Tulip Strategies Privacy Policy


PRIVACY


Updated Date: October 28, 2021


This Privacy Policy explains how Tulip Strategies collects and uses information when you interact with its site and mobile applications. This Privacy Policy applies to all users of Tulip Strategies’ website published at www.tulipstrategies.com and other websites with “Tulip Strategies” branding that link to this Privacy Policy (collectively, the Services).


We encourage you to read this Privacy Policy carefully before using this website or providing information to us. By using our website, you understand that we will collect, use, and disclose your information in accordance with this Privacy Policy.


CONTACTING US

If you ever have any questions about this Privacy Policy, please contact us at contact@tulipstrategies.com.



UPDATES TO THIS POLICY

We may change this Privacy Policy at any time. Please take a look at the "Updated Date" legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective on the "Last Updated" date indicated above. By using the Tulip Strategies services or providing information to us following such changes, you will have accepted the revised Privacy Policy.



PERSONAL INFORMATION

PERSONAL INFORMATION WE COLLECT

Tulip Strategies collects two types of information: Personal Information and Other Information. "Personal Information" is information that identifies you as a specific individual. "Other Information" is any information that does not identify you as a specific individual. Other Information is addressed below, under the heading "Other Information".


We and our service providers may collect the following Personal Information:

  • Name;

  • Physical address;

  • Telephone number; and

  • Email address


IF YOU SUBMIT ANY PERSONAL INFORMATION RELATING TO ANYONE OTHER THAN YOURSELF, YOU REPRESENT THAT YOU HAVE OBTAINED ANY NECESSARY CONSENT FROM THAT INDIVIDUAL FOR USE AND DISCLOSURE OF THAT INDIVIDUAL’S PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

HOW WE USE PERSONAL INFORMATION

We and our service providers may use Personal Information:

  • To respond to your inquiries and fulfill your requests, including to contact you if necessary;

  • To send you important information regarding Tulip Strategies, changes to our terms, conditions and policies and other administrative information;

  • To send you information by email, postal mail, telephone and other means about our services;

  • To protect the security or integrity of our businesses and Internet properties; and

  • As may be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, or that of you, our Affiliates or others; and (g) to allow us to pursue available remedies or to limit the damages that we may sustain.

HOW PERSONAL INFORMATION IS DISCLOSED

Your Personal Information may be disclosed:

  • To our third-party service providers, who provide services such as website hosting, data storage, data analysis, payment processing, IT services and infrastructure, customer service, email delivery and administration, credit card processing, auditing and other similar services to enable them to provide services;

  • To our subsidiaries and affiliated entities (collectively, our "Affiliates") for marketing and other purposes;

  • To selected third parties ("Promotional Partners"), to permit them to send to you marketing communications;

  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding); and

  • As may be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, or that of you, our Affiliates or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

OTHER INFORMATION WE COLLECT

"Other Information" is any information that does not identify you as a specific individual, such as:

  • Browser information;

  • Server log files;

  • Information collected through cookies, pixel tags and other technologies;

  • Physical location of your device;

  • Demographic information and other non-personally identifiable information provided by you; and

  • Aggregated information.

HOW WE COLLECT OTHER INFORMATION

We and our third-party service providers may collect Other Information in a variety of ways, including:

  • Through your browser: Certain information is collected through most devices, such as your Media Access Control ("MAC") address, device manufacturer and model, device identifier, screen resolution, and the type and version of your operating system and browser.

  • Through server log files: An Internet Protocol ("IP") address is a number that is automatically assigned to a device by an Internet Service Provider ("ISP"), and is identified and logged automatically in our server log files whenever a user visits the Tulip Strategies website, along with the time of the visit and the page(s) that were visited. We and our service providers use IP addresses for purposes such as calculating usage levels and helping diagnose server problems.

  • Using cookies: The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to Tulip Strategies’ Services by your computers and mobile devices. These servers are operated, and the cookies managed by Tulip Strategies, its business partners or its service providers. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org. If you choose to decline cookies, some or all of the features, functionality and promotions available through the Tulip Strategies website − such as the shopping cart, ability to view certain pages, and even placing orders or reviewing your order history – may not be available to you.

  • Analytics. We may use third-party services, such as Google Analytics or IBM Coremetrics, in connection with the Tulip Strategies website. Such services use cookies and similar technologies to analyze how visitors use the Tulip Strategies website, to compile statistical reports on activity related to the Tulip Strategies website, and to provide other services related to the Tulip Strategies website. Such services may also collect information about visitors’ use of other websites or other online resources. For more information about Google Analytics, including how to opt out, please go to: https://tools.google.com/dlpage/gaoptout. For more information about IBM Coremetrics, you may review its privacy policy located at: http://www.ibm.com/privacy/us/en/.

