Privacy Policy

Introduction.

1. Web Site Owner. Tuffy Winter Springs (“OWNER") is the owner of this web site (tuffywintersprings.com, hereinafter, the “Site”). OWNER can be contacted by e-mail at gene.john11@gmail.com. This online privacy policy (“Policy”) discloses OWNER's information practices for the Site, including what type of personal identifiable information is required to inquire about, request promotions, book an appointment, apply for employment, or purchase services from OWNER, how that information is used, with whom the information is shared, and your other data privacy rights.
2. Data Controller. OWNER is the data controller in relation to any personal information that OWNER processes about you and is responsible for ensuring that such processing complies with applicable data protection laws, including the California Consumer Privacy Act (the "CCPA") and the California Privacy Rights Act (the “CPRA”). Your privacy is important to us. Please be aware OWNER personnel and employees are required to comply with OWNER's data privacy practices as set out in this Policy and other data privacy-related policies.
3. Anonymous Site Visits. You may visit on the Site without disclosing any personal information, but disclosure of some personal information may be required to use of some of the Site's functionality and that functionality cannot be utilized without this disclosure. OWNER does keep track of the domains from which people visit us and analyzes the data gathered from Site visits for trends and statistics, and then OWNER discards the gathered data.
4. Site Transactions. At times, OWNER will need personal information regarding a customer or a prospect. For example, to process a request for promotions, an appointment, or a quote for services, OWNER will need to know a user's name, e-mail address, and/or company name. It is OWNER's intention to inform you before OWNER collects personal information, such as a user's name and/or email address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, OWNER will respect your wishes and your access to portions of the Site or OWNER's services requiring this information will be restricted.
5. BY USING THIS SITE, YOU ACKNOWLEDGE THAT YOU ARE AT LEAST EIGHTEEN (18) YEARS OF AGE AND AGREE TO BE BOUND BY THESE TERMS. IF YOU ARE NOT AT LEAST EIGHTEEN (18) YEARS OF AGE OR DO NOT WISH TO BE BOUND BY THESE TERMS, PLEASE EXIT THE SITE. YOUR SOLE REMEDY FOR DISSATISFACTION WITH THIS SITE OR THESE TERMS IS TO CEASE USING THE SITE.

Personal Information That May Be Collected.

1. Identifying Information. In order to receive promotions from Owner, make an appointment with Owner, apply for employment, or request a proposal for services featured on the Site, OWNER will require a user to provide certain personal identifying information, which may include: your name, company name, postal address, e-mail address, and telephone number (“Personal Information”). OWNER may request additional information necessary to provide services requested by a user. We may collect and have collected in the preceding twelve (12) months, the following categories of personal information from you in the course of business, including through your use of the Site, when you contact or request information from us, or when we offer or provide any services to you:
   • Identity Data, which includes first name, last name, and e-mail address.
   • Contact Data, which includes email address, mailing address, and phone number.
   • Technical Data, which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
   • Usage Data, which includes information about how you use the Site.
   • Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   • Payment and other financial information.
   • Cookie and device data, which includes information about your visit of the Site, IP address, device identifier, browser type and version, operating system and network, location, and time zone setting.
2. Collection of Information. When you access the Site, you are authorizing OWNER to collect, store, and use such information in accordance with this Policy. You provide this information to the Site via online forms in which you can input Personal Information such as your name, company name, and email address in order to request information, inquire about our services, or for other purposes indicated on Site. When you purchase any of our services, you may provide additional information to us about you. The Site may also gather certain information automatically and store it in log files when you use the Site. We may collect IP addresses and/or click-stream data for purposes of system administration, to understand how our visitors use the Site.
   • An IP address is a number that is automatically assigned to your computer whenever you access the Internet. When you request pages from the Site, our computers log your IP address.
   • Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view and other such non-personal information. This data helps us analyze how visitors arrive at the Site, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of content, and the like. We use this information to update the Site and ensure that we are meeting the needs of our visitors.
3. Service Quality Monitoring. Some services initiated via the Site may require a user to telephone OWNER, or OWNER to telephone the user. OWNER will not contact you by telephone without your prior consent or request, except to confirm an appointment, consultation, or a proposal request and/or to inform a user of the status of such request initiated by a user or respond to an employment application submitted by a user, if deemed necessary by OWNER. The user should be aware that it is OWNER's practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.
4. Children's Privacy and Information from Children. The Site and Services are not directed or intended for children under thirteen (13) years of age. OWNER does not knowingly collect Personal Information from individuals under thirteen (13) years of age. If you are under thirteen (13) years of age, you should not provide Personal Information on the Site. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to OWNER, please contact OWNER at gene.john11@gmail.com so that OWNER may delete and remove such child's information from OWNER's systems.
5. Links to Other Web Sites. The Site may contain links to other web sites. OWNER is not responsible for the privacy practices or the content of those other web sites. OWNER does not monitor, control, or endorse the information collection or privacy practices of any third parties. OWNER encourages you to become familiar with the privacy practices of every website you visit and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by OWNER through the Site and does not apply to these third-party websites. The ability to access information of third parties from the Site or Services, or links to other websites or locations, is for your convenience only and does not signify OWNER's endorsement of such third parties, their products, services, websites, locations, or their content.
6. Non-Identifiable Information. As you use the Site, certain information may also be passively collected. Through cookies, pixels, and beacons for the purposes of targeted and retargeted advertising, log files, and other technologies, OWNER may collect information about how you use the Site. This information allows OWNER to deliver more helpful information, programs, tools, and advertisements. 

