This Privacy Notice applies to all Personally Identifiable Information (defined below) that is collected by TASHLIJ our online properties (the “Sites”) and offline, through the Independent Representative and or Distributor Application and Agreement, customer product order forms, and any other method.
Keeping personally identifiable information secure is a top priority for TASHLIJ Inc. (“we,” “us,” or “our”). This privacy statement outlines our views and practices and how they pertain to you as an Independent Representative, Distributor, customer or visitor to the Sites. Please check back periodically, as these policies may change and your subsequent use of the Site will be deemed acceptance of such changes. However, our fundamental commitment to protecting visitors’ privacy will not change.
- Collection of Information
- Information You Volunteer. We only collect personally identifiable information you voluntarily provide while using our services, such as name, mailing address, email address, telephone number and payment card data (“Personally Identifiable Information” or “PII”). Independent Representative and or Distributor applicants will also be requested to provide PII such as their Social Security or Federal Tax ID Number so that we may prepare and file necessary non-employee compensation forms for the IRS. You may always choose not to provide us with information. However, we may not be able to provide you with the services you have requested. Visitors may access the Site without disclosing PII.
- Information Collected Automatically. We do not automatically log PII nor do we link information automatically logged by other means PII about specific individuals. However, we may record certain information that becomes available to us through your use of the Site, including, without limitation, the number of visitors and frequency of visits to the Site, the websites that you access immediately before and after the Site, the Internet browser you use, and your IP address. If we use this information, it is only on an aggregate basis.
- Do Not Track Requests. Web browsers may allow you to send a “Do Not Track” request with your browsing traffic, which would enable anonymous browsing of the Site. We honor Do Not Track requests from web browsers. However, anonymous browsing may prevent us from providing you with full functionality of the Site.
- Use of Information
If you choose to provide us with your Personally Identifiable Information, we will use it to provide you with the services you have requested, to serve you with content, to analyze trends, and to enhance your overall experience while visiting the Site. You may also subscribe to email lists and request that we refer you to a TASHLIJ Independent Representative and or Distributor who can provide you with more information about how to purchase TASHLIJ products and become a TASHLIJ Independent Representative and or Distributor. If you purchase TASHLIJ products or become a TASHLIJ Independent Representative and or Distributor, we will also use your PII to (1) provide services to you (such as processing product orders and/or returns and calculating and paying commissions); (2) support and improve the services you render to customers and downline Representatives; (3) provide you with additional services; (4) maintain our genealogy database and the proper functioning of our compensation plan; (5) issue payment and report income to taxing authorities; and (6) ensure compliance with legal obligations and our Policies & Procedures. In furtherance of these purposes, TASHLIJ may share your information with its parent company in the United States and its subsidiaries located in other countries. We do not collect, use, or disclose personal data for any other purposes that are materially different from the purposes set forth herein, but if we wish to do so, we always obtain your consent first and offer you the choice to opt out of such collection, use, or disclosure. As a network marketing company, TASHLIJ provides certain information to Independent Representative and or Distributors regarding the other Independent Representative and or Distributors and customers in an Independent Representative and or Distributor’s line of sponsorship. If you enroll as an Independent Representative and or Distributor with TASHLIJ, your name, rank, email address, address, telephone number and Points purchased will be provided to other Independent Representative and or Distributors in your upline and/or downline. No other personally identifiable information will be shared with other Independent Representative and or Distributors.
- Sharing Information with Third Parties
TASHLIJ may use internal and external service providers to operate the Site and perform other work on our behalf in the course of providing you with services you have requested such as developing the Site; fulfilling orders; delivering packages; administrative or accounting functions; and providing customer service. These service providers may have access to your Personally Identifiable Information, but are contractually bound to use your PII only for the purpose of performing their duties. Even so, we remain responsible for your PII and in cases of onward transfer to third parties TASHLIJ of data of EEA data subjects received pursuant to the EU-U.S. Privacy Shield, is potentially liable. Some of these service providers may be established in countries that offer less privacy protection than your country of residence.
TASHLIJ does not currently sell, trade or rent your PII to any unaffiliated third parties for marketing purposes. We value your privacy and will not jeopardize our relationship with you by selling your information to solicitors without your prior consent.
TASHLIJ may, however, share your PII to fulfill our legal obligations (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, (ii) in response to lawful requests by private parties, in connection with a lawsuit, subpoena, investigation or similar proceeding, (iii) to respond to a matter of personal or public safety, (iv) to investigate security incidents, (v) to protect our interests, rights and property, or (v) in the event of a sale or transfer of assets, or in the context of similar business negotiations.
