Effective Date: Aug 26, 2019

Last Modified: Aug 26, 2019

At The Disruptive, Inc. (the “Company”), we take privacy issues seriously. Please take a moment to read the following Privacy Policy to learn how we handle your Personal Information. 

This Privacy Policy describes what information and Personal Information (as defined below) we collect about you and the users of the Services (collectively, we will refer you to you and all users of the Services as “you” or “your”), our legal basis for processing the Personal Information, how the Company will use the Personal Information, how the Personal Information will be stored, and your rights in relation to the collection of your Personal Information when you visit, use, or interact with our website,, including any subdomains or subpages, (referred to as the “Website” in this Privacy Policy), and all associated services offered on or through the Website, (collectively, the Website, and all other services offered on or through the Website shall be referred to herein as the “Services”). 

Why Does the Company Collect Personal Information?

The Company collects Personal Information about you to improve how we operate, offer our Services, communicate with you about those Services, and provide effective, timely customer support when needed. We do not share your Personal Information except as set forth in this Privacy Policy, and we will never rent or sell any of the Personal Information we collect from you to third parties.

What Kind of Personal Information Do We Collect?

Our Website collects information, which includes Personal Information, about you. In this Privacy Policy, and under applicable law, “Personal Information” means any information relating to an identified or identifiable individual; and an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number (e.g., a social security number) or one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity (e.g., name and first name, date of birth, biometrics data, fingerprints, etc.). 

In this section, we will explain what type of information and Personal Information we collect, and how it is collected. We collect information and Personal Information about you in a few different ways when you use the Services or visit the Website. Should you decide to not provide the Company the Personal Information identified in this Privacy Policy, then we may not be able to provide the Services to you.

Company collects Personal Information in a variety of ways when you interact with the Website, including when you provide the Company information (including your name and email address); register or create an account with Company; when you place an order at Company; when you use the Services; when you visit Company pages or pages of certain Company partners; when you enter promotions or sweepstakes; when you subscribe to a newsletter or desire to be added to our mailing lists for other Services; when you correspond or otherwise interact with us; and when you provide feedback in any of our online surveys.

Information we collect may include: your name, e-mail address, phone number, address, billing information, demographic information provided by you (such as language, gender and age, and, if applicable, preferences and personalization information) and personal interest information. On occasion, we may ask for additional information to enable us to provide you with access to and use of certain information, materials and Services. Company may combine information about you that we have the information we obtain from business partners or other companies.

What Sources Do We Use to Collect Information? 

Automatically Collected Information

When you visit the Website and/or utilize the Services, the Company automatically collects some information about you and your activities. For example, when you visit the Website, the Company automatically collects information about your Internet Protocol (“IP”) address, your computer operating system and browser type, the amount of time you spent accessing the Website, language preferences, and the website you were viewing directly before you visited the Website. 

The Website also collects certain information about your usage and activity on the Website by using certain technologies, such as:

Cookies. the Company automatically collects information by using “Cookies.” Cookies are small data files that have unique identifiers and reside, among other places, on your computer, mobile device, and on the Website. Cookies help the Company improve the Website and your experience when visiting the Website, by helping with tasks such as recognizing you and your browser when you visit the Website, analyzing your behavior, and remembering your settings from previous visits. With respect to the Website’s use of cookies and other similar technologies, you may generally adjust your browser settings and elect not to allow cookies to be placed on your browser or machine, and thus opt-out of certain features of the Website’s automatic collection of certain data about you.

Mobile Device Information. When you access the Services by using a mobile device (e.g., a cell phone or tablet), the Company may collect, store, and process certain identification numbers associated with the device (e.g., an IDFA, unique device ID, or Google Ad ID), and information about the mobile device model, type, manufacturer, operating system, and phone number.

Web Beacons. The Company collects information by using web beacons. Web beacons are small, electronic images that may be used on a website or in emails. the Company utilizes web beacons to count visits, deliver cookies, and understand Website usage.

Do-Not-Track Signals. We currently do accept Do-Not-Track Signals and do not employ technology that recognizes Do-Not-Track Signals from your browser.

Log data. When you use the Website, the Company collects information called “log data” or “log information.”  This information includes the browser type and operating system that were used to visit the Website, the associated IP address for the visit, the time of day of the Website access, and any language preferences. the Company may log this information for internal record keeping and business purposes. For example, the log information is important for audit, security, quality improvement, and other internal business purposes.

