Effective date: November 1, 2019
Toro Labs LLC ("us", "we", or "our") operates the www.beprivate.co website
and the BePrivate app mobile application (the "Service").
This page informs you of our policies regarding the collection, use, and
disclosure of personal data when you use our Service and the choices you have
associated with that data.
We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Policy have the same meanings as in our Terms and Conditions.
Service means the www..beprivate.co website and the BePrivate app mobile
application operated by Toro Labs LLC
* Personal Data
Personal Data means data about a living individual who can be identified
from those data (or from those and other information either in our
possession or likely to come into our possession).
* Usage Data
Usage Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile
* Data Controller
Data Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for which
and the manner in which any personal information are, or are to be,
* Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process
your data more effectively.
* Data Subject (or User)
Data Subject is any living individual who is using our Service and is the
subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to
provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
("Personal Data"). Personally identifiable information may include, but is not
* Email address
* First name and last name
* Phone number
* Address, State, Province, ZIP/Postal code, City
* Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
following the unsubscribe link or instructions provided in any email we send.
We may also collect information that your browser sends whenever you visit our
Service or when you access the Service by or through a mobile device ("Usage
This Usage Data may include information such as your computer's Internet
Protocol address (e.g. IP address), browser type, browser version, the pages
of our Service that you visit, the time and date of your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may
include information such as the type of mobile device you use, your mobile
device unique ID, the IP address of your mobile device, your mobile operating
system, the type of mobile Internet browser you use, unique device identifiers
and other diagnostic data.
We may use and store information about your location if you give us permission
to do so (“Location Data”). We use this data to provide features of our
Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any
time, through your device settings.
Tracking & Cookies Data
Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Tracking technologies also used are beacons, tags, and scripts
to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.
Examples of Cookies we use:
* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences
and various settings.
* Security Cookies. We use Security Cookies for security purposes.
Use of Data
Toro Labs LLC uses the collected data for various purposes:
* To provide and maintain our Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when
you choose to do so
* To provide customer support
* To gather analysis or valuable information so that we can improve our
* To monitor the usage of our Service
* To detect, prevent and address technical issues
* To provide you with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless you have opted
not to receive such information
Legal Basis for Processing Personal Data Under General Data Protection
If you are from the European Economic Area (EEA), Toro Labs LLC legal basis
for collecting and using the personal information described in this Privacy
Policy depends on the Personal Data we collect and the specific context in
which we collect it.
Toro Labs LLC may process your Personal Data because:
* We need to perform a contract with you
* You have given us permission to do so
* The processing is in our legitimate interests and it's not overridden by
* For payment processing purposes
* To comply with the law
Retention of Data
Toro Labs LLC will retain your Personal Data only for as long as is
use your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply
with applicable laws), resolve disputes, and enforce our legal agreements and
Toro Labs LLC will also retain Usage Data for internal analysis purposes.
Usage Data is generally retained for a shorter period of time, except when
this data is used to strengthen the security or to improve the functionality
of our Service, or we are legally obligated to retain this data for longer
Transfer of Data
Your information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ than
those from your jurisdiction.
If you are located outside United States and choose to provide information to
us, please note that we transfer the data, including Personal Data, to United
States and process it there.
information represents your agreement to that transfer.
Toro Labs LLC will take all steps reasonably necessary to ensure that your
transfer of your Personal Data will take place to an organization or a country
unless there are adequate controls in place including the security of your
data and other personal information.
Disclosure of Data
If Toro Labs LLC is involved in a merger, acquisition or asset sale, your
Personal Data may be transferred. We will provide notice before your Personal
Disclosure for Law Enforcement
Under certain circumstances, Toro Labs LLC may be required to disclose your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).
Toro Labs LLC may disclose your Personal Data in the good faith belief that
such action is necessary to:
* To comply with a legal obligation
* To protect and defend the rights or property of Toro Labs LLC
* To prevent or investigate possible wrongdoing in connection with the
* To protect the personal safety of users of the Service or the public
* To protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100%
secure. While we strive to use commercially acceptable means to protect your
Personal Data, we cannot guarantee its absolute security.
"Do Not Track" Signals Under California Online Privacy Protection Act
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. Toro Labs LLC aims to take reasonable steps to allow
you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you
want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
* The right to access, update or to delete the information we have on you.
Whenever made possible, you can access, update or request deletion of your
Personal Data directly within your account settings section. If you are
unable to perform these actions yourself, please contact us to assist you.
* The right of rectification. You have the right to have your information
rectified if that information is inaccurate or incomplete.
* The right to object. You have the right to object to our processing of
your Personal Data.
* The right of restriction. You have the right to request that we restrict
the processing of your personal information.
* The right to data portability. You have the right to be provided with a
copy of the information we have on you in a structured, machine-readable
and commonly used format.
* The right to withdraw consent. You also have the right to withdraw your
consent at any time where Toro Labs LLC relied on your consent to
process your personal information.
Please note that we may ask you to verify your identity before responding to
You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service
("Service Providers"), to provide the Service on our behalf, to perform
Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
We may use third-party Service Providers to monitor and analyze the use of our
* Google Analytics
Google Analytics is a web analytics service offered by Google that tracks
and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google
services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
We may provide paid products and/or services within the Service. In that case,
we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is
provided directly to our third-party payment processors whose use of your
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.
The payment processors we work with are:
* Apple Store In-App Payments
* Google Play In-App Payments
* PayPal or Braintree
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If
you click on a third party link, you will be directed to that third party's
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone
under the age of 18. If you are a parent or guardian and you are aware that
your child has provided us with Personal Data, please contact us. If we become
aware that we have collected Personal Data from children without verification
of parental consent, we take steps to remove that information from our
We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the "effective date" at the top of
* By email: [email protected]