Touch Grass, llc

Effective Date: [March 31], 2025

Last Updated: [March 31], 2025

 

This privacy policy (this “Privacy Policy”) describes how Touch Grass, LLC, a Michigan limited liability company, and its affiliates (collectively, "Company," "we," or "us") collect and process personal information in relation to your use of our mobile application, website [app.touch-grass.com], and related services (collectively, the "Services"). If you do not agree to this Privacy Policy, your choice is to not utilize our Services or provide personal information in connection with them. By utilizing our Services, you agree to this Privacy Policy and expressly consent to the processing of personal information according to this Privacy Policy.

 

Depending on where you live, a supplemental privacy notice may also apply to you. Please review the supplemental privacy notice describing how we process personal information for residents of Europe, UK, and Canada.

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    1.Personal Information We Collect.

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Information You Choose to Give Us

• Contact information, including name, employer name, address, city, state, zip code, email address, and telephone number.

• Demographic information you choose to give us, including your age and gender.

• User contributions when you post on our Services or communicate with other users of our Services.

• Information provided or accessed in connection with the Services we provide, including online forms, account information, survey responses, and communications with our online support team.

• Payment information to complete purchase transactions.

• Precise geolocation, when you check in to certain locations.

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Information Automatically Collected by Using Our Website

• Your device data and how you interact with our website, including IP address, browser type, general location, and unique device identifier.

• Usage information, including the pages or content you view and searches on our website.

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Categories of Sensitive Personal Information

• Debit card, or credit card number in combination with any required security or access code, password, or credentials to facilitate your subscription for the Services.

• Precise geolocation information, when you check in at certain locations.

 

    2. How We Use Information We Collect. We may process this information to:

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•  Fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a subscription to our Services, we will use that information to process your payment and facilitate access. We may also save your information for these purposes. 

• Provide, personalize, and develop your account on our Services, including logging your engagement with our community and maintaining your points for engaging in certain tasks.

• Process your requests, purchases, transactions, and payments and prevent transactional fraud.

• Provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• Help maintain the safety, security, and integrity of our Services, databases, and other technology assets.

• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

• Send promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

• Personalize, measure, and improve our advertising to you.

• Fulfill any other use that we describe when you provide the information.

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Please note that we may anonymize or reasonably deidentify your personal information so that it can no longer be reasonably associated with or used to identify you in some circumstances. We may retain and use such information for any legitimate business purpose without further notice to you or obtaining your consent, unless required by law. 

 

    3. Disclosing, Sharing, and Selling Information.

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    a. Disclosing Personal Information

 

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

 

We disclose personal information as stated below:

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• with data analytics, software/IT, cybersecurity, cloud service, consultants, financial, legal, and other similar providers that support our business.

• with banks and credit card processors to the extent necessary for Company to deliver the services. 

• when we display your username to other users of the Services.

• when we believe sharing is necessary to protect our rights, preserve safety, investigate fraud or other wrongdoing.

• when required by law, which includes complying with any court order, law, or legal process, including responding to a government or regulatory request.

• in connection with the sale, transfer or financing of Company’s business or its assets, including a bankruptcy proceeding or to our affiliates.  

• to enforce or apply our agreements, including for billing or collection purposes.

• for any other purpose we disclose to you when you provide the information.

 

    b. Sharing Personal Information for Personalized Advertising

 

Company shares personal information with trusted third-party marketing partners to deliver personalized advertisements tailored to your interests, helping you discover products and services that align with your preferences. This information may include device identifiers, IP address, browser type, website usage and referring URLs, purchase activity, and geolocation information.

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    c. Selling Personal Information 

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In the preceding twelve (12) months, Company has not sold personal information to any third parties and does not sell personal information pertaining to minors under the age of sixteen (16).

 

    4. Information Security and Retention.

We use reasonable administrative, technical, and physical security measures to protect the personal information we retain and to help ensure that it is used in accordance with this Privacy Policy.  

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless longer retention is required by law or for auditing purposes. To determine the appropriate retention period for personal information, we consider applicable laws, the volume and nature of the personal information, its purpose, and the potential risk of harm from its unauthorized use or disclosure.

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    5. Cookies and Tracking Technologies.

 

    a. Cookies

Our Services may use “cookies” and other tracking technologies to gather information about your interactions.  This information may include demographic data, browser type, IP address, pages visited, activities conducted on the page, and the day and time of your visit. Our websites may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to make your experience on the website more personal and interactive. We do not currently honor “do not track” signals from a web site browser. Please refer to your computer browser help instructions for more information on cookies and other related technologies and how to manage their use. If you refuse or delete cookies, you will need to repeat the process if you use another computer or change browsers. If you refuse or delete cookies, some of the functionality of our Services could potentially be impaired.  

    b. Analytics Services

Please note that we use an analytics service, Google Analytics, to gather information about our website visits. To learn more about Google Analytics, including opting out of Google Analytics, click here  https://tools.google.com/dlpage/gaoptout?hl=en

    c. Web Beacons

Pages of our websites may also contain small electronic files known as web beacons [BAL5] [TD6] (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us, for example, to count users who have visited those pages.  We may use this information to provide a better website user experience, and tailor our marketing communications. 

