Privacy Policy

Last updated: July 2024

1. Introduction

1.1 Welcome to The Tattoo Pathways Privacy Policy:

At The Tattoo Pathway, we are committed to protecting the privacy of our users worldwide. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our website located at https://tattoopathway.com/ (the “Website”) and our mobile application (the “App”), collectively referred to as the “Services.”

1.2 Our Commitment to Your Privacy: We value your trust and understand the importance of safeguarding your personal information. This policy is designed to be comprehensive and transparent, providing you with a clear understanding of our data practices and the choices you have regarding your information.

1.3 Scope of this Policy: This Privacy Policy applies to all information collected through the Services, regardless of whether you are accessing the Services through the Website or the App. It covers personal information you provide directly to us, data we collect automatically, and information we receive from third parties.

1.4 Definitions:

• Personal Information: Any information that relates to an identified or identifiable natural person. This includes but is not limited to your name, email address, phone number, billing address, and any other information you provide when creating an account or making a purchase.
• App-Specific Data: Information collected through the App, such as journal entries, tattoo records, and photos you upload.
• Website Data: Information collected through the Website, such as your browsing activity, interactions with website features, and information you provide through forms or surveys.
• Automatically Collected Information: Technical information about your device, browsing actions, and patterns, including your IP address, browser type, operating system, referring URLs, pages viewed, and the dates/times of your visits.
• Sensitive Information: We do not intentionally collect any sensitive personal information, such as health information, genetic data, or biometric data. However, if you choose to share such information with us through journal entries or other voluntary means, we will handle it with utmost care and in accordance with this Privacy Policy.

1.5 Your Consent: By using our Services, you consent to the collection, use, and sharing of your information as described in this Privacy Policy.

1.6 International Data Transfers: Your information 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 from those from your jurisdiction. If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

1.7 Legal Basis for Processing (GDPR): If you are a resident of the European Union, our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where:

• We have your consent to do so.
• We need the personal information to perform a contract with you.
• The processing is in our legitimate interests and it’s not overridden by your rights.
• We have a legal obligation to collect or process personal information.

1.8 “Do Not Track” Signals: 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.

1.9 Contact Us:

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: support@tattoopathway.com

2. Information We Collect

2.1 Information You Provide to Us: We collect personal information that you voluntarily provide to us when you interact with the Services. This may include:

• Account Information: When you create an account, we collect your name, email address, phone number, billing address, and password.
• Payment Information: When you purchase a course or product, we collect payment information, such as credit card details, through our secure payment processor, Stripe. We do not store your full payment card information on our servers.
• Newsletter Subscription: When you sign up for our newsletter, we collect your email address.
• Contact Information: When you contact us for support or inquiries, we collect your name, email address, and any other information you choose to provide.
• Journal Entries and Tattoo Records: If you use the App, you may voluntarily provide journal entries, tattoo records, and photos.
• Social Media Information: If you interact with our social media pages or posts, we may collect information you publicly share on those platforms.

2.2 Information We Collect Automatically:

• Device Information: When you access the Services through the App, we may collect information about your device, including the device type, operating system, unique device identifiers, mobile network information, and your mobile operating system.
• Log Information: We collect information that your browser sends whenever you visit the Website. This log data may include your IP address, browser type and version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
• Usage Data: We may collect information about how you use the Services, including the features you use, the pages you visit, the links you click, and the time spent on each page.
• Cookies and Similar Technologies: We use cookies and similar tracking technologies to collect information about your activity on the Website. Cookies are small data files stored on your device that help us improve your experience on the Website. We may also use these technologies for marketing purposes, such as tracking your browsing behavior across websites to show you relevant ads.

2.3 Information from Third Parties: We may receive information about you from third parties, such as:

• Payment Processors: We receive information from payment processors like Stripe to process your payments.
• Analytics Providers: We receive data from analytics providers like Google Analytics and Firebase Analytics to understand how you use our Services and improve them.
• Marketing Partners: We may receive information about you from marketing partners, such as Facebook, to show you relevant ads based on your interests and browsing behavior.
• Other Sources: We may receive information about you from publicly available databases, social media platforms, or other third-party data providers.

2.4 Legal Bases for Processing (GDPR): If you are a resident of the European Union, we rely on the following legal bases to process your personal data:

• Contractual Necessity: We process your personal data to fulfill our contractual obligations to you, such as processing your orders, providing customer support, and delivering the Services you have requested.
• Legal Obligation: We process your personal data to comply with legal obligations, such as tax laws and accounting regulations.
• Legitimate Interests: We may process your personal data for our legitimate business interests, such as improving our Services, preventing fraud, and marketing our products and services, provided that these interests are not overridden by your fundamental rights and freedoms.
• Consent: In some cases, we may ask for your consent to process your personal data for specific purposes, such as sending you marketing communications or using your data for research. You have the right to withdraw your consent at any time.