Uses Made of the Information.

1. Limited Uses Identified. Without a user's prior consent, OWNER will not use your personal identifiable information for any purpose other than that for which it is submitted. OWNER uses personal identifiable information for, but not limited to, the following purposes:
   • contact you regarding your request for information about a potential purchase of services, promotions, employment application/offer, or an appointment requested by a user;
   • respond to inquiries or requests in connection with or through the Site;
   • fulfill your requests for services or an appointment for services;
   • handle complaints;
   • send communications and administrative/operational emails about the Site;
   • personalize and better tailor the features, performance, and support of the Site for your use;
   • send you Site-related and service-related communications, including any notices required by law, in lieu of communication by postal mail, and you may not opt out of service-related e-mails while your service request is pending;
   • send you newsletters and other messages, including changes to features of the Site and special offers that you may opt out of by clicking "unsubscribe" in the email; opting out may prevent you from receiving email messages regarding updates, improvements, or offers;
   • send you promotional/marketing information, offers, or other information regarding opportunities and functionality that OWNER thinks would be of particular interest to you;
   • improve the quality of the Site; and
   • analyze, benchmark, and conduct research on user data and user interactions with the Site and services offered via the Site.
2. Marketing Uses. OWNER offers you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from OWNER, you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the promotional e-mail you receive.
3. Stored Information Uses. OWNER stores the information provided by users or the information entered on the Site. This information is used to compile a user's interest history in order to enable OWNER to recommend products, services, or special offers that would be of interest to a user or to support user interaction with the Site; to facilitate service purchases or requested appointments with users; and/or to contact user again about other OWNER services and products or employment applications submitted by user.
4. Online Advertising. Some companies that help OWNER deliver interactive on-line advertising, such as banner ads, may collect and use information about OWNER's customers and the Site's users to help OWNER better understand the types of advertising or promotions that are most appealing to OWNER's customers and the Site's users. After it is collected, the information is aggregated so it is not identifiable to a specific individual. If, however, a customer or Site user would prefer that these companies not collect such information, please mark an "x" on the opt-out option box herein provided on the Site homepage.
5. Prior Disclosure. In the preceding 12 months, OWNER has disclosed the types of personal information listed above to its service providers for business purposes. In the preceding 12 months, OWNER has not sold personal information.

CCPA Financial Incentive Notice.

1. OWNER may feature reward/loyalty programs where customers can earn rewards, accumulate points on purchases, access exclusive promos, and earn opportunities to participate in other promotions such as but not limited to the Sweepstakes described immediately below. As part of these programs, we may collect Personal Information, such as your name, email address, phone number, and date of birth. Our good-faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.
2. From time to time, we may also offer incentives limited to a specific time period, such as limited-time sweepstakes, contests, and other promotions. In exchange for your participation in these promotions, you may be offered a financial incentive, such as a prize. As part of these limited-time promotions or sweepstakes, we may collect your Personal Information, such as your name, email address, and phone number. Participation in a limited-time offer or promotion is governed by the applicable terms and conditions for the program (Sweepstakes Rules and Prize Acceptance Agreements), which will also describe any financial incentives associated with the promotion and how to participate. You can terminate participation at any time as will be explained in the program terms. The value of your Personal Information will be disclosed in the promotions terms.
3. In addition to the programs identified above, we may also offer you one-time percentage off coupons, discounts, or other promotions from time to time, such as when you provide us your email address and agree to receive marketing emails in exchange for a one-time promotion. Such offers may not be available at all times. The amount and terms of such offers will be presented to you at the time of the offer. You can terminate participation at any time by contacting us at 407-388-9800. Our good-faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.
4. We may also offer opportunities to participate in surveys. In exchange for participation, you may be offered a financial incentive, such as a discount or a coupon. As part of these surveys, we may collect Personal Information, such as your name, preferences, experiences, beliefs, opinions, and other responses to the survey questions. Participation in surveys is governed by the applicable terms and conditions for the survey, which will also describe any financial incentives associated with that survey and how to participate. You can terminate participation at any time, as will be explained in the survey terms. Our good-faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.

