This Privacy Policy applies to all products, services, and websites (collectively, the “Website”) offered by Center for Anthroposophical Endeavors, dba Tonalitá (referred to as “us,” “we,” “our,” “Tonalitá”).

Your privacy is important to us. We’ve laid out below what information we gather, how we use the information, and the limited circumstances when information may be shared. We recognize your right to confidentiality and are committed to protecting your privacy. We use the information that we collect to provide you with the best experience possible and to communicate with you about our products, services, and promotions.

If you have any questions about this Privacy Policy, please feel free to contact us through our website or write to us at info@tonalitah.com.

1. Personal Information We Collect

1.1. User Data

In order to use the Website, you will need to input certain information to create an account and to use our services, including, your first and last name and email address (“User Data”). User Data also includes other data that you choose to share, or others choose to share about you, including photos, status updates, and other information on the Tonalitá platform. You are solely responsible for your User Data. You assume all risks associated with use of your User Data, including any reliance of its accuracy or completeness. User Data may include third party content, and you agree not to submit third party content unless you have the consent of the applicable third party owner of the content. Because you are solely responsible for your User Data, we make no guarantees regarding the accuracy, currency, or quality of any User Data.

1.2. Storage of Data

We encrypt and store all of your personal information on our secure servers. Credit card information will be stored on separate secure servers that are maintained by a third-party credit card processor (Stripe or PayPal, depending on the payment method you select).

2. Personal Information from Minors

We do not offer our Website to, or target, persons under the age of 16. In compliance with the Children’s Online Privacy Protection Act, we will remove any information we receive from people we believe to be under the age of 16 from our database and cancel any corresponding accounts.

3. Use of User Data

We use User Data to create your account, communicate with you about the Website, provide the Website, offer additional products and services, and to the extent necessary to enforce our Terms of Use and to prevent imminent harm to people or property.

4. Cookies

We use “cookies” to collect certain information from all users, including website visitors who do not create an Account with us. A cookie is a string of data that our system sends to your computer and then uses to identify your computer when you return to our Website. We use this information to better engage with our users and enhance their overall experience by serving the following purposes:

4.1 Authentication

We use cookies to verify your account and determine when you are logged in so we can show you the appropriate experience and features and to make it easier for you to access Tonalitá.

4.2 Security, Site, and Product Integrity

We use cookies to help us keep your account, data, and Tonalitá safe and secure. We also use cookies to combat activity that violates our policies or otherwise degrades our ability to provide Tonalitá products and services.

4.3 Site Features and Website

We use cookies to enable the functionality that helps us provide the Website and related services. We also use cookies to help provide you with content relevant to your locale.

4.4 Performance

We use cookies to provide you with the best experience possible, which includes helping us route traffic between servers and understand how quickly the Website loads for different users.

4.5 Analytics and Research

We use cookies to better understand how users use the Website so that we can make any necessary improvements.

4.6 Rejecting Cookies

If you have set your browser to reject cookies, you can still use the Website, but you may not be able to utilize all of the Website’s functionality.

4.7 Third-Party Cookies

Cookies and similar technologies may also be used by our affiliates and advertisers. Tonalitá encourages anyone who uses cookies to follow appropriate privacy standards and policies, but is not responsible for cookies placed by third parties.

5. Sharing User Data

5.1. Disclosure of User Data

We take reasonable steps to protect all of User Data against unauthorized access or release. We may share User Data (a) with our third party service providers; (b) if another company acquires our company, business, or assets, with such acquiring company; and (c) as required by law and when we believe disclosure is reasonably necessary to comply with a judicial proceeding, court order, or legal process served on us, to protect our rights and the rights of our users, or to enforce or apply our Terms of Use or other policies or user agreements.

5.2. Notice of Other Disclosure

Other than as detailed above, we will provide reasonable notice to you when your User Data might go to third parties, and you will have an opportunity to choose not to share User Data.

6. Security of User Data

6.1. Reviews and Updates to Security Measures

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of User Data. We do internal reviews of our data collection, storage, processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to the systems where we store User Data. In addition, we restrict access to User Data to our employees, contractors, and agents who need to know certain information in order to process it on our behalf. These individuals and entities are bound by strict confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

6.2. Payment Information

When you purchase services or products through the Website, your User Data and credit card or debit card information is processed, stored, and kept secure by a third-party credit card processing service, either Stripe or Paypal depending on the payment method you select. Your credit card information will be stored by Stripe or Paypal in their restricted-access database and subject to each provider’s Terms of Use and Privacy Policy. However, no method of transmission over the Internet, or electronic storage is 100% secure, and we cannot guarantee its absolute security. We assume no responsibility or liability for damages resulting from Stripe or Paypal’s processing, storage, or other use of your credit or debit card information or any User Data.

