Last Updated: August 5, 2020
information consistent with the Agreement.
If you are a California resident, please see the “Additional Disclosures for California Residents” section. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.
2. General Terms
● TULA Life Balanced, LLC may be referred to as “TULA,” “we,” “our,” or “us.”
● We call a user of the TULA Platform “User,” “Users,” “you,” “your,” or “Client” as appropriate.
● “Assistants” are independent contractors of TULA that are seeking to perform Tasks for Clients
● The community platform that we offer at our website (www.tulabalanced.com) is referred to as the “Site”
● The web application is referred to as the “App”
● TULA’s Site, App and related services, information and communications are collectively referred to as the “TULA Platform.”
3. Information Collection
TULA collects certain personally identifiable information about you, including information that is reasonably capable of being associated with you (“Information”). Examples of Information that TULA collects include:Contact Information. This may include your first and last name, postal address, email address, and birth day and month (but not year).
Promotional Information. Certain offerings of the TULA Platform, such as newsletters, surveys, contests, and the like are optional and so you are not required to enter them or to give us your data in connection with them. Where you do consent to take advantage of TULA Platform offerings, we will use your data to (as applicable) send you newsletters and other communications that are tailored based on information we have about you, or to operate and manage the survey, contest or similar offering in connection with our legitimate interest in promoting our business and the TULA Platform. To opt-out of receiving marketing communications from us, please see the Choice/Opt-Out section below.
Content Information. You also may choose to send TULA Personal Information in an email or chat message containing inquiries about the TULA Platform and we use this Information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the TULA Platform (such as through our chat functionality), and we will never use or share such information for marketing purposes.
We require that you furnish your Contact Information when you register an account with us in order to provide services through the TULA Platform. For example, if you are a Client, we collect your first and last name, email address, your address and your date of birth in order to create and administer your TULA account. We also collect additional information in order to facilitate your booking request, such as information about the task you are seeking, and the time, date and location of the task.
Third Party Information. We may receive additional information about you from Third Party Agents (as defined below) and combine it with other information that we have about you, to the extent permitted by law, in order to comply with our legal obligations and for the legitimate interest in improving the TULA Platform. TULA may work with Third Party Agents to perform identity checks, criminal background checks, and right to work checks on Assistants, if applicable and permitted by local law, in order to advance our legitimate interests in ensuring the safety of our Users and maintaining the integrity of the TULA Platform.
4. Information TULA Collects Automatically
We automatically collect certain information when you use the TULA Platform. The categories of information we automatically collect and have collected, including in the last 12 months, are as follows:
Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, portions of the TULA Platform that you view and interact with, the time of day you browse, and your referring and exiting pages.
Device Data, including data about the type of device or browser you use, your device’s operating system, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the TULA Platform, TULA may collect certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you use, and information about the way you use the TULA Platform (“Device Information”). We may use Device Information to monitor the geographic regions from which Users navigate the TULA Platform, and for security and fraud prevention purposes. Use of any IP-masking technologies or similar technologies (like the TOR network) may render portions of the TULA Platform unavailable and are forbidden on the
Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and, with your consent, precise location data (such as latitude/longitude data).
We also use various Tracking Technologies (“Tracking Technologies”) to automatically collect information when you use the TULA Platform, including the following:
Cookies. When you visit websites, including the Site, your browser may automatically transmit information to these websites throughout the visit. We use “cookies” and equivalent technologies to collect information through our Site and App. Cookies are small data files stored on your device that act as a unique tag to identify your browser.
Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Platform. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. We utilize persistent
cookies that only TULA can read and use, and access mobile device IDs to:
● save your login information for future logins to the TULA Platform;
● assist in processing items during checkout;
● hold session information; and
● track user preferences.