2.5 Data Minimisation and Purpose Limitation: We collect and process only the minimum amount of personal data necessary to fulfil the purposes outlined in this Privacy Policy. We will not use your personal data for any purpose that is incompatible with these purposes.

3. How We Use Your Information

3.1 General Purposes: We collect and use your information for the following purposes:

• To Provide, Maintain, and Improve our Services: This includes using your information to create and manage your account, process your orders and payments, provide customer support, and personalize your experience on the Website and App.
• To Communicate with You: We may use your information to send you transactional emails (e.g., order confirmations, password resets), as well as promotional emails and newsletters about our courses, products, or services. You can opt out of these communications at any time.
• To Personalize Your Experience: We may use your information to tailor the content and recommendations you see on our Services based on your interests and preferences.
• To Conduct Research: We may use anonymized and aggregated data derived from your information to conduct research and analysis to improve our Services and understand industry trends. This research will not identify you personally.
• To Comply with Legal Obligations: We may process your information to comply with applicable laws, regulations, legal processes,or governmental requests.
• For Direct Marketing: With your consent, we may use your email address and other contact information to send you marketing communications about our products, services, or promotions. You can unsubscribe from these communications at any time by clicking the “unsubscribe” link at the bottom of the email or by contacting us at support@tattoopathway.com.
• For Profiling: We may analyze your interactions with the Services and your purchase history to create a profile of your interests and preferences. This allows us to personalize your experience and offer you more relevant content, products, and services. You can object to this processing by contacting us at support@tattoopathway.com.

3.2 Specific Uses of Information:

• Account Information: We use your account information to manage your account, process your orders, and communicate with you.
• Payment Information: We use your payment information to process your payments and prevent fraud.
• Journal Entries and Tattoo Records: We use this information to provide you with a personalized experience within the App and, with your consent, for research purposes.
• Device Information: We use device information to optimize the App’s performance and ensure compatibility with different devices.
• Log Information, Usage Data, Cookies, and Similar Technologies: We use this information to analyze trends, administer the Website, track users’ movements around the Website, and gather demographic information about our user base.

3.3 Legal Bases for Processing (GDPR): If you are a resident of the European Union, we rely on the following legal bases to process your personal data for the purposes described above:

• Contractual Necessity: We process your personal data to fulfill our contractual obligations to you, such as processing your orders, providing customer support, and delivering the Services you have requested.
• Legal Obligation: We process your personal data to comply with legal obligations, such as tax laws and accounting regulations.
• Legitimate Interests: We may process your personal data for our legitimate business interests, such as improving our Services, preventing fraud, and marketing our products and services, provided that these interests are not overridden by your fundamental rights and freedoms.
• Consent: For certain activities, such as sending you marketing communications or using your data for research, we will obtain your explicit consent before processing your personal data. You have the right to withdraw your consent at any time.

4. How We Share Your Information

4.1 Sharing with Third-Party Service Providers: We may share your information with trusted third-party service providers who assist us in operating our business and providing the Services. These service providers have access to your personal information only to perform specific tasks on our behalf and are obligated not to disclose or use it for any other purpose. This includes:

• Payment Processors: We use Stripe to process payments. We do not store your full payment card information on our servers. Stripe’s privacy policy can be found at https://stripe.com/au/privacy.
• Cloud Storage Provider: We use Google Firebase/Firestore to securely store and sync your data. Google’s privacy policy can be found at https://policies.google.com/privacy.
• Email Service Provider: We use Postmark to send transactional and marketing emails. Postmark’s privacy policy can be found at https://postmarkapp.com/privacy-policy.
• Other Service Providers: We may use other service providers for purposes such as web hosting, data analysis, marketing, and customer service. We will always ensure that these providers have appropriate data protection measures in place.

4.2 Sharing with Research Partners: If you consent to participate in research, we may share your anonymized and aggregated data with research partners. This data will not contain any personal information that could identify you.

4.3 Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

4.4 Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to:

• Comply with a legal obligation.
• Protect and defend the rights or property of The Tattoo Pathway.
• Prevent or investigate possible wrongdoing in connection with the Services.
• Protect the personal safety of users of the Services or the public.

