Privacy Policy

Introduction

Tozny, LLC (“Tozny”), a technology company based in Portland, Oregon (“Tozny,” “Us” or “We”) respects the privacy of our users (“you” or “users”) and is committed to protecting your privacy by complying with this Privacy Notice (“Notice”).

Personally identifiable information, or “PII”, is data that may be used to identify an individual person, such as email address, name, phone number, government ID number, physical address, etc.  This Notice describes the types of PII we may collect from you and/or that you or third parties may provide when visiting our websites or when using our products. It also explains how we collect, use, maintain, secure and share your PII.

Tozny’s E3DB technology and InnoVault service deliver secure and authorized PII sharing among multiple parties.  We take the privacy and security of the PII we manage very seriously.  Quite litertally, our business depends on it.

This Notice applies to information we collect:

  • On the tozny.com website;
  • On the innovault.io website;
  • Via Tozny libraries installed on your mobile device(s) on your computer or in your web service;
  • In email, text or other methods of electronic communication between you and Tozny or its services and/or messages to privacy@tozny.com ;
  • From mobile devices, computers, or web services in order to provide Tozny services; and
  • From third parties that submit your PII to Tozny services.

This Notice does not apply to:

  • Information collected offline or via other non-electronic methods;
  • Any information collected by third party websites, whether linked or not linked to tozny.com, innovault.io, or Tozny services.

Please read this Notice carefully.  If you do not agree with Tozny’s privacy practices, as described in this Notice, please do not use the Tozny services and do not provide personal information via Tozny websites, services, or applications.  Your use of Tozny websites, services and/or applications indicates your agreement with this Notice.

Use of Tozny Services by Children Under Age 13

Tozny does not knowingly collect PII from children under the age of 13, and children under 13 should not provide any PII via Tozny websites, services, or applications.  If you become aware or believe that we have collected PII from a child under 13, please notify us at privacy@tozny.com.  If we learn that we have inadvertently collected PII from children under 13 without verifiable parental consent, we will delete that information from our systems.

Personal Information We Collect and How We Collect It

We collect and store PII from users and third parties with whom users have consented to share their PII.  This PII may include, but is not limited to:

  • Name, email address, phone number, other contact information;
  • Desktop and/or mobile device IP address and information provided by tracking technologies such as cookies and website search queries;
  • Unique device identifiers such as push tokens from mobile operating systems;
    Physical address;
  • Records of your consent and access control for Tozny services;
  • User security keys, tokens or passwords; and
  • PII provided to Tozny services by third parties.

How we collect PII:

  • When you provide it to us directly via our websites (tozny.com and innovualt.io);
  • When you register for Tozny services;
  • When you communicate with us electronically via email or text;
  • When you download our applications to your mobile devices or computers;
  • Automatically via tracking technologies, such as cookies and website analytics, when you visit our websites.  Tracking technologies collect PII such as IP address and website usage details; and
  • When PII is uploaded to Tozny services by third parties.

Tozny only shares your PII when you provide us with express opt-in consent.  In other words, you are in control of your PII.

How We Use and Disclose Your Personal Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present Tozny websites and their contents to you;
  • To provide you with information and/or services that you request from us;
  • To fulfill any other purpose for which you provide it and consent to its use;
  • To provide you with notices about your account or subscription for services, including expiration and renewal notices;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to Tozny websites, this Notice, or any services or applications we offer;
  • To allow you to participate in interactive features on the Tozny website, services, or applications;
  • To allow Tozny service users to share your PII for uses to which you expressly consent;
  • In any other way we may describe when you provide the information; and
  • For any other purpose with your express consent.

We may also disclose your personal information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • To enforce or apply our Terms of Service and other agreements located at www.innovault.io/eula
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tozny, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About How We Use and Disclose Your Information

Tozny provides you choices regarding the PII you provide to us.  You may choose not to submit PII to Tozny, yet still access and use some parts of Tozny websites, services, and applications as follows:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at www.adobe.com.  If you disable or refuse cookies, please note that some parts of Tozny websites may then be inaccessible or not function properly.

  • We do not control third parties’ collection or use of your information to serve interest-based advertising. However, Tozny does contract with its business partners, requiring them to comply with Tozny’s Terms of Service for your information.  These third parties may also provide you with ways to opt-out of their data use and sharing practices.

Accessing and Correcting Your Information

You can review and change your personal information by logging into your Tozny services and visiting your account profile page.  Certain information may be designated by third parties with whom we do business as not subject to change or deletion.  In that case, Tozny does not control how the third party treats change or delete requests.

You may also send us an email at privacy@tozny.com to request access to, correct or delete any personal information that you or third parties have provided to us. We cannot delete all of your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your PII from Tozny services, copies of that information may remain viewable in cached and archived pages, or might have been copied or stored by third parties. We do not have control over all uses of your information by third parties with whom Tozny shares your PII per your opt-in consent.  Proper access and use of information provided via Tozny websites, services, or applications, including PII you enter, is governed by our Terms of Use located at www.innovault.io/eula.

Data Security

Protecting your data and privacy is the highest priority at Tozny.  Tozny strives to ensure user data is kept securely and only used with consent from the user.  To accomplish these aims, Tozny uses numerous methods for protecting your personal information from unauthorized access, use, alteration,  disclosure or accidental loss.  These include but are not limited to: segregation of data; encryption of communications with TLS; use of private keys that are never transmitted from the user device; firewalls; redundancy; regular vulnerability scans and audits.  Tozny surpasses expected industry standards in data security and is committed to the Identity Ecosystem Framework.

Tozny protects your private data, but the safety and security of your information also depends on you.  It is your responsibility to restrict direct access of your account to authorized persons only.   You should also be careful about giving out information in public areas of Tozny websites, services, or applications, like message boards. The information you choose to share in public areas may be viewed by any user.

Although Tozny uses its best efforts to protect your personal information, no method of transmission over the Internet and no method of electronic storage is perfectly secure. Tozny cannot guarantee absolute security and any transmission of personal information is at your own risk. Tozny is not responsible for unauthorized access, use, alteration, or disclosure of personal information because of circumvention of privacy settings or security measures in Tozny websites, services, or applications. If Tozny ever learns of a security breach, affected users will be notified promptly so that they can take appropriate protective steps.  Tozny may also provide reasonable remedies to mitigate the effects of a breach for its users.

Changes to the Privacy Policy

Tozny will post any changes we make to our Privacy Policy on this page. If we make substantial changes to how we collect, use, share or protect your personal information, we will notify you by email to the primary e-mail address specified in your account and/or through a notice on the Tozny websites’ homepages.  The date this Privacy Policy was last revised is identified at the top of this Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or mobile number for you, and for periodically visiting the Tozny websites and this Privacy Policy to check for any changes.

Contact Information

To ask questions, raise concerns or comment about this privacy policy and our privacy practices, contact us at:

privacy@tozny.com

or

Tozny LLC
519 SW 3rd Ave, Suite 800
Portland, OR  97204

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