Session cookies make it easier for you to navigate our website and expire when you close your browser. We utilize session ID cookies and similar technologies to:
● enable certain features of the TULA Platform;
● better understand how you interact with the Sites and the TULA Platform;
● monitor usage by our Users and web traffic routing on the TULA Platform;
● track the number of entries in TULA promotions, sweepstakes and contests; and
● identify visited areas of the TULA Platform.Unlike persistent cookies, session cookies are deleted from your computer when you log off from the TULA Platform and then close your browser.
Exhibit A sets out the different categories of cookies that the TULA Platform uses and why we use them.
We may work with third party advertisers who may also place or read persistent cookies on your browser, and we may use Flash cookies (or local shared objects) to store your preferences or display content based upon what you view on the Sites to personalize your visit. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the TULA Platform.
Pixels. We and our Third Party Agents may also use "pixel tags", "web beacons", "clear GIFs", or similar means in connection with the TULA Platform and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, determine the success of marketing campaigns, and compile statistics about Site usage and response rates.
5. TULA's Use of Information
● To operate and make available the TULA Platform. We use your data to enable the posting of, selection for, completion of, and payment for Tasks;
● For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which Clients can find Assistants and conduct business, and in order to comply with our legal obligations;
● To conduct identification, criminal background, and right to work checks, if applicable, and to the extent permitted by local law, on Users, in order to advance our legitimate interests as well as for the substantial public interest of ensuring the safety of our Users both online and offline, preventing or detecting unlawful acts, protecting the public against dishonesty, and maintaining the integrity of the TULA Platform given that Assistants often interact directly with Clients and may enter their homes;
● To analyze TULA Platform usage as necessary for our legitimate interest in improving the TULA Platform to grow our business;
● To contact you and deliver (via email, SMS, push notifications, or otherwise) transactional information, administrative notices, marketing notifications, offers and communications relevant to your use of the TULA Platform, with your consent when required under applicable law, as necessary for our legitimate interests in proper communication and engagement with our Users
and in promoting our business;
● To provide you with customer support in order to fulfill our contracts with Users;
● For internal market research for our legitimate interest in improving the TULA Platform to grow our business;
● For troubleshooting problems for our legitimate interests in ensuring a safe and secure environment in which Users can meet;
● To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;
● To enforce our Terms of Service and our legitimate interests in ensuring our Agreement is complied with; and
● As otherwise set forth in the Agreement.
For more information and to understand your choices regarding third party ads, please see the “Cookies and Other Technologies and Interest-Based Advertising” in Exhibit A. Advertising and marketing is carried out as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.
Analytics and Market Analysis. TULA may analyze information (“Market Analysis”) as necessary for our legitimate interests in providing an engaging and relevant experience, and promoting and growing the TULA Platform.
TULA uses information to offer services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.
6. Information Sharing
To operate the TULA Platform, including processing your transactions, we may share your information with our agents, representatives, vendors and service providers, including Stripe, Airtable, Webflow, Flodesk, Zapier, Google Analytics and Twilio (“Third Party Agents”) so they can provide us with support services as follows:
● Email origination;
● Identity checks and criminal background checks, to the extent permitted by applicable law;
● Fraud detection. Our fraud detection providers also use information relating to you and your use of and activity on the TULA Platform to provide fraud detection services to their other clients;
● Receipt, invoice, or support services;
● Customer relationship management services;
● Financial transaction fulfillment and related chargeback and collection services; and
● To otherwise help us provide the TULA Platform
The use of your information by Third-Party Agents is governed by the terms and conditions of use and privacy policies for those Third-Party Agents. TULA expressly disclaims any liability arising in connection with the sharing of your information with Third Party Agents for the purposes of providing the TULA Platform. You hereby agree to hold TULA harmless from any liability that may result from the Third Party Agents’ use of your information.
Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners’ list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice, and/or likeness in advertising or marketing materials. We may occasionally contact you, if you want us to, with information about special events, activities, promotions, contests, submission opportunities, and programs. You always have the ability, in your Account, to ask TULA not to contact you with
this type of information.
