Policy Effective: May 25, 2018

This Privacy Policy has been created by Toolots, Inc. (“Company” or “We”) to describe how we collect, use and disclose information we collect through www.TOOLOTS.com (the “Site”), and any other websites, mobile and desktop applications, features, widgets or online services that we own that link to this Privacy Policy (together with the Site, the “Service”), as well as any information we collect outside of the Site in connection with the Service.  Our policy also describes the choices available to you about our use of and your ability to access, update, and correct your personal information. Note that we combine the information we collect from you from the Site, through the Service generally, or offline. Please also review our Terms of Use which governs your use of the Service.  

Please read this policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. We encourage you to read the entire Privacy Policy to understand our data privacy practices.

1. 1. Information We Collect About Registered Users and How We Collect It.  We collect several types of information from and about you, a User of the Service, and who may be a Customer or Skilled Technician, as each is defined in the Terms of Service - User Agreement,  including information by which you may be personally identified, directly or indirectly, such your name, date of birth, email address, other contact information, gender, occupation, demographic information, and financial information that you provide to make or receive payments for services obtained through our platforms, or information for the filing of tax forms, and other identifier by which you may be contacted online or offline ("Personal Information").  We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of a government-issued identification. If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card or other financial account information, and billing address.

1. 2. Information We Collect about Site Visitors.  We may use information collected on our Site to (i) to provide, operate, optimize, and maintain the Site; (ii) to respond to your inquiries and requests, and to provide you with information and access to our Services, if you request; (iii) to manage our Site and system administration and security; (iv) to improve the navigation and content of our Site; (v) to identify any server problems or other IT or network issues; (vi) to set up online accounts; (vii) to compile aggregated statistics about site usage and to better understand the preferences of our visitors; (viii) to carry out research and development to improve our products and services; (ix) to customize content and layout of the Site; and (x) to carry out other legitimate business purposes, as well as other lawful purposes.

1. 3. Information You Provide to Us.   Prior to collecting your Personal Information, we will let you know if you can provide it on a voluntary or mandatory basis, and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in in this Privacy Policy and our Terms of Use. The information we collect on or through our Site may include information that you provide to us, including (a) information provided at the time of registering to use our Site, subscribing to our service, posting material, or requesting further services; (b) information when you report a problem with our Site; and (c) records and copies of your correspondence (including email addresses) with us; (d) details of transactions you carry out through our Site and of the fulfillment of your orders; (e) your search queries and browsing on the Site. You may be required to provide financial information before placing engaging in a financial transaction through our Site.  We may link ratings and reviews provided to us by other Users regarding their transactions with you, which information may be linked to or viewable in your profile.  You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Site or transmitted to other users of the Site or third parties (collectively, "User Contributions"), such as your profile. Your User Contributions are posted on and transmitted to others at your own risk and we do not assume any liability or responsibility for any ratings or reviews posted about you by other Users.  If you wish to correct or remove any User Contribution, please contact us at AfterSales@Toolots.com.  Although we will provide you with the election to set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable.  Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. The profile you create on our site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal.  

With your consent, we may also collect data that is about you but individually does not identify you; and/or about your username, internet connection, the equipment you use to access our Site, usage details, IP addresses, information collected through cookies, web beacons, other tracking technologies, and third parties (“Non-Specific Information”). Non-Specific Information such as zip codes, demographic data, information regarding your use of the Service, and general project-related data may be aggregated and used by us to improve the Service.  Usernames are made public through the Service and are viewable by other Users.  Also with your consent, we may also use some combination of Personal and Non-Specific information which enables you to be identified, provided that any disclosure of any Personal Information to third parties in such combined use shall be subject to this Privacy Policy.

1. 4. Information We Collect Through Automatic Data Collection Technologies.  As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including (a) details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site; and (b) information about your computer and internet connection, including your IP address, operating system, and browser ID and type.  We also may use these technologies to collect information about your online activities over time and across third-party Sites or other online services (behavioral tracking).  You must provide us with your consent by opting in to behavioral tracking on this Site and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. The information we collect automatically is statistical data and may include your Personal Information, including the dates and times you access the Services and your browsing activities, to help us to improve our Site and to deliver a better and more personalized service, including by enabling us to: (a) estimate our audience size and usage patterns; (b) store information about your preferences, allowing us to customize our Site according to your individual interest; (c) speed up your searches; (c) recognize you when you return to our Site. We may also obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.  Also, when you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this Privacy Policy.