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    6. Other Important Information.

 

    a. Linked Websites

Our websites may contain links to other websites. We assume no responsibility for the content, privacy policies, or practices of any third-party websites.  You expressly relieve Company from any and all liability arising from your use of any third-party website, or from the content of any third-party website.

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    b. Children's Privacy

Our website does not target or knowingly collect any information from individuals under the age of eighteen (18).

   

    c. Changes to our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notification that the Privacy Policy has been updated on our website home pages. If we make material changes to how we treat the personal information we collect, we will notify you through a prominent notice on our website home pages, in addition to any other means necessary to fulfill our legal requirements. The date the Privacy Policy was last revised is identified at the top of the page. 

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     7. Contact Information.

For questions regarding this Privacy Policy, you may contact us at any of the following addresses. To exercise your consumer rights, depending on where you live, please follow the instructions provided in the supplemental privacy notice, under the "Exercising Your Rights" section.

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Email:                [Hello@touch-grass.com]

Address:             [STREET ADDRESS]
                          [CITY, STATE ZIP]

Phone:               [PHONE NUMBER]

 

 

Canada, EEA, and UK Supplemental Notice

This supplemental privacy policy (this "Supplemental Notice") provides Canada, European Economic Area ("EEA") and United Kingdom (“UK”) individuals additional information required by the Canadian privacy laws, EU General Data Protection Regulation and UK General Data Protection Regulation. These provisions, together with the statements in the above general Privacy Policy ("Privacy Policy"), set forth our practices and reasons for processing your personal information with regard to Canada, EEA and UK personal data. For Canada, EEA and UK individuals, if there is a conflict between this Supplemental Notice and the Privacy Policy, this Supplemental Notice governs. Certain capitalized terms used but not defined in this Supplemental Notice shall have the meanings set forth in our Privacy Policy. 

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Contact information:

Please contact the Company with any questions or to access any rights detailed below.

Data Protection Officer:         Tijana Dau 

Email:                                 [tijana@touch-grass.com]

Address:                              [ADDRESS]

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Legal basis and purposes for data processing:

We only process personal information when we have a legal basis for the processing or have your consent to do so. We may also process your personal information for the purposes of our own legitimate interests or for the legitimate interests of others so long as that processing does not outweigh your rights and freedoms. Specifically, we will only process your personal information in connection with one or more of the following bases:

• With your consent. 

• For the reason you provided it to us, including to provide any services requested or evaluate your employment candidacy.

• To further our legitimate interests, such as performing or marketing our services or preventing fraud. 

• To perform a contract between you and us.

• To satisfy an applicable legal requirement. 

• To serve the public interest, such as processing in response to a governmental request. 

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Automated decision making and profiling:

We do not make automated decisions about you or engage in data profiling.

 

Personal information requirements:

To engage with our services, website, or applications, you may be required to provide certain personal information to enable us to perform the services. Over the course of your relationship with the Company, you will be provided with information regarding which data elements are required.

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Your rights:

As a resident of the EEA or UK, you have choices regarding how we use your personal information. You are entitled to:

 

• The right to access: You have the right to request copies of your personal information.  We may charge you a minor fee for this service.

• The right to rectification: You have the right to request that we correct any information that you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete.

• The right to erasure: You have the right to request that we erase your personal information under certain conditions.

• The right to object to processing: You have the right to object to our processing of your personal information, under certain conditions. You may also decline our marketing communications.

• The right to data portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

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In addition, when we provide services or act as a data processor, we may receive your personal information from third parties as needed to provide our services. If we are processing your personal information as a data processor, we will refer you to our client for assistance with these requests. We support our clients with responding to requests as required by law.

 

To exercise these rights, please contact us at the email or mailing address above. Note that for your protection, we may need to verify your identity before we can process your request. If you believe that we have violated applicable law in our processing of your personal information, please contact us at [hello@touch-grass.com] or contact a supervisory authority.

 

International Transfers:                                                                                 

Our company is based in the United States.  Your personal information may be transferred to, stored at, or processed in the United States, or other countries that may not have equivalent privacy or data protection laws.  By using our website, applications, and/or services, you understand and agree to these processing terms.  We generally use approved EU and UK Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the EEA and UK.

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