By participating in any of the above promotional programs, you agree that the benefits are reasonably related to the value of the Personal Information collected and retained.

Participation in OWNER's promotional programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us at tuffywintersprings.com to unsubscribe or cancel your participation in any program.

Disclosure of the Information.

1. Within Corporate Organization. OWNER is an organization that may have legal entities, business processes, management structures, and technical systems that cross borders. OWNER may share your Personal Information within the OWNER corporate organization, and may transfer the information to countries in the world where OWNER conducts business. Some countries may provide less legal protection for customer Personal Information. In such countries OWNER will still handle customer Personal Information in the manner describe herein.
2. Mergers and Acquisitions. Circumstances may arise where for business reasons, OWNER decides to sell, buy, merge, dissolve, or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is OWNER's practice to seek appropriate protection for information in these types of transactions.
   
   OWNER maintains full rights to any information collected on the Site, and may freely collect, use, and disclose such information unless prohibited by this Privacy Policy or applicable law. In the event of a change in control of OWNER or sale by OWNER of substantially all of its assets, any information owned by or in the control of OWNER may be transferred to the OWNER successor, who will comply with the terms of this Privacy Policy, as it may be amended from time to time.
3. Agents. OWNER may employ or engages third-party companies and individuals to perform business functions on behalf of OWNER. These companies and individuals are provided with Personal Information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, content management, website hosting, fulfilling user requests, data storage, maintenance, and security, providing customer service support, analyzing data, providing marketing assistance and analysis, customer business reputation management, processing payments (including any credit card payments), and providing customer communication. Access to your Personal Information by these service providers is limited to the information reasonably necessary to perform its limited function.
   
   Such third parties' use of your information will be bound by this Policy. Please note, if you link to third-party websites, please be sure to read the privacy policies of such websites and/or platforms. OWNER is not responsible for information you share to third parties on third party websites and/or platforms.
   
   We may store Personal Information in locations outside the direct control of OWNER (for instance, on servers or databases co-located with hosting providers).
4. Affiliated Businesses. OWNER works closely with affiliated businesses operating websites, providing services, or selling products on each other's web sites. These businesses identify themselves to users. User information related to a transaction with an affiliated business is shared with that affiliated business. Please be sure to read the privacy policies of such affiliated businesses.
5. Marketing and Usage Analysis by Third Parties. OWNER reserves the right to disclose to third parties Personal Information about users for marketing analysis and usage patterns; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer.
6. Disclosure to Governmental Authorities. OWNER may disclose and release your Personal Information to government representatives: (a) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (b) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to OWNER's system or network, or in any cases in which OWNER believes it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or a violation or alleged violation of this Policy or other agreement OWNER may have with you.

Use of Computer Tracking Technologies.

1. No Tracking of Personal Information. The Site is not set up to track, collect or distribute Personal Information not entered by users. Through Site access logs, OWNER does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our Site and specific pages of the Site. This information is used for internal purposes by technical support staff for research and development, user analysis, and business decision making, all of which provides better services to the public. The statistics garnered, which contain no Personal Information and cannot be used to gather such information, may also be provided to third parties.
2. "DO NOT TRACK" browser signals. Please note that we do not alter our Site's data collection and use practices when we see a “Do Not Track” signal from your browser.
3. Use of Cookies. The Site may use cookies, web beacons, and similar tracking technologies. These technologies are widely used for security, to learn about and improve upon how users navigate a website, or to enable certain features. Cookies are small data files that are transferred to your hard drive when your browser settings permit the acceptance of cookies. Similar technologies, such as web beacons or pixel tags function through the use of small files, such as a GIF or PNG, which are opened on a page or in an email. The request for these files from a server reveals certain information, such as your browser type, IP address, and other information. To learn more about cookies and similar tracking technologies, and how they can affect your privacy, visit allaboutcookies.org. By tracking how and when you use the Site, these technologies help us determine which features and content on the Site are most important to our visitors. If you do not want information collected through the use of cookies, you can turn off cookies using your browser's settings menu; however, this may eliminate our ability to provide you with some of the features or functionality you would otherwise experience on the Site. Most modern browsers also include a "do not track" feature that may help protect your privacy. However, because there is not yet a defined response to do-not-track requests, the Site does not respond to your browser's do-not-track request.
   