Legal Obligations. TULA and our Third Party Agents may disclose information or User Generated Content, including location data or communication data, to a third party if required or permitted to do so by law or pursuant to a court order, warrant or subpoena. TULA reserves the right to disclose Personal Information from both private and public areas of the Site(s) and the TULA Platform in the absence of a court order, warrant or subpoena, to the extent permitted by applicable law, if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or TULA or its partners, parents or affiliates. It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited or otherwise constrained by law or court order from doing so, (ii) we have reason to believe the User’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be
impractical (in which case we may provide notice after the fact).
Merger or Acquisition. TULA reserves the right to share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Public Areas. Your profile on the TULA Platform consists of information about you, and may include information such as photographs and other information, including your username (“Profile”). The information in your User Profile may be visible to all Users and the general public. If you choose to post a Task via the TULA Platform, the contents of such listing will be viewable to Assistants on the TULA Platform.
7. Your Rights and Choices
You may opt-out of receiving promotional communications from us and our Partners, remove your information from our database, choose to not receive future promotional communications related to the TULA Platform, or cancel your account by contacting us at
firstname.lastname@example.org or 3800 Buchtel Blvd #100561, Denver, CO 80210.
Account Settings. During registration you choose whether to receive marketing correspondence from TULA and its affiliates and Partners. This information remains on your Profile where you can, at any point, easily edit it.
Corrections to Profile. You have the right to access, update, and correct inaccuracies in your TULA Profile at any time by logging in and clicking on the “Account” tab. There, you can view, update, and correct your Account information. Our databases automatically update any information you edit in your Profile under the “Account” tab. So that we may protect the integrity of the TULA Platform, there are certain pieces of information, such as your age, that you cannot alter yourself. For example, since children under the age of majority in their jurisdiction of residence are not allowed to register as Users, we need to take reasonable measures to preserve the accuracy of our Users' ages. You may contact us at email@example.com or 3800 Buchtel Blvd #100561, Denver, CO 80210 if there is a need to make a correction to such data. Please see the Children’s Privacy section for more details.
Promotional Communications. You can opt out of receiving promotional communications from TULA sent via email by clicking on the unsubscribe link in any message. You can opt out of receiving promotional communications from TULA sent via text message at any time by following the instructions provided in those messages to text the word "STOP". Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, TULA may continue to send you non-promotional communications, such as those about your account, Tasks, transactions, servicing, or TULA’s ongoing business relationship with you. If you receive unsolicited email from a TULA domain, please let us know here firstname.lastname@example.org or at 3800 Buchtel Blvd #100561, Denver, CO 80210.
Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operations should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to
“Do Not Track” signals. For more information on “Do Not Track,” visit https://www.allaboutdnt.com. If you are a California Resident, please see the Additional Disclosures for California Residents section below.
8. TULA's Information Retention Policy
We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations, but in no case longer than six (6) months after you delete your Account. We may also retain data from which you cannot directly be identified, for example where stored against a randomly-generated identifier so we know the data relates to a single User, but we cannot tell who that User is. We use this kind of data for research purposes and to help us develop and improve our services, and we take appropriate measures to ensure you cannot be re-identified from this data. In all cases, all information collected from you shall be deleted six (6) months after you delete your Account on the TULA Platform.
9. TULA’s Security of Collected Information
Your TULA account is password-protected so that only you and authorized TULA staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer, you should sign out of your TULA account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties. TULA implements and maintains reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorizedaccess, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
10. Notification of Changes
11. Children’s Privacy
This service is intended for a general audience, and is not directed at children under 13 years of age. In certain jurisdictions, this minimum age may be higher. Please check the Jurisdiction-specific Provisions below for more information.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe that we have collected information from your child in a manner not permitted by law, please let us know by contacting us here: email@example.com or by mail at 3800 Buchtel Blvd #100561, Denver, CO 80210. We will remove the data.
We do not knowingly collect or “sell” the Personal Information of minors under 18 years old who are California residents.