4.5 Aggregate Information: We may share aggregated or de-identified information that does not directly identify you with third parties for various purposes, such as analytics, research,

5. Your Choices and Rights

5.1 Accessing and Controlling Your Personal Information: You have the right to access, correct, update, or request deletion of your personal information. You can do this by:

• Logging into your account: You can directly access and manage most of your personal information within your account settings.
• Contacting us: If you are unable to access or update your information through your account, you can contact us at support@tattoopathway.com to request assistance.

5.2 Marketing Communications: You can opt out of receiving promotional emails from us by following the unsubscribe instructions included in these emails or by contacting us at support@tattoopathway.com. Please note that even if you opt out of receiving marketing emails, we may still send you non-promotional communications, such as emails about your account or our ongoing business relationship.

5.3 App Preferences: Within the App, you can manage your preferences for data syncing and other app-specific settings.

5.4 Your Rights Under the General Data Protection Regulation (GDPR): If you are a resident of the European Union, you have the following rights under the GDPR:

• Right to be Informed: You have the right to be informed about how your personal data is being collected, used, and shared.
• Right of Access: You have the right to request access to your personal data and to receive a copy of it in a structured, commonly used, and machine-readable format.
• Right to Rectification: You have the right to have your personal data corrected if it is inaccurate or incomplete.
• Right to Erasure: You have the right to request the deletion or removal of your personal data under certain circumstances.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
• Right to Data Portability: You have the right to request that we transfer your personal data to another organization or to you in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data under certain circumstances.
• Right not to be subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

To exercise any of these rights, please contact us at support@tattoopathway.com.

5.5 Your Rights Under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA): If you are a California resident, you have the following rights under the CCPA and CPRA:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we collect about you, the categories of sources from which we collected your personal information, our business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share your personal information.
• Right to Delete: You have the right to request that we delete any personal information we have collected from you.
• Right to Opt-Out of Sale: You have the right to opt out of the sale of your personal information. We do not sell your personal information.
• Non-Discrimination: You have the right not to be discriminated against for exercising any of these rights.

To exercise any of these rights, please contact us at support@tattoopathway.com

6. Data Security

6.1 Security Measures: We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: We use industry-standard encryption protocols, such as SSL/TLS, to secure data transmission between your device and our servers.
• Secure Storage: Your data is stored on secure servers with restricted access and regular backups.
• Access Controls: We limit access to your personal information to authorized employees and contractors who need to know that information to operate, develop, or improve our Services.
• Regular Security Assessments: We conduct periodic security assessments to identify and address vulnerabilities.

6.2 No Guarantee of Security: While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. No method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.

6.3 Your Responsibility: You also play a role in protecting your personal information. You should choose a strong password for your account and avoid using the same password for multiple online accounts. You should also be careful about sharing your personal information online.

7. Data Retention

7.1 Retention Period: We will retain your personal information for as long as your account is active or as needed to provide you with the Services. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7.2 Deletion of Data: If you wish to delete your account or request that we delete your personal information, you can do so by contacting us at support@tattoopathway.com. We will make reasonable efforts to delete your information from our records, but please note that some residual information may remain in our backup systems or for legal purposes.

7.3 Anonymized Data: We may retain and use anonymized and aggregated data derived from your personal information indefinitely for research and statistical purposes. This data does not identify you personally and cannot be used to track you.

8. Children’s Privacy

8.1 We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through the Services. If we learn that we have collected personal information from a child under the age of 13 without verification of parental consent, we will take steps to delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at support@tattoopathway.com.

8.2 If you are a resident of the European Union and under the age of 16, you confirm that you have obtained parental consent before creating an account and using the Services.

9. International Data Transfers

9.1 Your personal information 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 from those in your jurisdiction.

9.2 Specifically, we may transfer your data, including Personal Data, to Australia and process it there. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

9.3 If you are a resident of the European Union, please note that we may transfer your personal data to countries outside the European Economic Area (EEA). These countries may not have data protection laws that are as comprehensive as those in the EEA. However, we will only transfer your data to countries that have been deemed to provide an adequate level of protection by the European Commission, or we will ensure that appropriate safeguards are in place to protect your personal information, such as Standard Contractual Clauses.

10. Changes to this Privacy Policy

10.1 We reserve the right to update or modify this Privacy Policy at any time and for any reason, at our sole discretion. We will notify you of any changes by posting the new Privacy Policy on the Website and/or through a notification within the App.

10.2 It is your responsibility to review this Privacy Policy periodically for any changes. Your continued use of the Services following the posting of any changes to this Privacy Policy constitutes acceptance of those changes, we will provide you with additional notice (such as adding a statement to our homepage or sending you an email notification) before the changes become effective.

11. Contact Us

11.1 If you have, please contact us by email at support@tattoopathway.com