   In addition to the cookies used by the SSE and any of our service providers, some cookies are placed by third parties such as Google Analytics, as described below. By using the Site, you agree to the use of cookies for the following purposes:
   • Essential Cookies: these are essential in order to enable you to move around the Site and use its features.
   • Performance and Analytics Cookies: Google Analytics ("Analytics") is Google's free web analytics tool that helps us understand how our visitors engage with the Site. Analytics collects information anonymously and reports website trends without identifying individual visitors. Analytics uses its own set of cookies to track user interactions with the Site. These cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Analytics customers can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. A different set of cookies is used for each website, and visitors are not tracked across multiple sites. Analytics customers are obliged to notify users of their use of analytics software. To disable this type of cookie, some browsers will indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis. In addition to declining cookies, you can also install the Google Analytics Opt-out Add-on in your browser, which prevents Google Analytics from collecting information about your website visits. You can also opt out by clicking here.
   • Functionality Cookies: these small data files that remember the choices you make on the Site. These cookies help to make your visit more personal and are deleted automatically when you close your browser or the session expires.
     You can block or disable cookies on your device at any time by indicating this in the preferences or options menus in your web browser. You can also delete the cookies that are stored on your device. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of the Site. You can find more information about cookies at www.allaboutcookies.org . To learn more about, or to opt-out of Google's analytic and marketing services, visit Google Analytics Terms of Service , the Google Privacy Policy, and Google Analytics Opt-out.
4. Use of Web Beacon Technologies. OWNER may also use Web beacons or other technologies, to better tailor the Site to provide better customer service. If these technologies are in use, when a user accesses these pages of the Site, a non-identifiable notice of that visit is generated which may be processed by OWNER or by its suppliers. Web beacons usually work in conjunction with cookies. If a user does not want cookie information to be associated with the user's visits to these pages, the user can set its browser to turn off cookies.
5. Collection of Non-Identifiable Information. OWNER may collect non-identifiable information from user visits to the Site in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on the Site; Site and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." OWNER or its contractors may use this data to analyze trends and statistics.
6. Collection of Personal Information. OWNER collects personal identifying information from users during a transaction or request submitted by the user on the Site. OWNER may extract some personally identifying information about that transaction or request in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help OWNER understand trends and patterns. This information is not reviewed at an individual level.

Information Security and Deletion.

1. Commitment to Online Security. OWNER employs physical, electronic, and managerial procedures to safeguard the security and integrity of Personal Information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints. All OWNER agents and contractors with access to Personal Information on the Site are also bound to adhere to OWNER security standards.
2. No Liability for Acts of Third Parties. OWNER exercises all reasonable efforts to safeguard the confidentiality of customer Personal Information. OWNER uses secure server software (TLS/SSL) to process all financial transactions and user requests that occur on the Site. TLS/SSL technology can encrypt Personal Information transmitted over the Internet. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, OWNER does not warrant the security of its servers, nor does OWNER warrant that your information, including Personal Information, will be completely secure or not be intercepted while being transmitted over the Internet. OWNER shall not be liable for unauthorized disclosure of Personal Information due to no fault of OWNER including, but not limited to, errors in transmission and unauthorized acts of OWNER staff and/or third parties.

Privacy Policy Changes and Opt-Out Rights.

1. Changes to Privacy Policy. OWNER reserves the right to change or update the Policy at any time. A notice of any material change will be posted on the Site home page for thirty (30) days prior to the implementation of such change. There are two boxes at the end of OWNER's notice of change (1) an "I accept" box, and (2) an "I do not accept" box. If customer does not mark the "I do not accept" box, customer will be deemed to have accepted OWNER's privacy policy updates.
2. Opt-Out Right. OWNER does not sell your Personal Information. However, you have the right to opt-out of any transfer or sale of your Personal Information OWNER collects about you. If you choose to opt out, please contact us at gene.john11@gmail.com.

Your Privacy Rights.

