Posted: June 24, 2018
Effective: June 24, 2018
The Toome.news Websites are maintained by the Leorica LLC, 16192 Coastal Highway, Lewes, Delaware 19958.
TooMe is committed to protecting the privacy of our users. We strive to provide a safe, secure user experience.
About Our Privacy Policy
This Privacy Policy sets forth the online data collection and usage policies and practices that apply to the TooMeNews website and the Leorica family of websites (referred to collectively as “Leorica Websites”), currently including TooMe.news, TooMe.org, Unihealer.com. Nulw.com. It also includes the order forms and member services accessible from those websites. The Leorica Websites contain links to other websites over which we have no control. We are not responsible for the privacy policies or practices of other websites that you visit through a link on the ToomeNews and Leorica Websites.
This Policy provides information required under the General Data Protection Regulation (GDPR), including:
- Personal Data we collect
- How Personal Data will be processed and the legal basis for processing
- With whom Personal Data will be shared
- Retention of your Personal Data
- What safeguards are in place to protect your Personal Data
- The transfer of your Personal Data outside the EEA
- Your rights with regards to your Personal Data
- Where to address your questions or complaints
Policy Details
What is Personal Data?
Personal Data (also referred to in this policy as Personal Information) means any information relating to a natural person who can be identified by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
Personal Information We Collect
When you visit the TooMeNews and Leorica Websites, there are four types of information you might provide to us: contact information you knowingly choose to disclose; billing information when you join, subscribe, or make a purchase; demographic or other information about you; and technical information collected by us as you interact with our websites.
Contact Information
In some areas of the TooMeNews and Leorica Websites, we request or may request that you provide personal information, including your name, address, e-mail address, and telephone number.
Purchaser Information
In some areas of the TooMeNews and Leorica Websites, we request or may request that you provide your credit card number, contact information, and billing information.
Demographic Information
IIn other areas, we collect or may collect demographic information such as your age, career focus and discipline, preferences, gender, educational degrees, ethnic background, interests, and household income range. Sometimes, we collect or may collect a combination of information types. Examples of areas on the TooMeNews and Leorica Websites where we collect or may collect personal or combined personal and demographic data are pages where you can sign up to use a service, post a resume, enter a contest, or purchase a product.
Technical Information
We also gather or may gather certain information about your use of our site, such as what areas you visit and what services you access. Moreover, there is information about your computer hardware and software that we collect or may collect. This information can include, without limitation, your IP address, browser type, domain names, access times, and referring website addresses. Some of this information is collected through the use of cookies (described below).
Use of Personal Information
The information collected may be used by TooMeNews for the purpose of providing you with the content you request, operating and improving the TooMeNews and Leorica Websites, fostering a positive user experience, and delivering the products and services that we offer.
We may also use the information we gather to inform you of other products or services available from the TooMeNews and Leorica Websites or to contact you about your opinion of current products and services or potential new products and services that may be offered.
We may use your contact information in order to send you e-mail, postal mail, or other communications regarding updates at the TooMeNews and Leorica Websites, such as Job Alerts, newsletters, new opportunities, and additional listings which may be of interest to you. We may also use it to send you information about third-party products and services that match your interests and preferences, if you opt in for this communication. The nature and frequency of these messages will vary depending upon the information we have about you. In addition, at the time of registration for certain services, such as Leoric Careers Job Alerts, or free partial access to any of the TooMeNews and Leorica Websites, you have the option to elect to receive additional communications, information, newsletters, and promotions relating to topics that may be of special interest to you.
If in the future we intend to process your Personal Data for a purpose other than that for which it was collected, we will provide you with information on that purpose and any other relevant information.
For EU-based visitors and subscribers, the following table provides information required by the GDPR relating to our use of your personal information.
| Personal Information | Legal Basis for Processing |
|---|---|
| Contact information, including name, address, e-mail address, and telephone number. | Consent to provide you with the content you request, as necessary for the performance of a contract. |
| Purchaser information, including credit card number, contact information, and billing information. | Necessary to provide you with the content you request. |
| Demographic information, including age, career focus and discipline, preferences, gender, educational degrees, ethnic background, interests, and household income range. | Legitimate purpose of providing tailored content to you. |
| Technical information, including your IP address, browser type, domain names, access times, and referring website addresses. | Legitimate purpose of authenticating subscribers and optimizing website performance. |
Retention of Personal Information
We retain indefinitely all the personal information we gather about visitors or subscribers as necessary to fulfill our contract with you. We retain indefinitely certain anonymized information we gather about visitors or subscribers for the legitimate purpose of performing website analytics and providing use of our website to all visitors in an efficient, practical, and relevant way. If there is no legal basis or other requirement for keeping your data AND after there has been no activity from you for twenty-six (26) months, your data that is no longer required will be purged.