- Security of Information
TASHLIJ takes administrative, technical and physical measures to help ensure that your Personally Identifiable Information remains accurate, timely and secure. However, no data transmission over the Internet, or through an electronic database, is guaranteed to be 100% secure. Although we strive to protect your information through measures such as the following steps, we cannot guarantee or warrant its security:
- TASHLIJ uses Secure Socket Layers (SSL) to ensure a secure connection whenever transmitting or receiving personal information. With SSL, information transmitted between two computers via the Internet is sent in an encrypted format so that only the sending and receiving computers can decode it. SSL ensures that no one intercepts any of your personal information while it is being transferred to us. A secure connection is maintained until the checkout process is either completed or canceled.
- TASHLIJ restricts access to PII to our employees, contractors and agents who need to know that information in order to perform their jobs. They are obligated to respect the confidentiality of your PII and may be disciplined or terminated for failing to meet these obligations.
- Data Integrity & Access or Corrections
TASHLIJ will keep Personally Identifiable Information in active files or systems as long as necessary in order to fulfill the purposes for which it was collected or as required to perform our contractual relationship with our customers and TASHLIJ Independent Representatives. After a Representative terminates his TASHLIJ business, we must keep some information for accounting purposes, for the calculation of earnings under our compensation plan, and for compliance purposes. We will make reasonable efforts to ensure that the information is accurate and complete and will update or correct your information as needed when notified by you. You may request copies of your Personally Identifiable Information by contacting us at our contact information listed below in Section 10 and representatives may edit your personal information by accessing your account profile. In instances where a Customer purchases product offline, directly from a Coach, we may not have access to the Customer’s Personal Information and you will need to contact your Coach directly.
Depending on the law in your area, you may have various rights concerning personally identifiable information, which may include, a right of access, rectification, restriction of or objection to processing (including for direct marketing), portability to another controller, or erasure. You may exercise some of these rights through functionality on the Site. Where the functionality is not available you may contact TASHLIJ through the contact information provided below. Please be aware that the rights listed above may be subject to various limitation set out by law.
- Independent Representative and or Distributor Organizational Data
TASHLIJ is a direct sales organization that distributes our products through a network of Members, Distributors and Managers known as “Independent Representatives” and or “Independent Distributors”. You may place an order through your Independent Representative, or directly with TASHLIJ and TASHLIJ will share your information with your Independent Representative and or Distributor in order to process your order. Each customer may choose how to place an order and how to be contacted when placing an order. An Independent Representative and or Distributor who introduces a new to the TASHLIJ business is known as a Sponsor and Sponsors may build their own independent sales organizations. To assist Independent Representatives with their businesses, TASHLIJ provides Sponsors with their organizational reports that contain their customer and Independent Representative and or Distributor PII and business data, including, but not limited to, name, address, TASHLIJ identification number, telephone number, email address, fax number, level or rank within the TASHLIJ marketing plan, and volume and sales statistics. These reports are provided to Independent Representatives in the strictest confidence and for the sole purpose of developing their TASHLIJ businesses and constitute the confidential, proprietary trade secrets of TASHLIJ. Some TASHLIJ Representatives may live in countries that offer less privacy protection than your country of residence.
The Site is a general audience website and is not designed or targeted at children. TASHLIJ does not knowingly collect, use or disseminate any personally identifiable information from children under the age of 13. If you believe we may have collected information from your child on the Sites, please contact us and we will make reasonable efforts to delete the information from our records.
- Third-Party Links
- Privacy Shield Statement
In compliance with the Privacy Shield Principles, TASHLIJ commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact TASHLIJ at:
TASHLIJ has further committed to refer unresolved Privacy Shield complaints to our chosen independent recourse mechanism, the International Centre for Dispute Resolution® of the American Arbitration Association® (ICDR/AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit go.adr.org/privacyshield.html for more information or to file a complaint. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. The ICDR/AAA services are provided at no cost to you. In addition, TASHLIJ is subject to the investigatory and enforcement powers of the Federal Trade Commission.
- California Privacy Rights
The California Consumer Privacy Act (“CCPA”) provides individuals in California with specific rights regarding their personal information. TASHLIJ does not discriminate against anyone for exercising rights under the CCPA. This section describes specific rights under the CCPA and how to exercise them. Exercising these rights is subject to TASHLIJ receiving and confirming a verifiable request, which process is outlined below.