1. 5. Privacy Controls.  We may not share any tracking behavior containing your Personal Information without your consent and may not allow third parties to do so. We use cookies and other tracking technologies such as pixels and web beacons, to collect this information. These technologies also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our Services and to provide analytics information and enhance the effectiveness of our Services.  You will have the right to decide or accept or reject cookies.  You can exercise preferences about what cookies are served on our Site by visiting our cookie settings preference center, available here: Privacy Settings. You can also exercise your Website cookie preferences by visiting the TRUSTe preference center by clicking this link: [http://preferences-mgr.truste.com/]

• Browser Controls: You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Site though your access to some functionality and areas of our Site may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.
• Disabling Most Interest Based Advertising: Most advertising networks offer you a way to opt-out of interest based advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
• Mobile Advertising: You can opt out of having your mobile advertising identifiers used for certain types of Interest Based Advertising, including those performed by us, by accessing the settings in your Apple or Android mobile device and following the most recent published instructions. If you opt out, we will remove all data about you and no further data collection or tracking will occur. The random ID we (or our third party partners) had previously assigned to you will also be removed. This means that if at a later stage, you decide to opt-in, we will not be able to continue and track you using the same ID as before, and you will for all practical purposes be a new user to our system.
• Do Not Track: Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site do not currently process or respond to “DNT” signals. Toolots takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. To learn more about “DNT”, please visit All About Do Not Track [https://allaboutdnt.com/]

1. 6. How We Use Your Information.  We use information that we collect about you or that you provide to us, including any Personal Information to (a) provide and improve the Service, complete your transactions, process your registration, verify the information you provide is valid and for compliance and internal business purposes; (b) focus content presented to you; (c) administer our business relationship with you; (d) assess a Skilled Technician’s proposal to provide services to a Customer; (e)  enforce and comply with the law, including to conduct an investigation, to protect the property and our rights and those of a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity; (f) carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (g) notify you about changes to our Site or any products or services we offer; (h) allow you to participate in interactive features on our Site, including contacting other Users of our Site; (i) in any other way we may describe when you provide the information; and (i) for any other purpose with your consent.  If you consent, we may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you.  We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this privacy policy to (a) our subsidiaries and affiliates; (b) contractors, service providers, and other third parties we use to support our business; (c) a buyer or other successor in the event of 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 about our Site users is among the assets transferred; (d) third parties to market their products or services to you if you have consented to these disclosures; and (e) fulfill the purpose for which you provide it. 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 use and other agreements, including for billing and collection purposes.  We may also disclose your Personal Information to enforce compliance with our Terms of Use and applicable law, if we believe disclosure is necessary or appropriate to protect the rights and safety of our Users, or others and to carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.  We may use such information generally for statistical analysis, product development, marketing and research. 

1. 7. Sharing Your Information with Third Parties.  We may share aggregated Personal Information and Non-Specific Information with third parties.  Your Personal Information will not be shared with third parties for their marketing purposes unless you have provided you with the opportunity to opt-in to such sharing.  We may also share your Personal Information as described in this Privacy Policy and as follows:

• To provide, support and improve the Services.  We will share the Personal Information that you allow us to share with other Users to provide and support our Services or to make certain features of the Services available to you. If you choose to submit a proposal for work as a Skilled Technician, we will share information relevant to your application with the applicable Customer(s), including, but not limited to, the information contained in your Skilled Technician Profile.  If you are a Customer and have posted a Request for Service, you agree that your Request for Service may be posted to Skilled Technicians who have registered on the Site.
• Information about Skilled Technicians Share with Customers and Our Vendors:  We may provide our Users with the option to participate in third party payment services, such as Paypal (“Payment Vendor”).  If you elect to participate in this option, and your account suspended from the Service, you agree that we may share that information with the Payment Vendor and other Users which are in active transactions with you. When we share Personal Information with non-User third parties, we will take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use any Personal Information transferred to them in a manner consistent with this policy and applicable law.  
• Information about Customers and Agencies Shared with Skilled Technicians: If you have entered into a service contract with another User or agreed to use our Payment Vendor, we may provide the Payment Vendor with your name, company address, billing address, or tax ID or VAT number to complete the transaction or to facilitate the resolution of a claim or dispute. The User receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.
• Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of our Site features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information to perform these tasks on our behalf.
• Legal and Investigative Purposes: We will share information with government agencies as required by law in response to lawful requests by public authorities, we will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), at the request of governmental authorities or other third parties conducting an investigation, to protect the property and our rights or those of a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use device identifiers to identify our Users and may do so in cooperation with third parties at our discretion.

