PRIVACY POLICY

1. Introduction

At tombillips.com (“we”, “our”, or “us”), we value your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website and interact with our services. Our practices are grounded in a commitment to strict data protection standards in accordance with the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

Your trust is important to us, and we strive to implement data handling policies that respect the rights of users while ensuring transparent and secure data processing.

2. Scope of This Policy and Data Controller Role

This Privacy Policy applies to users of the tombillips.com website and to all personal data we collect or process through the site, including through forms, accounts, transactions, and other interactions. For purposes of data protection laws, the data controller responsible for your information is tombillips.com.

Should you have any questions or concerns regarding how we process your data, you may contact us at [email protected].

3. Categories of Personal Data We Process

We may collect and process the following categories of personal data:

– Usage Data: Includes information about how you use our website, including your IP address, browser type, geographic location, access times, referring URLs, pages viewed, and interaction metrics.

– Account Data: Information provided during account registration or updates, such as your full name, address, email address, and telephone number.

– Profile Data: Includes your communication preferences, purchasing behavior, product or service interests, and feedback submitted through our platform.

– Communication Data: Includes the content of correspondence sent to tombillips.com, including support requests, inquiries, responses to surveys, and direct messages exchanged via our contact forms or email.

– Technical Data: Data collected from your device or browser, including hardware identifiers, operating system details, device configurations, and diagnostic logs.

– Transaction Data: Details regarding purchases made through the site, including billing addresses, order history, payment method (excluding full payment card numbers), and shipment tracking data.

– Preference Data: Information related to your choices regarding marketing communications, newsletters, and product preferences or usage trends.

4. Legal Bases for Data Processing

We process your personal data under the following lawful bases recognized by the GDPR:

– Consent: When you provide explicit consent to receive newsletters, marketing communications, or allow the placement of non-essential cookies.

– Contractual Necessity: When processing is required for the performance of a contract to which you are a party, such as completing a product order or managing your tombillips.com account.

– Legal Obligation: Where processing is necessary to comply with a legal or regulatory requirement.

– Legitimate Interests: For purposes such as fraud detection, service improvement, analytics, or to ensure the security and performance of our website—provided these interests do not override your rights and freedoms.

5. Your Rights

As a data subject under the GDPR and CCPA, you have the following rights concerning your personal data:

– Right of Access: You have the right to request a copy of the personal data we hold about you.

– Right to Rectification: You may request correction of inaccurate or incomplete information.

– Right to Erasure: You may request deletion of your data when retention is no longer necessary, except where we are legally obliged to retain it.

– Right to Restriction of Processing: You have the right to limit how we use your data under certain conditions.

– Right to Data Portability: Upon request, we will provide your personal data in a structured, commonly used, and machine-readable format.

– Right to Object: You may object to our processing of your data when based on legitimate interests or for direct marketing purposes.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request in accordance with applicable legal requirements and within lawful timeframes.

6. Security Measures

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, misuse, disclosure, alteration, or destruction. These include:

– Data encryption both in transit and at rest
– Firewalls and intrusion detection systems
– Role-based access control and secure login credentials
– Periodic backups and disaster recovery planning
– Staff training on data security and confidentiality

While no system can fully guarantee security, we are committed to continuously monitoring and improving our safeguards.

7. International Data Transfers

Due to the nature of the Internet and business operations, your personal data may be transferred to, and processed in, countries outside of your jurisdiction, including regions that may not afford the same level of data protection. Where such transfers occur, we ensure appropriate data protection measures are in place, including Standard Contractual Clauses approved by the European Commission, or reliance on adequacy decisions when applicable.

8. Data Retention

We retain your data only for as long as necessary for the purposes described in this policy, or as required by law. Our standard retention periods are as follows:

– Usage and Technical Data: 12 months
– Account and Profile Data: While account remains active, and for 6 years following closure
– Communication Data: 3 years
– Transaction Data: 7 years (for tax/legal compliance)
– Preference Data: Until consent is withdrawn or 2 years of inactivity

After these periods, data will be securely deleted or anonymized.

9. Cookie Policy

Our website uses cookies and similar technologies to enhance your experience. Cookies fall into the following categories:

– Essential Cookies: Necessary for core site functionality such as navigation and access to secure areas.

– Functional Cookies: Enable preference storage and enhance usability.

– Analytics Cookies: Help us understand how users interact with the site, including page visits and error tracking.

– Performance Cookies: Collect aggregate data to improve site load times and user responsiveness.

For a detailed breakdown of the specific cookies used on tombillips.com, or to view our full cookie declaration, please refer to our Cookie Management page.

10. Cookie Management in Compliance with GDPR & CCPA

By visiting tombillips.com, you are presented with a cookie banner allowing you to manage your preferences. You may choose to allow all cookies, reject non-essential cookies, or customize your selections.

You may also change your cookie settings at any time via your browser or visiting our Cookie Preferences Center. We comply with applicable legal obligations regarding cookie consents, including prior opt-in for EU visitors and “Do Not Sell My Info” provisions for California residents.

11. Children’s Privacy

Our services are not intended for children under the age of 13. We do not knowingly collect or process personal data from children. If we become aware that data belonging to a person under 13 has been collected without verifiable parental consent, we will take steps to delete that information immediately.

12. Policy Updates

We may revise this Privacy Policy from time to time to reflect changes in data practices, legislation, or technical developments. Updated versions will be posted on tombillips.com, and may be communicated to you directly if applicable. Your continued use of our services following changes indicates acceptance of the updated policy.

13. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact us via:

Email: [email protected]

We are committed to ensuring your data protection rights are respected at all times. Our privacy practices align with the requirements of the GDPR and CCPA. If you believe your privacy rights have been violated, please contact us, and we will take prompt action to resolve the matter.

Thank you for trusting tombillips.com.