  • Flash Local Stored Objects: We and our service providers may use a third-party technology, called Flash, in connection with the Tulip Strategies website, including our online content. Flash provides a facility, referred to as Local Stored Objects ("LSO"), that allows a website operator or online content provider (or their service providers) to store certain information locally on an individual’s device. If you do not want Flash LSOs stored on your device, you can adjust the settings of your Flash player to block Flash LSO storage using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Tulip Strategies website. We expect our service providers and technology suppliers to honor any decision by you to restrict or limit Flash LSOs, but we cannot guarantee that they will do so.

  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) are small images that may be used by us and our service providers in connection with some pages of the Tulip Strategies website and HTML-formatted email messages to, among other things, render such pages to you on various hardware devices and operating system versions, track the actions of users and email recipients, measure the success of marketing campaigns and compile statistics about usage and response rates. Pixel tags may collect information such as the pages, features and links accessed by a user, and the IP address, browser type and operating system of such user’s device.

  • Physical location: We and our service providers may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content, including for marketing purposes, based on the choices that have been made with respect to such uses. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our third-party marketing partners, such as our Promotional Partners, to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns, based on the choices that have been made with respect to such disclosures. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we, our service providers, and/or our third-party marketing partners may not be able to provide you with the applicable personalized services and content.

  • From you: We and our service providers may collect demographic information such as your city, state or zip code of residence, as well as other information, such as your preferred means of communication, your gender and your date of birth, when you voluntarily provide this information to us or our service providers. You may also have the opportunity to provide us with information regarding major events such as weddings, child births and the purchase of a new home. We also maintain a record of your orders, purchases, exchanges, returns, wish lists and gift registries in connection with the Tulip Strategies website or our businesses. Unless combined with Personal Information, this information does not personally identify you or any other customer or potential customer of our businesses.

  • By aggregating information: We and our service providers may aggregate Personal Information collected from our customers and potential customers. Aggregated Personal Information does not personally identify you or any other customer or potential customer.

HOW WE USE AND DISCLOSE OTHER INFORMATION

We may use and disclose Other Information for any purpose, and we may combine Other Information with Personal Information (such as combining your zip code with your name). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information while it is so combined.

DO NOT TRACK SIGNALS

We note that the Tulip Strategies website will continue to operate as described in this Privacy Policy, whether or not a "Do Not Track" signal or similar mechanism is received from your browser.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data storage system or data transmission over the Internet can be guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures.

Please exercise caution in submitting Personal Information via the Tulip Strategies website, especially if you are accessing the Tulip Strategies website using a WiFi hotspot or public network. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem and place any orders with us over the telephone or in person, instead of using the Tulip Strategies website. You may contact us in such circumstances in accordance with the "Contacting Us" section below.

CHOICES AND ACCESS

YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION

We provide choices regarding our use and disclosure of your Personal Information for marketing purposes, regardless of whether such information is collected by us through the Tulip Strategies website or otherwise. You may opt-out from:

  • Our sharing of your Personal Information with Affiliates, Promotional Partners and other third parties for their marketing purposes: If you no longer want us to share your Personal Information on a going-forward basis with our Affiliates, Promotional Partners and other third parties for their marketing purposes, you may opt-out of such sharing by contacting us in accordance with the "Contacting Us" section below. In so contacting us, please be sure to include your full name and the contact information that you no longer wish to be shared, and state specifically whether you wish to opt-out of such sharing with (a) Affiliates, (b) Promotional Partners and other third parties, or (c) both.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of our Affiliates, Promotional Partners and other third parties with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send important administrative messages to you, and you cannot opt-out from receiving such administrative messages. For example, when you place an order, we will continue to confirm your order and shipment status by email. We may also need to contact you via telephone, email or postal mail with information or questions regarding your order.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

We welcome your willingness to update your information with us. You may review or ask us to update your Personal Information by contacting us in accordance with the "Contacting Us" section. In your request, please make clear what information you would like to have changed. We will try to comply with your request as soon as reasonably practicable. We are not responsible for changing information in the databases of Affiliates, Promotional Partners and other third parties with whom we have already shared your Personal Information.

CHILDREN’S PRIVACY

Tulip Strategies does not intend that any portion of the Services will be accessed or used by children under the age of 18, and such use is prohibited. The Services are designed and intended for adults. By using the Services, you represent that you are at least 18 years old and understand that you must be at least 18 years old to create an account and purchase the goods and services advertised through the Services. Tulip Strategies will promptly delete information associated with any account for which the registered user associated with the account is not at least 18 years old.

JURISDICTIONAL ISSUES

The Tulip Strategies website is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Tulip Strategies pursuant to Section 1798.83 of the California Civil Code, please Contact Us at contact@tulipstrategies.com.

We may take a reasonable period of time to respond to any request to update or modify any information, limit use of information or to opt out of or unsubscribe from any communications. We may also ask for additional information to authenticate the request. If you request the deletion, modification or limitation of use of your personal information maintained by us, we will promptly review your request and respond. If we grant your request, such information may be retained for a period of time in our backup systems as a precaution against system failures. Some information may be retained for longer periods as required by law, contract or auditing requirements. In some circumstances we will not be able to limit use of your personal information without unsubscribing you from communications or deleting your information.