12. Contacting Us
TULA's staff will respond to all mail or email from Users with questions about privacy, including the types of Personal Information stored on the TULA database, and requests to delete or rectify such Personal Information.
13. Jurisdiction-specific Provisions
A. Residents of the United States of America
Information of U.S. Users. Our collection, use, and retention of the Information of U.S. Users is in accordance with applicable U.S. laws, as is our determination of what is deemed to be “personal data and/or information”. Such collection, use, and retention laws are different from those afforded to EU Users under the General Data Protection Regulation of 2018 (“GDPR”).
THE TULA PLATFORM IS SPECIFICALLY MADE FOR U.S. USERS AND DOES NOT CONTEMPLATE USE BY ANYONE OUTSIDE OF THE U.S. AT THIS TIME. ANY USER WHO IS NOT WITHIN THE U.S. SHOULD CEASE USING THE TULA PLATFORM IMMEDIATELY.
TULA expressly disclaims any liability that may arise should any other individuals obtain the information you submit to the TULA Platform.
TULA’s Security of Collected Information. While TULA will use commercially reasonable efforts to ensure the security of all information collected, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all information stored therein, and you agree to hold TULA harmless for any damages that may result therefrom. If you have any further questions on this issue, please refer to the Terms of Service.
B. Additional Disclosures for California Residents
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise.
California Notice of Collection. We have collected information corresponding to the following categories of information enumerated in the CCPA.
● Identifiers, including name, address, email address, account name, IP address - and an ID number assigned to your account.
● Customer records, phone number, billing address, employment or education information.
● Demographic information, such as your age or gender. This category includes pieces of Personal Information that also qualify as protected classification characteristics under other pre-existing California or federal laws.
● Analytics and Advertising, including purchases and engagement with the TULA Platform.
● Internet activity, including history of visiting and interacting with the TULA Platform, browser type, browser language and other information collected automatically.
● Geolocation data, including location enabled services such as WiFi and GPS.
● Inferences, including information about your interests and preferences.
For more information on what we collect, including the sources we receive information from, review the Information Collection section. We collect and use these categories of Personal Information for the business purposes described in the TULA’s Use of Information section, including to provide and manage the TULA Platform.
TULA does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the TULA’s Use of Information section as a “sale,” we will comply with applicable law as to such activity.
TULA discloses the following categories of information for commercial purposes:
● Commercial Information;
● Demographic Data;
● Location Data;
● Inferences; and
● Internet activity.
We use and partner with different types of entities to assist with our daily operations and manage the TULA Platform. Please review the Information Sharing section for more detail about the parties we share information with. Right to Know and Delete. If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
● The categories of Personal Information we have collected about you;
● The categories of sources from which the Personal Information was collected;
● The categories of Personal Information about you we disclosed for a business purpose or sold;
● The categories of third parties to whom the Personal Information was disclosed for a business person or sold;
● The business or commercial purpose for collecting or selling the Personal Information; and
● The specific pieces of Personal Information we have collected about you.
In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and TULA may have legal grounds for keeping such data. To exercise any of these rights, please submit a request at firstname.lastname@example.org or by mail at 3800 Buchtel Blvd #100561, Denver, CO 80210. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.Right to Non-Discrimination. You have the right to non-discriminatory treatment by us, should you exercise any of your rights.
Shine the Light. Customers who are residents of California may request info: a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please contact us at email@example.com or 3800 Buchtel Blvd #100561, Denver, CO 80210.
Requests must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please note that TULA is not required to respond to requests made by means other than through the provided email address or mail address.
