ONLINE PRIVACY NOTICE
Effective as of October 2, 2023
This privacy policy (the “Privacy Policy”) applies to the information collection and
use practices of our online services, which are made available to you through a variety of
platforms, such as through the Collective615 mobile application (the "App"), our website
located at www.collective615.com (the "Site"), and through our social media accounts on
Instagram and Facebook, and LinkedIn (collectively, "Social Media"), all owned and
operated by Collective615 LLC, a Tennessee limited liability company ("Collective615,"
"we," "us," or "our"). The App, the Site, and our Social Media accounts are collectively
referred to as the "Platform." We have created this Privacy Policy to tell you what
information the Platform collects, how we use that information, and who we will share that
information with, if at all. This Privacy Policy does not address the privacy practices of
any third parties that we do not own, control, or are affiliated with. Capitalized terms not
defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By
visiting and/or using our Platform, you are agreeing to the terms of this Privacy Policy and
the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to
use the information it contains to help you make informed decisions.
TYPE OF INFORMATION WE COLLECT OR RECEIVE
In the course signing up for our services or purchasing products on our Site or
operating the App, we will collect and/or receive the following types of information. You
authorize us to collect and/or receive such information.
(a) Personal Identification Information. We only receive or collect information
that identifies you personally. When you sign up to become a user or contact us, you will
be required to provide us with personal information about yourself (collectively, the
"Personal Information"). Such Personal Information may include your name, e-mail
address, physical address, and phone number. When you visit our website or App, your
IP address is automatically received and stored by servers. We do not collect any
Personal Information from you when you use the App unless you provide us with the
Personal Information voluntarily.
(b) Third-party Log In. If you register or visit the App through an email service
provider, Facebook Connect, or another social media website, you are authorizing us to
collect, store, and use, in accordance with this Privacy Policy, any and all information that
you agreed that the social media website would provide to us through its Application
Programming Interface ("API"). We do not receive or store your passwords for your social
media accounts.
(c) Payment Information. If you choose to make a purchase or subscribe to a
feature or service ours that requires a fee, you will be required to provide us with your
payment information, including, without limitation, bank account numbers, credit card or
debit card numbers, cardholder names, billing address, account details, ACH information,
and similar data (collectively, "Payment Information"). Such Payment Information will be
collected and processed by our third-party payment vendors pursuant to the terms and
conditions of their privacy policies and terms of use, and we do not obtain access to any
Payment Information in connection with such purchases or subscriptions.
(d) Geolocational Information. Certain features and functionalities of the App
are based on your location. In order to provide these features and functionalities while
you are using your mobile device, we may, with your consent, automatically collect
geolocational information from your mobile device or wireless carrier and/or certain third-
party service providers (collectively, "Geolocational Information"). Collection of such
Geolocational Information occurs only when the App is running on your device. You may
decline to allow us to collect such Geolocational Information, in which case we will not be
able to provide certain features or functionalities to you.
(e) Third-Party Analytics. Information you choose to share with our company
may be treated as public information. We and the third-party technology providers, ad
exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which
we work use third-party analytics services (e.g., Google Analytics) to evaluate your use
of the App, compile reports on activity, collect demographic data, analyze performance
metrics, and collect and evaluate other information relating to the App and mobile and
Internet usage. These third parties use cookies and other technologies to help analyze
and provide us the data. The third-party analytics provider does not receive personally
identifiable information through the use of cookies. We have also limited the provider’s
ability to see your full IP address.
You consent to the processing of data about you by these analytics providers in
the manner and for the purposes set out in this Privacy Policy. For more information on
these third parties, including how to opt out from certain data collection, please visit
[URLs]. Please be advised that if you opt out of any such service, you may not be able to
use the full functionality of the App.
(f) Other Information. In addition to the Personal Information, Payment
Information, and Geolocational Information, we may automatically collect or receive
additional information regarding you and your use of the App; your interactions with us
and our advertising; and information regarding your computer and mobile devices used
to access the App (collectively, the "Other Information"). Such Other Information may
include:
(i) From You. Additional information about yourself that you voluntarily
provide to us, such as your gender and your product and service
preferences.
(ii) From Your Activity. We may collect or receive information regarding:
(A) IP address, which may consist of a static or dynamic IP
address and will sometimes point to a specific identifiable computer
or mobile device;
(B) browser type and language;
(C) referring and exit pages and URLs;
(D) date and time; and
(E) details regarding your activity on the App, such as search
queries and other performance and usage data.