Sharing of Personal Data
We do not share or disclose your personal information to third parties except as set forth below:
| Personal Information | Purpose of Sharing |
|---|---|
| Technical information | With Leorica business partners for the legitimate purpose of understanding usage patterns for TooMeNews and Leorica Websites and those of our partners. |
| Technical information | With web hosting and other technical service providers for the legitimate purpose of hosting our web servers and ensuring information security for our networks. |
| Contact information | With consultants and vendors for the legitimate purpose of providing customer support and marketing assistance. |
| Credit card information | With credit card processors for purposes of processing credit card transactions in connection with the subscriber’s contract with the TooMeNews and Leorica websites. |
| Contact information | With our business partners, with your consent, for the purposes of providing you with products or services tailored to your interests and preferences. |
- In addition, we disclose personal information if legally required to do so, if requested to do so by a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect the rights or property of TooMeNews; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
- In the event any one or all of the TooMeNews and Leorica Websites become the subject of a bankruptcy proceeding, whether voluntary or involuntary, the TooMeNews or its trustee in bankruptcy may sell, license, or otherwise dispose of such information in a transaction approved by the bankruptcy court as is legally required.
- In the event the TooMeNews and Leorica business is acquired in whole or part by a third party by way of merger, consolidation, or purchase, we will disclose and transfer such information to the third party.
- The TooMeNews may also share aggregated anonymous information about visitors to TooMeNews and Leorica Websites with its clients, partners, and other third parties so that they may understand the kinds of visitors to the TooMeNews and Leorica Websites and how those visitors use the site.
Transfer of Personal Data Outside the EEA
Personal Data captured on this website may be transferred to, and stored or otherwise processed at, a destination outside the European Economic Area (hereinafter “EEA”), including destinations that are not subject to Data Privacy Provisions equivalent to those in the EEA countries in which you provided your Personal Data. We transfer your data to the US with your consent or where necessary to provide you with the services you have requested. We will take all steps reasonably necessary to ensure that your Personal Data is processed safely and in accordance with this Privacy Policy.
Your Rights under the GDPR with regard to your Personal Data
Under the GDPR, EU-based visitors and subscribers have the rights to request from us access to Personal Data we store about you, to amend (or rectify) this data, to restrict our processing of the Personal Data, to erase the data, and to receive a copy of the data in a structured, commonly used, and machine-readable format (data portability). If you wish to invoke a right under the GDPR, you may contact us at admin@toome.org.
Please use the subject line “GDPR query” in the subject line. Your e-mail should include a sufficiently detailed description of the GDPR right with which you seek assistance. We may need to contact you for further information and reserve the right to charge a fee for certain requests. TooMe News will notify you if your request has been granted or declined, or if exemptions apply.
If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe that we have not complied with the requirements of the GDPR with regard to your Personal Data.
Information You Post
If you post any personal information in public and/or social network areas of the TooMeNews and Leorica Websites, e.g., in online forums or chat rooms, the information disclosed may be displayed to other users of these services and may be collected and used by others over whom we have no control. TooMeNews is not responsible for the use made by third parties of information you post or otherwise make available in public areas of the TooMeNews and Leorica Websites. If you remove information that you have made public on TooMeNews and Leorica Websites, copies may remain viewable in cached and archived pages of the TooMeNews and Leorica Websites or if others have copied or saved that information.
Opt-In and Opt-Out Choices
The registration forms and other sections of the TooMeNews and Leorica Websites where we collect your information provide you with relevant opt-in and opt-out choices regarding promotional activity and other communications with you.
E-mail to Members: TooMeNews members may opt in for first- or third-party informational e-mails or opt out of all e-mail communication, except transactional emails, such as subscription renewal and association election information. Members can manage their email preferences by logging into My Profile and going to the Edit My Contact Information section, or by contacting TooMeNews MemberCentral Support at membership@toome.org.
E-mail to Subscribers: Paid subscribers to TooMeNews publications, including TooMENews, UnihealerNews, NulwNews may also opt in for first- or third-party informational e-mails or opt out of all e-mail communication (with the exception of subscription renewal information) by contacting TooMe MemberCentral Support at membership@toome.org.
E-mail to Users of Free Services and Products:
- Where permitted by law, users of free online services provided by TooMeNews, such as free partial access to content from the Leorica family of journals, access to News from TooMe or Unihealer, or e-mail alerting services/newsletters, or who seek other free online services provided by TooMeNews are agreeing that TooMeNews may contact them by e-mail in exchange for these free services. Users who fall under the CASL and GDPR regulations who use free online services may opt in to e-mails from TooMeNews and Leorica Websites. Users can also opt in for third-party informational e-mails.