Collection, Sale, and Disclosure of Personal Information
Information regarding the categories of personal information that TASHLIJ collects, the categories of sources from which TASHLIJ collects this information, and the business purposes for which TASHLIJ collects this information, can be found in the sections tilted “Collection of Information” and “Use of Information” set forth above in this Privacy Statement.
Within the past 12 months, TASHLIJ has disclosed for business purposes the following categories of personal information to our service providers, as well as with any third party with whom you have instructed us to share this information:
- Identifiers (i.e. name, address, IP address, email address, account name, etc.);
- Personal Information collected under California Civil Code Section 1798.80;
- Commercial Information (i.e. purchasing history or tendencies);
- Internet Activity (i.e. browsing or search history, interactions with our Sites); and
- Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information.
We disclose the above-listed categories of personal information for business purposes, such as enabling your use of our Sites, services, and products; communicating with you; understanding how you interact with our Sites, services, and products; improving our products, services, and other offerings; helping to detect and prevent against fraud; fulfilling orders; delivering packages; performing administrative or accounting functions; providing customer service; and complying with applicable laws and regulations.
Under the current definitions contained in the CCPA, TASHLIJ does not sell, and has not sold in the past 12 months, any personal information.
California residents have the right to ask TASHLIJ to disclose what personal information TASHLIJ collects and uses. Upon receipt and verification of a verifiable request, TASHLIJ will provide an individual with the following information:
- Specific pieces of personal information that TASHLIJ possess;
- the categories of personal information TASHLIJ has collected in the preceding 12 months;
- the categories of sources from which TASHLIJ collected personal information; the business or commercial purpose for which TASHLIJ collects personal information; the categories of third parties with whom TASHLIJ shares personal information; and
- whether TASHLIJ has sold or disclosed personal information for a business purpose and, if so, a list of the categories of personal information sold or disclosed.
A right of access request under the CCPA is free of charge up to two (2) times in a 12-month period. TASHLIJ will not respond to requests that are unfounded, fraudulent, repetitive, harassing, or excessive.
California residents also have the right to ask TASHLIJ to delete personal information that TASHLIJ has collected about them. An individual may submit a verifiable request to delete following the instructions below.
Upon receipt of a verifiable request to delete, TASHLIJ will delete personal information from our records and notify our service providers to delete the same personal information from their records. Please note, TASHLIJ may delete some information and deidentify some information. In cases where TASHLIJ deidentifies information, TASHLIJ implements technical safeguards and business processes as outlined in Section 4 “Security of Information”.
TASHLIJ may not be able to comply with a deletion request if it is necessary for TASHLIJ to keep information in order to, among other things, provide goods or services requested, maintain an ongoing business relationship, comply with legal obligations, protect against fraudulent or illegal activity, or perform other necessary activities as permitted under the CCPA.
How to Exercise Rights Under the CCPA
A California resident wishing to exercise any rights under the CCPA should submit a request to TASHLIJ by Emailing us at: CustomerService@tashlij.com
Please include the following information in your request:
- Whether you want to exercise the right to access or delete personal information.
- Information TASHLIJ may already maintain such as first and last name; the email address you use to interact with TASHLIJ; your ZIP code; your TASHLIJ Member ID number (if you have one), and the order number or description of products purchased for the last order you placed with TASHLIJ (if any).
- Whether you are making the request for yourself or for someone for whom you are authorized to act as a designated agent. If you are making the request on behalf of someone else, provide proof of such authorization.
TASHLIJ will use the information above, and any information it already maintains to verify identity to make sure we do not provide or delete personal information in response to a fraudulent request. TASHLIJ may request additional information to help identify an individual or verify that you want your information deleted. If TASHLIJ is unable to confirm that the individual making the request is the same person about whom we have collected personal information, we will not be able to complete the request.
TASHLIJ will attempt to provide the requested information or confirm completion of a request to delete personal information within 45 days. TASHLIJ will notify you within that time period if we will need additional time to process your request.
- Notice for Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally, identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
TASHLIJ does not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada laws. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
- Changes to Our Privacy Notice
We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make changes, we will post the updated Supplemental Notice on the website and update the effective date. Your continued use of our website following the posting of changes to this Supplemental Notice constitutes your acceptance of such changes.
- Questions and Complaints
TASHLIJ takes your privacy seriously. If you believe we have not complied with this privacy statement, please contact us so we can investigate your complaint.
Please summarize the nature of your question in the subject line of any email you send. Thank you for reviewing this policy.
Date of Last Revision: May 1, 2020