1. Right to Access. You have the right to request what personal information we have collected, used, or disclosed, about you in the twelve (12) months preceding your request.
2. Corrections to Personal Information. You have the right to request the correction of the personal information that you provided to us. If your Personal Information changes, or if you note an error upon review of your information that OWNER has on file, please contact OWNER.
3. Deletion of Your Personal Information. You have the right to request that OWNER delete Personal Information collected by OWNER. Upon receipt of such request, OWNER will delete your Personal Information collected as of the date of such request, except when necessary to: (i) complete the transaction for which the Personal Information was provided or perform a contract with the you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity and prosecute those responsible; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech (of business or another consumer) or other rights; (v) comply with the California Electronic Communications Privacy Act; (vi) engage in public or peer reviewed research in the public interest; (vii) enable internal uses reasonably aligned with the expectations of the consumer based on their relationship with the business; and (viii) comply with a legal obligation; (ix) use your Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
   
   Please note that if OWNER deletes your Personal Information, you may not be able to use certain Site functions that require your Personal Information and services that require your Personal Information may be disrupted.
4. Right to Opt-Out. You have the right to opt-out of the sale of your personal information to third parties and any automated decision-marking processes. We, however, do not sell user personal information.
5. Right to Know. You have the right to receive information from us regarding the specific personal information we have collected, categories of personal information we have collected, the sources from which we have collected personal information, the purposes for which we have collected and shared personal information, the categories of any personal information we sold as well as the categories of third parties to whom such personal information was sold, if any, any automated decision-making processes based on their collected personal information, and the categories of personal information that we disclosed for a business purpose in the twelve (12) months preceding your "right to know" request.
6. Right to Data Portability. You have the right to receive a copy of your electronic personal information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit this information to another entity without hindrance, delivered within forty-five (45) days of your request.
7. Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights under the CCPA. However, we are permitted to offer different levels of service, if such differences are reasonably related to the value provided to you by your personal information.
8. Additional California Privacy Rights. California's privacy laws require a company to provide notice to California users of their rights to receive information on to which entities their information was shared for marketing purposes. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of OWNER who are California residents to request certain information regarding OWNER's disclosure of Personal Information for their direct marketing purposes. To make such a request, please send a request to gene.john11@gmail.com. Within thirty (30) days of receiving such a request, OWNER will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. OWNER reserves its right not to respond to requests submitted other than to the address specified in this paragraph.
   Effective January 1, 2023, the rights set forth above will also apply to job applicants, employees, and contractors, and when personal information is transmitted in business-to-business written or verbal communications or transactions relating to providing or receiving a product or service to or from another business, and the personal information concerns an employee, owner, director, officer, or contractor of that business.
   If you are a California resident interested in exercising your privacy choices referenced in this section of the Policy, please send us a request to gene.john11@gmail.com or by calling us at 407-388-9800. For requests submitted via email, you must provide us with sufficient information that allows us to reasonably verify you are the individual about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity with the information provided, we may ask you for additional pieces of information. Such requests may not be made more than once per calendar year.

Text Marketing Terms and Conditions.

By entering your phone number for a request for any services or products, or subscribing via our subscription form, you agree that we may send you text notifications and text marketing offers. You acknowledge that consent is not a condition for any purchase.

Your phone number, name, and any potential purchase information will be shared with our SMS platform. This data will be used for sending you targeted marketing messages and notifications. Upon sending the text messages, your phone number will be passed to a text messages operator to fulfill their delivery.

If you wish to unsubscribe from receiving text marketing messages and notifications, you may reply with STOP to any mobile message sent from us or use the unsubscribe link we provide you with in any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted as a reasonable means of opting out. Message and data rates may apply.

For any questions please text "HELP" to the number you received the messages from. You can also contact us for more information. If you wish to opt out, please follow the procedures above.

Accountability.

1. Questions, Problems and Complaints. If you have a question about this Policy, or a complaint about OWNER's compliance with this Policy, you may contact OWNER by e-mail gene.john11@gmail.com or phone at 407-388-9800.
2. Terms of Use. If you submit a request for services, promotions, or an appointment via the Site, or otherwise contact us via the Site, your action is hereby deemed acceptance of OWNER's practices described in this Privacy Policy. Any dispute over privacy between a Site user and OWNER is subject to the provisions of this Policy and to OWNER's Terms and Conditions of Use which is hereby incorporated herein and which can be read at Terms and Conditions of Use.

Governing Law and Venue.