6.3. Security Breach

If User Data is compromised as a result of a security breach, we will promptly notify you that your personal information may have been compromised via email, by posting a notice on our website, or as otherwise required by applicable law.

7. Third Party Applications and Linked Sites

We rely on certain third-party applications to operate the Website, and we may make additional third party applications, including add-ons to our Website, available for you to use. The information we collect when you enable a third party application is processed under this Privacy Policy. Information collected outside of our website by a third party application provider is governed by the third party’s privacy policies. Our website may contain links to and from other sites operated and maintained by third parties. We have no responsibility for linked websites, and we provide these links solely for your convenience and information.

8. Transfers of Personal Information

The Website is hosted and operated in the United States (“U.S.”). If you do not reside in the U.S., laws in the U.S. (and other countries) may differ from the laws where you reside. By using the Website, you acknowledge that any personal information about you, regardless of whether provided by you or obtained from a third party, is being provided to Tonalitá in the U.S. and will be hosted on U.S. servers, and you authorize Tonalitá to transfer, store, host and process your information to and in the U.S. and in other countries at the discretion of Tonalitá. You consent to transfer of your data to the U.S. pursuant to the standard data protection clauses promulgated by the EC.

9. Processing Grounds

We will only use your personal information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

9.1. Contractual necessity

We process some personal information because we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Website. When we process data due to contractual necessity, failure to provide such personal information will result in your inability to use some or all portions of the Website that require such data.

9.2. Legitimate interest

We may process personal information when we believe doing so furthers our legitimate interest. Our legitimate interests may include operation and improvement of the Website; marketing the Website; provision of customer support; protection from fraud or security threats; completion of corporate transactions; and compliance with legal obligations.

9.3. Consent

In some cases, we process personal information based on the consent you expressly grant to us at the time we collect such data. When we process personal information based on your consent, it will be expressly indicated to you at the point and time of collection. To withdraw your consent, please email us at info@tonalitah.com.

9.4. Other processing grounds

From time to time we may also need to process personal information to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

10. Data Retention

Unless you request otherwise pursuant to your rights below, we keep the User Data we collect for so long as reasonably necessary to fulfill the purposes for which the User Data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.

11. Your Data Rights

You have certain rights with respect to your personal information, and we want to help you review and update your information to ensure it is accurate and up-to-date. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include personal information, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days.

If you wish to exercise any of the following rights, you may do so by contacting us at info@tonalitah.com:

11.1. Access

You can request more information about the personal information we hold about you and request a copy of such personal information.

11.2. Rectification

If you believe that any personal information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

11.3. Erasure

You can request that we erase some or all of your personal information from our systems. Please note that if you request the deletion of information required to provide the Website to you, your Account will be deactivated and you will lose access to the Website.

11.4. Portability

You can ask for a copy of your personal information in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

11.5. Withdrawal of Consent

If we are processing your personal information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal information, if such use or disclosure is necessary to enable you to utilize some or all of our Website.

11.6. Objection

You can contact us to let us know that you object to the further use or disclosure of your personal information for certain purposes, such as for marketing purposes.

11.7. Restriction of processing

You can ask us to restrict further processing of your personal information.

You also have the right to lodge a complaint about Tonalitá’s practices with respect to your personal information with the supervisory authority of your country or EU Member State.

12. Opting Out

12.1. Not Providing User Data

You can choose not to provide User Data, although failing to provide User Data may prevent or inhibit your use of the Website and affect our ability to adequately respond to your requests.

12.2. Opting Out of Emails

If you do not want to receive e-mail or other mail from us, you can adjust your account settings to opt out of receiving such communications or choose to unsubscribe from the link in the e-mail that you no longer wish to receive.

13. California Disclosures

13.1. California information-sharing disclosure

If you are a California resident, you have the right to request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and what types of information we disclosed. California residents may request this list by emailing us at info@tonalitah.com with “California Privacy Rights” in the subject line.

13.2. Do Not Track Signals

We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

14. Conditions of Use, Notices, and Revisions

By using the Website, you consent to the collection, use, and disclosure of User Data according to the terms of this Privacy Policy. We reserve the right to modify or amend this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by providing the updated Privacy Policy on our website, sending you an e-mail, or posting a notice on our website so that you are always aware of the information that we collect, how we use it, and under what circumstances we disclose it. Unless we clearly state otherwise, the changes to our Privacy Policy will affect only the information we collect after the effective date of the change.

If you have any questions or concerns regarding any of the terms of this Privacy Policy, please feel free to contact us at: Tonalitá, PO Box 521, Mountlake Terrace, WA 98043

Last updated: October 2, 2024