Last Updated: December 5th, 2022
- The Information We Collect
- How We Collect This Information
- How We Use This Information
- How We Share This Information
- How We Safeguard the Information We Collect
- Our Retention of Data
- Accessing and Updating Your Information
- Your Choices
- Advisory Regarding Participation by Children and Teens
- Relationship to Terms of Service; Incorporation of Terms of Service
- Notice of Privacy Rights to California Residents
- Notice of International Data Transfers
- Notice of Privacy Rights to Virginia Residents
- Third Party Sites
- Contact Us
2. The Information We Collect
Our Platform gives us the opportunity to communicate with people interested in Tim’s blog, podcasts, books, TV shows, and his other activities and interests. The Platform also provides you with opportunities to participate in exchanges on these topics and to receive additional information on all of the above. To provide these Services, and to otherwise conduct our business via the Platform, we rely on information provided by and collected from our users. This information consists of the following:
2.1 Personal Information. We collect certain information that identifies you as an individual (collectively, “Personal Information”). The Personal Information we collect may include the following:
- Your name,
- Your email address,
- Your social media handle (e.g., if you engage with us on social media), and
- Your billing and/or shipping address and payment card information, which is collected and processed by our third-party payment processor. We do not have access to your full payment card information.
2.2 Automatically Collected Technical and Device-Related Information. We also collect technical and device-related information that identifies or may reasonably be used to identify a particular user device (collectively, “Automatically Collected Information”). Automatically Collected Information is typically collected automatically by technical means, and for purposes of our Platform, consists of the following:
- Device identifiers, such as cookies;
- Device information, such as hardware and software settings;
- IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
- Tracking information that we collect, or that third parties collect.
2.3 Anonymous Information. Our Platform also collects, processes, and/or uses information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or perturb the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information about how the Website is used.
2.4 Blockchain Information. As part of the Services, we process certain personal data in a blockchain data record. This means that such personal data is stored in an immutable blockchain as part of a database called a distributed ledger. Anything stored in a ledger as part of the blockchain (“Blockchain Information”) may not be changed or deleted. Blockchain Information includes, but is not limited to, (i) the public address of any blockchain-compatible digital or cryptocurrency wallet that you connect to our Services (“Wallet”); (ii) any blockchain-based or Web3 domain names (e.g., a domain name registered with the Ethereum Name Service) associated with the Wallet; and (iii) corresponding data relating to the minting, purchase, sale, transfer, and any other transaction involving non-fungible tokens (NFTs) or cryptocurrency, including the purchase price, date, time, and location of the transactions. We may use pseudonymization to reduce the risk to individuals whose personal data is processed in the blockchain. Please carefully review how the use of blockchain with our Service may limit the exercise of certain of your rights regarding personal data in Section 13 (Notice Of Privacy Rights To California Residents) below.
To the extent Automatically Collected Information, Anonymous Information, or Blockchain Information constitutes personal information under applicable law, we will treat such information as Personal Information.
3. How We Collect This Information
We collect the above information through the following means and technologies:
3.1 Registration. In order to provide you with the Services, we need to collect Personal Information consisting of your name and email address. Accordingly, when you register to receive the Services, you provide this Personal Information.
3.2 Payments. When you order certain Services through our Website, we will require you to submit your payment information via our third-party payment processor. The payment information our processor collects may include your credit or debit card number or your bank account number, the expiration date of your credit or debit card, purchase amount, date of purchase, and payment method. Our processor may also collect certain Personal Information from you, such as your name, billing address, and, if applicable, shipping address. We do not have access to full payment card numbers or bank account numbers. For more information on our privacy practices with respect to our service providers, please refer to Section 5.2 (Our Service Providers).
3.3 User-Generated Content. We give you the ability through the Platform to engage with Tim and others in public exchanges, and these include opportunities for you to provide comments, reviews, recommendations, and other input via the Platform (collectively, “User-Generated Content” or “UGC”). Please understand that, if you include Personal Information in User-Generated Content, others will be able to read, collect, re-publish, and otherwise freely use the information. We are not responsible for Personal Information you decide to include in UGC. For example, we do not assume any obligation or responsibility to take down, remove, or edit User-Generated Content, except as required by applicable law, although we reserve the right to do so in our discretion. If you include in your User-Generated Content any Personal Information relating to others, you represent that you have full permission and authority to do so.
3.4 Contests, Special Offers, and Surveys. On occasion, we will provide you with the opportunity to participate in contests, receive a special offer, or provide us with feedback via a survey. To make these Services available to you, we will use the email address and name you provided us when you registered.
