Privacy Policy

Notice at Collection of Personal Information

We collect the categories of Personal Information identified below. We do not "sell" or "share" (as such terms are defined in California law) Personal Information, nor do we knowingly collect Personal Information about persons under the age of 16. Your mobile information will not be sold or shared with third parties for promotional or marketing purposes.

B. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information

We process your Personal Information to operate, improve, understand, and personalize our Services. We use Personal Information for the following purposes:

• To provide you with our Services.
• To communicate with you, including to respond to your inquiries and requests and request feedback from you, and to send you important updates and messages about offers, changes to our Services, this Privacy Policy, and/or other applicable terms and conditions.
• To provide support and assistance for the Services.
• To create, maintain, customize, and secure your account with us.
• To personalize website content and communications based on your preferences.
• To process your payments and fulfill your orders or other transactions.
• To improve and develop the Services, including testing, research, analysis, and product development.
• To monitor, protect, and maintain the security and integrity of our Services and our business, such as protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities.
• To comply with applicable laws, regulations, and contractual obligations; enforce our Terms of Use; protect our rights, privacy, safety, property, and/or those of others; and respond to lawful requests and communications from law enforcement and other government officials.
• To review the usage and maintain the operation of our Services.
• To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction.
• To fulfill any other purpose for which you provide your Personal Information or as explained to you at the point of information collection.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at .

C. Retention

We retain Personal Information about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

Personal Information We Collect

There are several ways we may obtain Personal Information about you, including through (A) information you provide to us; (B) information we automatically collect; (C) information we receive from third parties; and (D) combining information from different sources. This includes data that identifies you personally whether directly or indirectly.

A. Information You Provide

We collect Personal Information as listed in the above Notice at Collection from you as follows:

• When You Use our Services. We collect Personal Information from you when you inquire about or create an account to use the Services.
• When You Make a Purchase. If you purchase services from us, we or our third-party payment processors collect a payment card number or other payment information.

B. Information We Automatically Collect

When you visit and interact with our Services, we or our third-party analytics partners and service providers may use a variety of technologies, such as cookies, tags, SDKs, or scripts, to collect certain information regarding your activity. The specific types of information that we and our partners and service providers may automatically collect when you visit and interact with our Services include:

• Device and Browser Information. This includes your device's IP address and/or other unique identifiers, browser type, device type, internet service provider, and operating system.
• Location Information. When you access our Services from a mobile device, your device's approximate location (derived from your device's IP address or other signals) may be collected.
• Usage Information. When you interact with our Services, certain information may be collected, including the date and time of your visit, the pages you view immediately before and after you access our Services, the areas or pages of our Services that you visit, the amount of time you spend viewing or using our Services, recordings of chat sessions (including with the involvement of bots), and other Site usage information. We (or our third-party vendors) may use tools and software to monitor and record information (including screenshots and videos) about your interactions with our Services, including keystrokes, mouse movements, form field entries, and overall engagement with our Services.
• Marketing Information. If you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our Site).
• Third-party analytics technologies. We may use third-party analytics and tracking tools to better understand who is using our Services, how people are using them, and how to improve their effectiveness as well as the effectiveness of any related content.

Cookies and Other Similar Technologies: "Cookies" are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of our Sites and related content.

Please note that cookies (and other similar technologies) provided by third parties may be placed on our Sites and the providers of these technologies may combine information collected from your interaction(s) with our Services with information they collect from other sources and use the combined information for analytics purposes.

C. Information We Receive from Third Parties

We may receive Personal Information from other sources. Our third-party sources may include:

• Our Business Partners, including companies that co-sponsor our promotions.
• Our Marketing/advertising and analytics partners, including online advertising networks and analytics providers.
• Social Media Platforms (note that the information we receive from such platforms is dependent upon their policies and your settings on the platforms).
• Other Companies that provide Personal Information to supplement what we already know about you, including data aggregators.

D. Combination of Information

We may combine Personal Information that we receive from various sources. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.

How We Disclose Your Personal Information

We may disclose each category of your Personal Information that we collect to service providers and other parties for the following purposes:

• Auditing related to a current interaction and concurrent transactions, including, but not limited to, auditing compliance with this specification and other standards.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use of Personal Information that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service that we own, control, or that was provided for us.

We disclose your Personal Information to the following categories of service providers and other parties:

• Service providers, including:
  • Security and fraud prevention consultants.
  • Hosting and other technology and communications providers.
  • Analytics providers.
  • Staff augmentation and contract personnel.
• Parties who acquire your Personal Information through an acquisition or other change of control:
  • Personal Information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).
• Government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
• Other parties at your direction:
  • Third-party business partners who you access through the Services.
  • Other parties authorized by you.

Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our Terms of Use; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

Please note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.

Your Privacy Choices and Rights

You have the ability to make certain choices about how we use your Personal Information, as follows:

A. Unsubscribing from Our Marketing and Promotional Communications

From time to time, we may send you marketing and promotional communications, including special offers from us or our partners. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.

B. Privacy Rights and Requests

Depending on your U.S. state of residence, you may have certain rights in relation to your Personal Information, including:

• Right to Know: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you. Please note that we may not be required to respond to your requests "to know" or access specific pieces of Personal Information more than twice in any 12-month period.
• Right to Data Portability: You may have the right to access your information in a portable format.
• Right to Delete: You may have the right to request that we delete Personal Information that we have collected from you, subject to certain exceptions.
• Right to Correct: You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
• Right to Opt Out of Certain Types of Personal Information Uses and Disclosures: You may have the right to opt out of the "sale" or "sharing" of your Personal Information, or the use and disclosure of your Personal Information for "targeted advertising" (as these terms are defined in applicable law). However, we do not "sell" or "share" your Personal Information, nor do we use and disclose your Personal Information for "targeted advertising" (as these terms are defined in applicable law).

Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent's authority to make the request) and confirm the Personal Information we maintain relates to you.

If you are interested in exercising one or more of the rights outlined above, you can contact us at . Please put the statement "Your Privacy Rights" in the subject field of your email. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Submitting a privacy rights request does not require you to create an account with us.

We will not discriminate against you if you decide to exercise your privacy rights.

C. Agent Requests

Only you, or someone legally authorized to act on your behalf, may submit a request related to your Personal Information. You may also submit a request on behalf of your minor child.

Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf. Tirith retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.

D. Right to Appeal

Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at .

External Links

Our Services may have links to third-party services, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

Children's Privacy

We do not knowingly collect or solicit Personal Information from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Information, please contact us at . Please mark your inquiries "Children's Privacy Information Request."

Data Security

We seek to protect your Personal Information from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Information and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.

Revisions to This Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the tirith.us website, by sending you an email, and/or by other lawful means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

How to Contact Us

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at .