privacy practices, please email us at help@TustinMedia.com, or write to us at:

Tustin Media, Inc.