3.5 Beacons and Tags. The Platform may use certain data collection technologies that rely on (i) beacons, (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Platform have been visited or to measure the effectiveness of searches that users perform on our Platform. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Automatically Collected Information and, in certain instances, Personal Information.
3.6 Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Platform, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Platform, as well as the presence of any software that our Platform may require to operate with your device or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Automatically Collected Information.
3.7 Cookies. A cookie is a small amount of data which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies; however, you may need to enable cookies on your web browser if you wish to access certain personalized features of our Services. Cookies are a form of Automatically Collected Information. Please visit http://www.allaboutcookies.org/ and https://cookies.insites.com/disable-cookies/ for more information on how you can disable some or all cookies.
3.8 Click-Throughs. We may send email messages or display links that use a “click-through URL” linked to our Platform or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Automatically Collected Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.
3.9 Advertising Technology. The Services may include use of third-party advertising cookies or other identifiers on your device, and may use Anonymous Information about your visit to our Platform or applicable Automatically Collected Information.
4. How We Use This Information
We use the information we collect for some or all of the following:
- To provide you with the Services you request and, specifically, to allow Tim to send you email with information, for example, about his activities, recommendations, interviews, podcasts, books, TV shows, and news, and to allow you to receive Tim’s podcasts;
- To process payments you make with respect to our Services;
- To conduct fraud monitoring, prevention, and detection activities;
- To allow you to participate in contests, special offers, and surveys;
- To allow you to post User-Generated Content;
- To respond to your inquiries;
- To customize your visit to and use of the Platform;
- To determine which services and content (including marketing content) might interest you;
- To inform you of products and services that we think (or our marketing partners think) would be appealing to you, whether the goods or services are provided by us or by others and whether the goods or services are available via our Platform or via some other channel (including channels operated by third parties); this includes information in the form of recommendations and endorsements that Tim might provide;
- To track access to and use of our Platform and conduct data and other analyses, including anonymization and aggregation of Personal Information;
- To perform internal administration, auditing, operation, and troubleshooting for our Platform;
- To engage in the activities specified in Section 5 (How We Share This Information);
- To engage in personalized advertising;
- To evaluate and improve our Platform and our communications and to develop and test new services and content; and
- To comply with applicable law.
5. How We Share This Information
We value your privacy, and we share the information we collect only in the manner set out below.
5.2 Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Platform, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personal Information, Automatically Collected Information, and Anonymous Information as applicable. The following are examples:
- We use service providers (a) to fulfill your orders (where applicable), (b) to provide customer service (where applicable), (c) to process and distribute email, including Tim’s email newsletter, (d) to process and display User-Generated Content; and (e) to manage promotions, special offers, and similar activities. These service providers generally require access to your Personal Information in order to perform these services.
- We use analytics service providers to assist us in understanding and using Automatically Collected Information. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
- We may use service providers to anonymize and aggregate Personal Information in order to generate Anonymous Information.
- We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Automatically Collected Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Platform.
We require our service providers to contractually commit to protect the privacy and security of the Personal Information they process on our behalf.
5.3 Third Party Advertising. We may share Automatically Collected Information and Anonymous Information with third parties for their marketing purposes and activities. These marketing activities may take place on our Platform or via online services, mobile apps, traditional channels, and other methods independent of our Platform. These activities may involve a third party placing its cookies, beacons, and/or tags on our Platform in the manner specified in Section 3.5 (Beacons and Tags) and 3.7 (Cookies).
In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services.
As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“interest-based advertising”).
We also use audience matching services (which is a type of interest-based advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate Facebook Custom Audiences on our Service and may disclose your hashed email address to Facebook as part of our use of Facebook Custom Audiences.
For further information on your rights and choices regarding analytics, interest-based advertising, and Matched Ads, please see the “Your Choices” and “Notice Of Privacy Rights To California Residents” sections.
5.4 Questions of Harm; Legal Process. We may disclose your Personal Information and Automatically Collected Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary:
- To comply with legal process;
- To protect and defend our rights and property, including the Platform and associated content;
- To protect against fraud, misuse, or unauthorized use of our Services;
- To protect the personal safety or property of Platform users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
- To cooperate with public and government authorities, including, where required, authorities outside your jurisdiction.
While you are not able to opt out of this use of information, we will take reasonable steps to limit such use and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, where required under applicable law, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.