1. 8. Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• 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 Site. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
•  Promotional Offers from the Company. If you wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-in by following at our Privacy Settings page or by sending us an email stating your request AfterSales@Toolots.com.   We do not control third parties' collection or use of your information to serve interest based advertising. However, these third parties must not allow your information to be collected or used in this way without your consent if you are in the European Economic Protection Area. You can also opt out of receiving targeted ads from users of the Network Advertising Initiative ("NAI") on the NAI's Site.

1. 9. Accessing and Correcting Your Information.  You can review and change your Personal Information by logging into the Site and visiting your account profile page. 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.  You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may access, correct, or request deletion of your personal information by making updates to that information or by contacting us through your online account.  If you completely delete all such information, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like us to delete your account in our system, we will use commercially reasonable efforts to honor your request; however, certain information will actively remain on the Service even if you close your account, including information in your Work Schedule and messages you posted to the Service. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may be retained by us for our administrative purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Service. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Site users.

1. 10. Data Security.  We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.  Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

1. 11. Phishing. Phishing websites imitate legitimate websites to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to us. For more information about phishing, visit the Site of the Federal Trade Commission at http://www.consumer.ftc.gov/articles/0003-phishing. In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be Toolots, please report this to us at AfterSales@Toolots.com.

1. 12. Changes to Our Privacy Policy.  It is our policy to post any changes we make to our Privacy Policy on this page, which will be effective upon posting.   We will display a notice of any material changes to the way your Personal Information is used and may notify you via email of such material changes, in our discretion.  The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

1. 13. Age Restricted Site.  Our Site is not intended for persons under 18 years of age. No one under age 18 may provide any information to the Site. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Site or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at 16300 Shoemaker Avenue, Cerritos, CA 90703 and/or at AfterSales@Toolots.com.

1. 14. Social Media and Third Party Websites. Our Site may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie to make sure the feature functions properly. Our Site include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

1. 15. California Residents Only - Privacy Rights.  California Civil Code Section § 1798.83 permits California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. Alternatively, the law provides that a Company may comply by disclosing in its privacy policy that it provides consumers choice (opt-in or opt-out) regarding sharing Personal Information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated above in this Privacy Policy, we provide you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time we offer that choice, we will not share your information with that identified third party for its direct marketing purposes. If you are a California resident and you have questions about the disclosure of your Personal Information to third parties for their direct marketing purposes and your rights, please send your questions to AfterSales@Toolots.com or send a letter to 16300 Shoemaker Ave, Cerritos, CA 90703, USA.  Please note “California Privacy Rights” in the subject field of your email or your letter and include your name, street address, city, state, and ZIP code.  We are not responsible for notices that are not properly labeled or sent, or do not have complete information.

1. 16. International Transfer of Personal Information.  Toolots is a United States company. If you are located outside the United States and choose to provide information to us, Toolots transfers Personal Information to the United States for processing. The U.S. may not have the same data protection laws as the country in which you initially provided the information, so if you are User outside of the U.S, you agree to assume the risk of any loss arising from the application of your local data protection regulations. When we transfer your information to the U.S., we will protect it as described in this Privacy Policy. By visiting the Service, or providing Toolots with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States.

1. 17. Other Data Protection Rights  Users may have the following data protection rights:

• To access, correct, update or request deletion of Personal Information. Toolots takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a User, you can manage many of your individual account and profile settings within the dashboard provided through the Toolots platform, or you may contact us directly by emailing us at AfterSales@Toolots.com. You can also manage information about your Contacts within the dashboard provided through the Toolots platform to assist you with responding to requests to access, correct, update or delete information that you receive from your Contacts.
• In addition, individuals who are residents of the European Economic Protection Area (EEA) can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us using the contact details provided in the “Contact Information” section below.
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.  
• The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here. [ Link to : http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm]

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from either a Skilled Technician or a Customer that you have engaged, we will either direct such party to reach out to you, or, if appropriate, we may respond directly to their request.

1. 18. Legal Basis for Processing Personal Information (EEA Persons Only).  If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Site; and for our marketing activities.

If you are a User, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.  If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided below.  If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:

1. 19. Contact Information. 

For EEA Residents:

For the purposes of EU data protection legislation, Toolots, Inc. is the controller of your Personal Information. Our Data Protection Officer can be contacted at __________@Toolots.com.

For Non-EEA Residents:

To ask questions or comment about this privacy policy and our privacy practices, contact us at: TOOLOTS INC., 16300 Shoemaker Avenue, Cerritos, CA 90703 and/or at AfterSales@Toolots.com.