(iii) About Your Mobile Device. We may collect or receive information
regarding:
(A) type of mobile device;
(B) advertising Identifier ("IDFA" or "AdID");
(C) operating system and version (e.g., iOS, Android or
Windows);
(D) carrier; and
(E) network type (WiFi, 3G, 4G, LTE).
(iv) From Cookies. A cookie is a file containing an identifier (a string of
letters and numbers) that is sent by a web server to a web browser
and is stored by the browser. The identifier is then sent back to the
server each time the browser requests a page from the server. When
you visit the Site or the App, we may send cookies or other similar
tracking technologies to your computer or to any other device you
use. We use cookies and similar tracking technologies to track your
preferences and to know how you use our services. We may use
both session cookies, which expire once you close the App, and
persistent cookies, which stay on your mobile device until you delete
them and other technologies to help us collect data and to enhance
your experience with the App. Cookies are small text files an app can
use to recognize a repeat visitor to the app. We may use cookies for
various purposes, including to:
(A) type of mobile device;
(B) personalize your experience;
(C) analyze which portions of the App are visited and used
most frequently; and
(D) measure and optimize advertising and promotional
effectiveness.
If you do not want us to deploy cookies in the App, you can opt out by setting your
mobile device to reject cookies. You can still use the App if you choose to disable cookies,
although your ability to use some of the features may be affected or result in its blocking.
For further information visit allaboutcookies.org
Cookies are used for user
identification and proper assignment of historical user data collected during previous
visits.
COOKIE POLICY
As described above, we use your personal information and data to provide you
with targeted advertisements or marketing communications we believe may be of
interest to you. For example:
(a) We may use Google Analytics to help us understand how our
customers use the Site. You can read more about how Google uses your Personal
Information here: https://www.google.com/intl/en/policies/privacy/. You can also
opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
(b) We may use a Facebook pixel on our website. Using the pixel,
Facebook collects information about the users and use of our website. The
information is used to personalize Facebook advertisements and to analyze the
use of our website. To find out more about the Facebook pixel and about
Facebook's use of personal data generally, see the Facebook cookie policy at
https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at
https://www.facebook.com/about/privacy. The Facebook cookie policy includes
information about controlling Facebook's use of cookies to show you
advertisements. If you are a registered Facebook user, you can adjust how
advertisements are targeted by following the instructions at
https://www.facebook.com/help/568137493302217.
(c) We may publish Google AdSense advertisements on our website,
together with advertisements from advertisers and advertising networks that are
distributed by Google. The advertisements may be personalized to reflect your
interests. Google and its partners use cookies to help determine your interests.
You can opt out of Google's personalized advertising by visiting
https://www.google.com/settings/ads and you can opt out of third party cookies
used for personalized advertising by visiting http://www.aboutads.info. You can
review Google's privacy policy at https://policies.google.com/privacy.
(d) We may share information about your use of the Site, your
purchases, and your interaction with our ads on other websites with our advertising
partners. We collect and share some of this information directly with our advertising
partners, and in some cases through the use of cookies or other similar
technologies.
For more information about how targeted advertising works, you can visit the
Network Advertising Initiative’s (“NAI”) educational page at
https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://adssettings.google.com/authenticated
Additionally, you can opt out of some of these services by visiting the Digital Advertising
Alliance’s opt-out portal at: https://optout.aboutads.info/.
We can use different type of cookie or tracking technologies while you are visiting
our website and/or application:
(a) Strictly necessary cookies: These types of cookies enable you to access
and browse websites and use their features. Without these cookies,
services like billing or shopping baskets cannot work properly.
(b) Performance cookies: These cookies collect information and data about
how you use our websites and/or application. The data collected can be
used to optimize our websites and/or applications. These cookies are
used to know where our visitors and users are coming from. These
cookies do not collect information that identifies you personally.
(c) Functionality cookies: These cookies allow our website or application to
remember your choices. They can be used to memorize your
localization, or your preferences such as language settings or font size.
You can set your browser not to accept cookies and the above website and/or
application tells you how to remove cookies from your browser. However, some of our
websites and/or applications might not work properly without the use of cookies.
Here are some of the main explanation on how to delete cookies on your browser:
CHROME https://support.google.com/chrome/answer/95647
FIREFOX https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-
website-preferences
OPERA - https://help.opera.com/en/latest/security-and-privacy/
INTERNET EXPLORER - https://support.microsoft.com/en-
gb/help/17442/windows-internet-explorer-delete-manage-cookies
SAFARI - https://support.apple.com/en-gb/guide/safari/manage-cookies-and-
website-data-sfri11471/mac
EDGE - https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-
privacy
For mobile devices, if you don’t want to receive targeted advertising based on your
center of interest coming from a mobile application, please check the parameters of the
operating system of your mobile device and follow these instructions: 1) iOS Users: to
enable “Limited Ad Tracking” follow the instructions given by Apple. 2) Android Users: to
enable the option “deactivate ad personalization”, follow the instructions given by Google
on Google Play. 3) You might want to download the DAA mobile AppChoices application
to control behavioral advertising online.