6. How We Safeguard the Information We Collect
We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
7. Our Retention of Data
We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (a) the duration of our relationship with you, (b) the existence of a legal obligation as to the retention period, and (c) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
8. Accessing and Updating Your Information
If you would like to review, correct, or update the Personal Information that you have provided to us, or if you would like to request an electronic copy of your Personal Information, you may make such requests by completing the form located at tim.blog/corrections/ or emailing us at legal [at] tim.blog. If you email us, please provide your full name, email address you have used to access the Services, and specify the type of request you are making. We will verify your identity using the email address we have in our records.
9. Your Choices
- Unsubscribing to Email. If you no longer wish to receive email messages from us, you can opt out of this Service by either (1) following the “unsubscribe” instructions located near the bottom of each email message or (2) emailing us at legal [at] tim.blog.
- Analytics and Interest-based Advertising. The companies we work with to provide you with interest-based advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices/ for website opt outs and https://www.aboutads.info/appchoices for mobile opt outs. Note that opting out through these links only means that the selected participants should no longer deliver interest-based advertising to you, but does not mean that the participants will not process your information for interest-based advertising purposes or that you will no longer receive interest-based advertising from other companies.
Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.
To opt out of us disclosing your hashed email address to an ad partner for Matched Ads purposes, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will remove your email address from any subsequent lists disclosed to ad partners for Matched Ads purposes.
10. Advisory Regarding Participation by Children and Teens
This Service is not directed toward children under 13 years old. Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT KNOWINGLY COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you are a parent or guardian and believe we have collected personal information from children, please contact us at legal [at] tim.blog. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.
11. Relationship to Terms of Service; Incorporation of Terms of Service
12. Notice of Privacy Rights to California Residents
California provides additional rights to California residents, including through the California Consumer Privacy Act as replaced by the California Privacy Rights Act (“CCPA”). This section addresses those rights and only applies to California residents.
A. Notice of Collection.
We have collected the following categories of personal information (as described in the CCPA) in the past 12 months.
- Identifiers, including name, postal address, email address, social media handles, and online identifiers (such as IP address).
- Customer records, including billing and/or shipping addresses and payment information.
- Commercial or transactions information, including records of products or services purchased, obtained, or considered.
- Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Non-precise geolocation data, including location derived from an IP address.
- Inferences drawn from any of the information identified in this section.
For further details on the personal information we collect and the sources from which we obtain personal information, please review the “The Information We Collect” section above.
We collect and use this personal information for the business and commercial purposes set out in the “How We Use This Information” section above. We disclose this personal information to the categories of persons set out in the “How We Share This Information” section above. Please visit those sections for further details.
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under the CCPA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out of Sales and Sharing” section below.
We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
B. Right to Know, Correct, and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold or shared;
- The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
- The business or commercial purpose for collecting or selling or sharing the personal information; and
- The specific pieces of personal information we have collected about you.
In addition, you have the right to correct or delete the personal information we have collected from you. These rights are subject to certain exceptions and also apply to sensitive personal information.
To exercise any of these rights, please email us at legal [at] tim.blog.
If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
The Services may use blockchain technology to store certain personal data, including your digital wallet address, time of transactions, and other information that may be used to directly or indirectly identify you. We use pseudonymization in our blockchain records to reduce the risk to individuals whose personal data is processed in the blockchain. As a result, the way we respond to a request to exercise certain of your rights (i.e., access, correction, and deletion requests) will be limited. We cannot alter information stored in a blockchain, but, if you request erasure, object to the processing of your personal data, or request that the processing of your personal data be limited by us, we will not include your personal data in our records that are added to the blockchain subsequent to such request. We may not be able to provide you the Services if you request that your personal data be deleted or you object to further processing of your personal data.
C. Right to Opt-Out of Sales and Sharing.
We do not “sell” or “share” your personal information as those terms are defined by the CCPA. We have deactivated the advertising functionality of Google Analytics, and have turned on Facebook’s “Limited Data Use” feature, which automatically deactivates the collection of interest-based advertising data for users located in California.
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at legal [at] tim [dot] blog with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
G. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
13. Notice of International Data Transfers
14. Notice of Privacy Rights to Virginia Residents
Virginia provides additional rights to Virginia residents through the Virginia Consumer Data Protection Act (“VCDPA”). This section addresses those rights and applies only to Virginia residents.
You have the following rights under the VCDPA:
- To confirm whether or not we are processing your personal data,
- To access your personal data,
- To correct inaccuracies in your personal data,
- To delete your personal data, and
- To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format.
- To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To exercise any of these rights, please email us at legal [at] tim.blog and specify which right you are seeking to exercise. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request.
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at legal [at] tim.blog and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.
15. Third-Party Sites
We want your feedback. If you have suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 19 (Contact Us).
18. Contact Us
legal [at] tim.blog