Privacy Policy

Privacy advocates 

 

Privacy Policy

Effective as of Aug 13, 2025.  

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This Privacy Policy describes how our nonprofit (“TOTM,” “we,” “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). TOTM may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

Index

• Personal Information we collect

• How we use your personal information

• How we share your personal information

• Retention

• Your choices

• Other sites and services

• Security

• International data transfers

• Changes to this Privacy Policy

• How to contact us

Personal information we collect

Personal Information you may provide to us. Personal information you may provide to us through the Service or that we may generate about you includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.

• Demographic data, such as your city, state, country of residence, and postal code.

• Profile data, such as the username and password that you may set to establish an online account on the Service, biographical details, photograph or picture, links to your profiles on social networks, interests, phone number, preferences, and any other information that you add to your account profile.  

• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise. 

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Payment data, such as payment card information needed to complete transactions, which is collected by our payment processor, Stripe. Posh does not receive your payment card information.

• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. 

• User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, information about your attendance at events, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.

• Contacts data, with your opt-in consent, you may choose to provide the Service with access to your contacts.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Event Organizer data. In addition to the categories of personal information identified above, we, our service providers, and our business partners may collect personal information from individuals who choose to create events through the Service (each, an “Event Organizer”), such as:

• Event data, such as information relating to or needed to complete your creation of an event, including the name of your event, the name and address of the venue where your event is hosted, features of your event, registered attendees of your event, and a description of your event. 

• Business details data, such as your business website, industry, terms of service link, representative name and email address, date of birth, bank account number, and other information you provide in connection with organizing an event.

• Government-issued identification number data, such as national identification number (e.g., Social Security Number or tax identification number), which is collected by our organization processor, Stripe, if you choose to participate in our Event Organizer onboarding process.

• Capital advance data, such as information you provide when you apply for and/or participate i

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Note that for certain processing activities the Event Organizer may be the controller of your personal information. We therefore encourage you to read the privacy policies of the Event Organizer. We do not control the Event Organizer’s websites, mobile applications or online services operated by the Event Organizer, and we are not responsible for their actions. 

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Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

• Marketing partners, such as joint marketing partners and event co-sponsors.

• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

• Other users, such as your friends or contacts who may use the Service to invite you to use the Service yourself by providing us with certain of your contact details. See the “Data about others” section below.

• Third-party services, such as social media services, that you use to log into, or otherwise link to your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. For example, we may receive your personal data through Google’s YouTube API Services if you choose to embed a YouTube video on the Service. You can learn more about Google’s privacy practices by reviewing the Privacy Policy at http://www.google.com/policies/privacy. 

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that allow you to invite your friends or contacts to use the Service, and we may collect contact details about these invitees from you so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their consent to do so.

Tracking Technologies

Cookies and other technologies. Some of the automatic collection described above is facilitated by cookies and other technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.For information concerning your choices with respect to the use of tracking technologies, see the Your choices section of our Cookie Notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide, operate and improve the Service and our business;

• personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;

• establish and maintain your user profile on the Service;

• facilitate your invitations to friends who you want to invite to join the Service; 

• facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality;

• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

• communicate with you about events or contests in which you participate;

• understand your needs and interests, and personalize your experience with the Service and our communications; and

• provide support for the Service, and respond to your requests, questions and feedback.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. Data is secured and the organization is willing to express Data retrieved. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en. 

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  

• Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below. 

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making solutions)

• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 

• enforce the terms and conditions that govern the Service; and 

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you.  We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. For more information on analytics, see our Cookie Notice.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such when is required by law

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.   When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. 

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, consumer research and website analytics). 

Payment processors. Any payment card information you use to make a purchase or to pay fees on the Service is collected and processed directly by our payment processors, TOTM. Wix may use your payment data in accordance with its privacy policy. You may also sign up to be billed by your mobile communications provider, who may use your payment data in accordance with their privacy policies.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. 

Third parties designated by you. Third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with the Event Organizer, e.g.: to send you messages on an event you signed-up for or future events. Moreover, if you are an Event Organizer, we may share your personal information with the third-party venues, DJs, photographers, security teams, or other third parties that you have chosen to provide services for your event. We will share personal information that is needed for these other companies to provide the services that you have requested.

Business and marketing partners. Third partieswith whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in TOTM or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee TOTM in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other registered users. Your user-generated content data is visible to other registered users of the Service. For example, other registered users of the Service may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Additionally, if you choose to register for an event through the Service, your personal information may be provided to the Event Organizer of that event.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below. 

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

 

Cookies and other technologies. For information about cookies and other technologies employed by the Website-Service and how to control them, see our Cookie Notice. 

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Mobile location data. You can disable our access to your device’s rough geolocation in your mobile device settings.

Privacy settings. If you have an account on the Service, you can control whether your profile is public and other settings by visiting “Privacy Settings” within your account.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

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Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.

 

 Understand that any data collected not used with any intended of harm nor destruction of property. We do not control websites, mobile applications or online services operated by third parties, and we are to be held responsible for actions while interrogating more effective AI Data Protection. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

 

To be continued.