HOW DATA IS COLLECTED
(a) You provide us with most of the data we collect. We collect data and process
personal data and information when (1) you register online or use services online or (2)
use the website or application when cookies are set on your device.
(b) Our company might also receive data and information indirectly from the
following sources:
Flurry (https://www.flurry.com)
Firebase (https://www.firebase.google.com)
Count.ly (https://count.ly)
AppsFlyer (https://www.appsflyer.com)
Facebook App Event (https://developers.facebook/coom/docs/app-events)
(c) We may share Other Information about your activity on the App with third
parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e.,
behavioral, contextual, retargeting, analyzing, managing, reporting, and optimizing of
ads). These third parties may use cookies, pixel tags (also called web beacons or clear
gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags
enable us and these third-party advertising companies to recognize a browser's cookie
when a browser visits the site on which the pixel tag is located in order to learn which
advertisement brings a user to a given site. In addition, we may receive Other Information
from advertisers and/or their service providers such as advertising identifiers, IP
addresses, and post-conversion data.
HOW TO OPT OUT OF THIRD-PARTY INTEREST-BASED ADVERTISING
If you wish to opt out of third-party interest-based advertising, please visit
http://www.networkadvertising.org and http://www.aboutads.info/choices for details on
how to do so. Additionally, users of mobile Devices can follow the below instructions:
Android Users: For Android devices with OS 2.2 and up and Google Play Services
version 4.0 and up: Open your Google Settings app & go to; Ads & go to; Enable "Opt out
of interest-based advertising."
iOS Users: iOS 7 or Higher: Go to your Settings & go to; Select Privacy & go to;
Select Advertising & go to; Enable the "Limit Ad Tracking" setting.
iOS 6: Go to your Settings & go to; Select General & go to; Select About
& go to; Select Advertising & go to; Enable the "Limit Ads Tracking"
setting.
HOW INFORMATION IS USED AND SHARED
(a) You authorize us to use the Personal Information, Payment Information,
Geolocational Information, and the Other Information (collectively, the "Information") to:
(i) provide and improve our App;
(ii) provide our services;
(iii) administer our promotional programs;
(iv) solicit your feedback; and
(v) inform you about our products and services.
(b) Within our company we restrict access to personally identifiable information to
employees, contactors, and vendors, subject to non-disclosure requirements who require
access to information in order to perform their official duties and exercise controls to limit
what data they can view based on the specific needs of their position.
(c) In order to provide our services and administer our promotional programs, we
may share the Information with our third-party promotional and marketing partners,
including, without limitation, businesses participating in our various programs.
(d) We engage third-party companies and individuals to perform functions on our
behalf. Examples may include providing technical assistance, customer service,
marketing assistance, and administration of promotional programs. These other
companies will have access to the Information only as necessary to perform their
functions and to the extent permitted by law
(e) In an ongoing effort to better understand our users, the App, and our products
and services, we may analyze certain Information in anonymized and aggregate form to
operate, maintain, manage, and improve the App and/or such products and services. This
aggregate information does not identify you personally. We may share and/or license this
aggregate data to our affiliates, agents, business and promotional partners, and other
third parties. We may also disclose aggregated user statistics to describe the App and
these products and services to current and prospective business partners and investors
and to other third parties for other lawful purposes.
(f) We may share some or all of your Information with any of our parent companies,
subsidiaries, joint ventures, or other companies under common control with us.
(g) As we develop our businesses, we might sell or buy businesses or assets. In
the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar
event, the Information may be part of the transferred assets.
(h) To the extent permitted by law, we may also disclose the Information:
(i) when required by law, court order, or other government or law
enforcement authority or regulatory agency; or
(ii) whenever we believe that disclosing such Information is necessary or
advisable, for example, to protect the rights, property, or safety of us or
others, including you.
ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION
PREFERENCES
If you have provided us any Personal Information, you may access, remove,
review, and/or make changes to the same by contacting us as set forth below. In addition,
you may manage your receipt of marketing and non-transactional communications by
clicking on the "unsubscribe" link located on the bottom of any of our marketing e-mails.
We will use commercially reasonable efforts to process such requests in a timely manner.