- Where permitted by law, users who do not wish to receive e-mail alerting services or newsletters may cancel such services by following the unsubscribe instructions at the bottom of any e-mail message from TooMeNews.
- Users who do not wish to receive e-mail may follow the unsubscribe instructions at the bottom of any e-mail message from TooMe.
The above are examples of opt-in/opt-out options and are not intended to describe every option on the TooMeNews and Leorica Websites websites.
Cookies
A cookie is a text file that is placed on your hard drive by a webpage server. We use cookies to deliver faster and more accurate results and a more personalized site experience. We also use cookies to track clickstreams, for load balancing, and for analytic purposes.
We use AdWords Remarketing, a remarketing and behavioral targeting service provided by Google, Yahoo. We also use Google and Yahoo and Adobe Analytics data and the DoubleClick cookie to serve ads based on a user’s prior visits to our website.
We also use a Google-provided tool called reCAPTCHA, which, on some form submissions, is intended to distinguish humans from robots in order to prevent spam and abuse of those forms.
Web Beacons
Our webpages may contain electronic images known as web beacons (sometimes called single-pixel GIFs) that allow us to count users who have visited those pages and to deliver co-branded services. Web beacons are not used to access your personally identifiable information on the TooMeNews and Leorica Websites. They are a tool we use to compile aggregated statistics about our website usage. Web beacons collect only a limited set of information, including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.
Feedback
We have, or may have, an area on our websites where you can submit feedback. Any feedback you submit in this area becomes our property, and we have a legitimate interest in contacting you for further information.
How We Protect Your Information
We are concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to us and we cannot guarantee that your information on the TooMeNews and Leorica Websites may not be accessed, disclosed, altered, or destroyed by breach of any of our industry-standard physical, technical, or managerial safeguards. We provide reasonable technical, administrative, and physical controls to secure the confidentiality, integrity, and availability of personal information. If you have any questions about security on the TooMeNews and Leorica Websites, you may contact us at support@toome.org.
Payment Processing
We utilize third-party payment services to enable you to purchase certain products or services from the TooMeNews and Leorica Websites. In such cases, you will be directed to a third-party service provider’s website operated by that provider in order to make the purchase. Any information that you provide to such provider may be subject to the applicable service provider’s privacy policy and not this Privacy Policy. We are not responsible for and have no control over the privacy policies or practices of third-party service providers. Use of third-party service providers to purchase products or services offered on the TooMeNews and Leorica Websites is solely at your risk.
All credit transactions occur in a secure area of our site to protect you from any loss, misuse, or alteration of information collected. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes. When you place an order online at any of the TooMeNews and Leorica Websites, your credit card information is protected through the use of encryption of web content using Transport Layer Security.
Additional Terms and Rules for Social Networking
Social networking services provided on the TooMeNews and Leorica Websites may have additional terms of conduct, privacy policies, and privacy settings that you will be required to agree to and set when you register for such services.
Updating Your Information
It is important to us that we have your correct contact information so that you don’t miss out on further correspondence or experience problems with the delivery of publications and products.
Members and customers with a TooMe ID can change their personal information or update their account information at any time by logging into My Profile. Other registrants or users may also update their personal information at any time by sending an e-mail to membership@toome.org.
Where to address your questions or complaints
If you have any concerns as to how your data is processed, you can contact:
TooMe for the Leorica LLC Office
16192 Coastal Highway
Lewes, Delaware 19958
Tel: (302) 503-0250
E-mail: support@leorica.com
Changes to Privacy Statement
If we change our Privacy Statement for the TooMeNews and Leorica Websites, we will post those changes here so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.
We welcome your comments concerning this Privacy Statement. Members who believe that we have not adhered to this statement may contact us by e-mailing us at support@leorica.com. Non-members may contact us at support@leorica.com. We will use commercially reasonable efforts to promptly determine and remedy the problem. Thank you for using the TooMeNews and Leorica Websites.
Legal Requests
TooMeNews reserves the right to share your information to respond to duly authorized information requests of governmental authorities or where required by law.
California
Under California Civil Code Section 1798.83 (also known as S.B. 27), if you are a California resident and your business relationship with TooMeNews is primarily for personal, family, or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail to support@leorica.com with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by S.B. 27’s requirements.
Acceptance of These Terms
Your use of the TooMeNews and Leorica Websites shall indicate your understanding and acceptance of the terms of this Privacy Statement. If you do not agree with all the terms herein, you should not use the TooMeNews and Leorica Websites or services.