CookiesThese cookies (including local storage and similar technologies) tell us when
you’re logged in, so we can customize your experience and connect your
account information and settings.Localization These cookies help provide a localized experience by showing you your localmetro area.Site features
and servicesThese provide functionality that helps us deliver products and the TULA
Platform. For example, cookies help you log in by pre-filling fields or help
ensure older versions of web browsers can still view our Site. We may also use
cookies and similar technologies to help us provide you with social plugins and
other customized content and experiences, including customized fonts.Analytics and
researchThese are used to understand, improve, and research products and services,
including when you access the TULA Platform and related websites from a
how you are using site features, to report on any errors in how the Site is
functioning, to report to our vendors when content licensed from them is
assessed, and to segment audiences for feature testing. We and our partners
may use these technologies and the information we receive to improve and
understand how you use websites, products, services and ads.Interest-Based
AdvertisingThings like cookies and pixels are used to deliver relevant ads, track ad
campaign performance and efficiency, and to understand your interests from
your online activity on the Site, and other websites. For example, we and our ad
partners may rely on information gleaned through these cookies to serve you
ads that may be interesting to you on other websites and in doing that your
information (which will not contain your name, email address or other "real-
world" identifiers) will be shared with other platforms in the digital advertising
ecosystem all involved in assisting the delivery, purchase, reporting and
analysis of digital advertising. Similarly, our advertisers may use a cookie,
attribution service or another similar technology to determine whether we’veserved an ad and how it performed, or provide us with information about how
you interact with them.
Please note that even if you opt-out of interest-based advertising by a third
party, these tracking technologies may still collect data for other purposes,
including analytics, and you may still see ads from us, but the ads will not be
targeted based on behavioral information about you and may therefore be less
relevant to you and your interests.
You can instruct your browser, by changing its options, to stop accepting
cookies or to prompt you before accepting a cookie from the websites you visit.
To successfully opt-out, you must have cookies enabled in your web browser.
Please see your browser’s instructions for information on cookies and how to
enable them. Your opt-out only applies to the web browser you use so you must
opt-out of each web browser on each device that you use. Once you opt out, if
you delete your browser’s saved cookies, you may need to opt-out again.
For more information about targeting and advertising cookies and how you can
opt out, you can visit the Network Advertising Initiative opt-out page, or
the Digital Advertising Alliance’s opt-out pages.Social Media and Digital Advertising cookies and widgets
● Facebook Impressions: We use Facebook Impressions to track the number of people that
interact with our content on Facebook. This information is collected by Facebook and is
that we receive from Facebook using the privacy settings in your Facebook account.
● LinkedIn Widgets: This tool enables visitors to engage with us via LinkedIn and show visitors
relevant ads and personalized content on LinkedIn. To learn more about LinkedIn’s practices and
● Flodesk: Email newsletters you elect to receive from us are transmitted through Flodesk.
Flodesk uses pixel tag technology to determine whether an email has been opened. In addition,
when you click on any link in an email newsletter or marketing message you have elected to
receive, Flodesk recognizes that fact. This information is used in the aggregate to measure the
rate at which emails are opened and various links are clicked, to measure user interests and
traffic patterns, and to improve the content of the email newsletters and the services and features
offered through the email newsletter and marketing messages. Because some of this information
is linked to individual email addresses, it is personally identifiable. You can view Flodesk’s
● Google Ads: We use Google Ads to promote our company online and use the cookies provided
by Google to record completion of a transaction on our website. You can find out more about
● Instagram: We use Instagram to promote our company online and use the cookies provided by
Instagram to track the number of people that interact with our content on Instagram. Further, we
use Instagram to record your name, contact details, and social media handles. This information
● Google Analytics: We use Google Analytics, a web analytics service. Google Analytics uses
cookies to help TULA analyze how visitors use the Site. The information generated by cookies
about your use of the Site and the TULA Platform (including your IP address) will be transmitted
to and stored by a Google server in the United States. Google uses this information for the
purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators,
and providing Site operators with other services relating to Site activity and Internet usage. You
can prevent the storage of data relating to your use of the Site and created via the cookie
(including your IP address) by Google, as well as the processing of this data by Google, by
downloading and installing the browser plug-in available here. You can obtain additional
information on Google Analytics’ collection and processing of data and data privacy and security
at the following links: How Google Uses Information From Sites Or Apps That Use Our
Services and Analytics Help.