You should be aware, however, that it is not always possible to completely remove or
modify information in our subscription databases. You cannot opt out of receiving
transactional e-mails related to the App (e.g., requests for support).
We may also deliver notifications to your mobile device (e.g., push notifications).
You can disable these notifications by deleting the relevant service or by changing the
settings on your mobile device.
HOW WE PROTECT YOUR INFORMATION
We take commercially reasonable steps to protect the Information from loss,
misuse, and unauthorized access, disclosure, alteration, or destruction.
Our company uses commonly used practices and technical controls to protect the
information in our possession or control. These practices and controls include, but are not
limited to, encrypting the transfer of personal information over the internet, using firewalls
and intrusion detection systems and maintaining strict technical controls and procedures
to ensure data integrity.
We periodically review our processes and systems to verify compliance with
industry best practices and to ensure the highest level of security for our website.
Please understand, however, that no security system is impenetrable. We cannot
guarantee the security of our databases or the databases of the third parties with which
we may share such Information, nor can we guarantee that the Information you supply
will not be intercepted while being transmitted over the Internet. In particular, e-mail sent
to us may not be secure, and you should therefore take special care in deciding what
information you send to us via e-mail.
IMPORTANT NOTICES TO NON-U.S. RESIDENTS
The App is operated in the United States and its servers are operated in France.
If you are located outside of the United States, please be aware that your Information,
including your Personal Information, may be transferred to, processed, maintained, and
used on computers, servers, and systems located outside of your state, province, country,
or other governmental jurisdiction where the privacy laws may not be as protective as
those in your jurisdiction. If you are located outside the United States and choose to use
the App, you hereby irrevocably and unconditionally consent to such transfer, processing,
and use in the United States and elsewhere.
APP STORES; EXTERNAL WEBSITES
Your app store (e.g., iTunes or Google Play) may collect certain information in
connection with your use of the App, such as Personal Information, Payment Information,
Geolocational Information, and other usage-based data. We have no control over the
collection of such information by a third-party app store, and any such collection or use
will be subject to that third party's applicable privacy policies.
The App may contain links to third-party websites. We have no control over the
privacy practices or the content of these websites. As such, we are not responsible for
the content or the privacy policies of those third-party websites. You should check the
applicable third-party privacy policy and terms of use when visiting any other websites.
CHILDREN
The App is not directed to children under the age of 18. We adhere to the Children's
Online Privacy Protection Act (COPPA) and will not knowingly collect Personal
Information from any child under the age of 13. We ask that minors (under the age of 18)
not use the App. If a child under the age of 18 has provided us with Personal Information,
a parent or guardian of that child may contact us and request that such information be
deleted from our records.
CALIFORNIA PRIVACY RIGHTS: SHINE THE LIGHT LAW
Under California Civil Code Section 1798.83, California residents who have an
established business relationship with us may choose to opt out of our sharing their
contact information with third parties for direct marketing purposes. If you are a California
resident and you wish to opt out, please send an e-mail to connect@collective615.com.
CALIFORNIA PRIVACY LAW: DO NOT TRACK
We do not monitor, recognize, or honor any opt-out or do not track mechanisms,
including general web browser "Do Not Track" settings and/or signals.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.
We may change this Privacy Policy from time to time. Any such changes will be posted
on the Site and the App. By accessing the Site and/or App after we make any such
changes to this Privacy Policy, you are deemed to have accepted such changes. Please
be aware that, to the extent permitted by applicable law, our use of the Information is
governed by the Privacy Policy in effect at the time we collect the Information. Please
refer back to this Privacy Policy on a regular basis.
DATA PROTECTION RIGHTS AND HOW TO CONTACT US
(a) Our company would like to make sure you are fully aware of all your data
protection rights. Every user has, if applicable, the right to:
(i) The right to access: you have the right to request our company for
copies of your personal data.
(ii) The right to rectification: you have the right to request that our
company corrects any information you believe is inaccurate or
mistaken. You also have the right to request our company to
complete information you believe is incomplete.
(iii) The right to erasure: you have the right to request that our company
erase your personal data under certain conditions.
(iv) The right to restrict processing: you have the right to request that
our company restricts the processing of your personal data under
certain conditions.
(v) The right to object to processing: you have the right to object to our
company’s processing of personal data under certain conditions.
(vi) The right to data portability: you have the right to request that our
company transfers the data we have collected to another
organization or directly to you under certain conditions.
(b) If you have questions about this Privacy Policy, please e-mail us at
connect@collective615.com with "Privacy Policy" in the subject line.