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Privacy

Last Updated: December 21, 2020 (Policy)

TRPC Inc, d/b/a Commons (“Commons,” “we,” “us,” or “our”), is committed to protecting your privacy. This Privacy Policy (“Privacy Policy”), describes how we collect, use, and disclose information through our website https://commons.co (the “Site”).

By visiting the Site, you agree to the terms of this Privacy Policy as they may be amended from time to time. Your use of our Site and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service, including their applicable limitations on damages and the resolution of disputes. The Commons Terms of Service are incorporated by reference into this Privacy Policy.

Because the Services may change and this Privacy Policy may change accordingly, please check back occasionally for updates.

1. COLLECTION

The information we collect from you depends on how you use the Site, including when you merely browse the Site, when you create an Account as a customer or Coach, and when you purchase products through the Site.

a) When you Browse the Site. We use cookies, web beacons, local storage objects, pixels and other technologies that operate on the Site. These technologies may collect your computer’s Internet Protocol (IP) address, domain name, internet browser and operating system, the time, date, and length of time you visit our Site, mobile device ID, the web pages you view on our Site, including the time spent on each page and clicks on each page, referring URL or the webpage that led you to our Site, and other interactions with the Site (“Technical Data”). You can adjust the permissions within your browser or device operating system. However, if you set your browser to disable certain technologies, such as cookies, some features of the Site may not function properly. Please see the section “Cookies and Tracking” below for more information.

b) When you Create an Account.

  • To create an account as a customer, we need to collect the following information about you: name, shipping address, email address, and phone number.
  • To create an account as an independent Coach, we will need to collect the following additional information: name shipping address, email address, and phone number.

c) When you Make a Purchase.

  • We will also collect your billing zip code and payment card information if you make a purchase on the Site. We send payment card information to our PCI-DSS compliant payment gateway for processing using SSL encryption technology. Your payment card information is never stored for use beyond your current transaction.

d) From Other Sources. We may receive additional information about you from public and commercially available sources and other third parties. Commons independent Coaches may also share information about you with us (for example, if your Coach invites you to create an Account, we receive your name and email address from your Coach in order to send you an invitation). If you access third-party services, such as Facebook, Google, or Twitter through the Site, to log into the Site, or to share information about your experience on the Site with others, we may collect information from these third-party services. We may combine all of the information we collect and receive about you, both online and offline, and use or disclose it in the manner described in this Privacy Policy.

If you disclose any personal information relating to other people to us or to our service providers in connection with the Site, you represent that you have the authority to do so and permit us to use this information in accordance with this Privacy Policy.

2. USE

We use your information, including your personal information, for the following purposes:

  • Providing the Site and support services, including to communicate with you about your access to and use of the Site, to respond to your inquiries, to provide troubleshooting, to process your payments and provide technical support, and for other user service and support purposes;
  • Analyzing and improving the Site and operations, including to better understand how users access and use the Site, to evaluate and improve the Site and our business operations, and to develop new services, to conduct surveys and other evaluations (such as user satisfaction surveys), and for other research and analytical purposes;
  • Personalizing content and experiences, including to tailor content we send or display on the Site, to offer location customization and personalized help and instructions; and to otherwise personalize your experiences;
  • Advertising, marketing and promotional purposes, including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns, to send you newsletters, offers or other information we think may interest you, to contact you about the Site or information we think may interest you, and to administer promotions;
  • In connection with our Commons independent Coach Program, including to validate sales made by Coaches, to calculate and make payments to Coaches under the Commons independent Coach Compensation Plan, to issue payments to and report income to taxing authorities, to support the operation of our customer discount subscription plan, to maintain the proper functioning of our Compensation Plan, to enforce our Coach Policies and Procedures, and to help Coaches search for, communicate with and validate customers in our systems.
  • Otherwise securing and protecting our business, including to protect and secure our business operations, assets, the Site, network and information and technology resources, to investigate, prevent, detect and take action regarding fraud, unauthorized access, threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct;
  • Defending our legal rights, including to manage and respond to actual and potential legal disputes and claims and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties;
  • Auditing, reporting, corporate governance, and internal operations, including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations, our general business, accounting, record keeping and legal functions, and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business; and
  • Complying with legal obligations, including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.

3. DISCLOSURE

We may share your information, including personal information, as follows:

  • With our service providers, to facilitate the services they provide to us. These may include providers of services such a customer service support, payment processing, email delivery, information technology and related infrastructure provision, website hosting, and other services;
  • With Commons independent Coaches, including as part of a Compensation Report which contains information (such as name, contact information, level or rank, and volume and sales statistics) on other Coaches and Customers within a Coach’s organization. Compensation Reports are provided to Coaches in strict confidence and for the sole purpose of supporting the Coach in further developing their Commons organization, including for use in marketing tools and platforms. Coaches are bound by the terms of their Coach Agreement and the privacy and data protection covenants contained therein.
  • Pursuant to business transfers if (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company;
  • In response to legal processes to comply with the law, a judicial proceeding, court order, or other legal process (e.g., in response to a court order or a subpoena);
  • To protect us and others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to the safety of any person, violations of our Terms of Service or this Privacy Policy, or as evidence in litigation in which we are involved; and
  • In aggregate, anonymized, or de-identified form with other entities for marketing, advertising, research or similar purposes.

4. COOKIES AND TRACKING

a) Technologies. We and our third party service providers use cookies, web beacons, local storage objects, pixels, session replay/screen capture, and other similar technologies to collect Technical Data as described in Section 1(a) above. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).

b) Disabling Cookies. Most web browsers automatically accept cookies but you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to the Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

c) Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our App. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

d) Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section below.

e) Third-Party Ad Networks. Advertisers may also use technologies like cookies and web beacons to enable them to recognize your computer each time they send you an advertisement even when you are visiting another site. As a result, the advertiser would have the ability to deliver targeted advertisements that they believe would be of most interest to you. We do not have access to or control of the cookies that may be placed on your computer by third-party advertisers.

Users may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

5. SECURITY

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

6. YOUR CHOICES

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account, the Site, or any other services you have requested or received from us.

7. THIRD PARTY LINKS

The Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

8. MISCELLANEOUS

The Site is headquartered in the United States and using the Site demonstrates your consent to the transfer and processing of information as described in this Policy. The Site is not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. California residents may request certain information regarding our disclosure of personally identifiable information about you to third parties’ for their own direct marketing purposes. However, we do not currently disclose PII to third parties for their direct marketing purposes.

9. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is current as of the effective date set forth above. We reserve the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of this Site by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to this Site. Under certain circumstances, we may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of this Site or sending you an email.

10. CONTACT US

If you have questions about the privacy aspects of the Site or would like to make a complaint, please contact us by email at legal@commons.co, by phone at (332) 230-4303‬, or by mail at 433 Broadway, Suite 509, New York, NY 10013.

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