Information About How You Use the Services. We may collect information about your participation and actions on the Services. This may include information such as the pages on the Website you visit, how you browse the Services, and the various functions that you use. 

Location Data. The Company does not currently track or collect your precise geographic location, or any latitude or longitude coordinates associated with your location. However, it’s important to note that some types of collected information (e.g., your IP address) may possibly be used to provide an approximate location of your computer or mobile device.  the Company does not currently take any steps with this type of information to identify your precise geographic location. 

Social Media Widgets:

The Websites include social media features, such as links to Facebook and Instagram. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information from Third Party Services:

We may also obtain other information, including Personal Information, from third parties and combine that with information we collect through our Websites. Any access that we may have to such information from a third-party social media or authentication service is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third-party service, we will access and store your name, email address(es), current city, profile picture URL, and other Personal Information that the third-party service makes available to us, and use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services. 

How Do We Use Your Personal Information?

Company uses your Personal Information in the following ways:

  • Delivery and billing for our Services, and to communicate with you concerning your account and customer service issues. This may include verifying authorization of credit card usage before any purchase of content or services.
  • Improving our Services by providing personalized content recommendations, language and location customization, and/or personalized help and instructions.
  • To ask you to participate in surveys about Services, news and events.
  • Offering you Services for you to purchase.
  • Providing you with content, services, instructions, and a more personalized experience based on Personal Information, such as your language preferences, zip/postal code, country locations, and any content or other preferences you provide.
  • Providing you with news, free newsletters, updates, targeted advertising, promotions, and special offers.
  • To better understand how our Services are used, including Website traffic patterns and what types of content are most popular with users of Services.
  • Administer the Website and Services to diagnose and resolve technical problems.
  • Send you notifications and communications to the email address that you have provided in relation to the Services.
  • Generate, create, and review reports and other data about you and others on the Website and to conduct research on the Website and any usage or patterns.
  • Administer the Services.
  • Provide you and others with customer support.
  • Carry out or fulfill our legal obligations, regulatory requirements, and/or enforce our rights arising from any contractual agreement (such as our Terms of Use) between the Company and you.
  • Provide you notice about changes to the Services.

Payment Information

Certain Services made available through the Website require payment.  To make any such payment through the Website, payment information will be required. The Company does not store or directly access any of your payment information or account information. Instead, the Company utilizes third party payments processors to process all payments.  The Company does not have direct responsibility or control over your payment information or account information. the Company’s agreements with the third parties service provides that receive your payment information and/or account information require them to keep the information secure and confidential. 

As such, the Company cannot and does not guarantee that the transmission of your payment information or related Personal Information will always be secured against access from unauthorized third parties. There is always the chance that unauthorized third parties will be able to defeat the security measures taken by the Company or the third parties we have contracted with.  The Company makes no representations or warranties and assumes no liability or responsibility for improper access to or disclosure of your payment information or Personal Information due to unauthorized third-party access, errors in transmission, or other causes beyond the Company’s control. To help in this process, you should never share your username, password, or other information pertaining to the Company with anyone. 

How and When We Disclose the Information We Collect.

Company may share your Personal Information with trusted vendors and partners who work with Company. These partners are provided with your Personal Information to help Company communicate with you about offers from us and from our marketing partners. They are contractually required to keep this Personal Information secure and to only use it for the purposes for which it is provided. Company may send Personal Information about you to other companies or people when we need to share your information to provide the Service you have requested or to provide a Service to you. However, these companies are only permitted to use the Personal Information for these purposes.

Company may also disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with law or legal process or if requested by duly authorized public authorities; (b) comply with the order of a competent judicial authority in any jurisdiction; (c) comply with legal process served on Company; (d) protect and defend the rights or property of Company, or our affiliated companies, their employees and agents; (e) enforce our Terms of Use; (f) protect against fraud or other illegal activity or for risk management purposes; (g) permit us to pursue available remedies or limit the damages that we may sustain; and (g) act in urgent circumstances to protect the personal safety of you and other users of Services or the public at large.

If Company should ever file for bankruptcy, or become insolvent, or be acquired by a third party, or merge with a third party, or sell all or part of its assets, or transfer substantially all or part of its relevant assets to a third party, then Company is entitled to share the Personal Information and all other information you have provided through the Website to potential and subsequent business and merger partners.

Company may share “cookie” and other anonymous data about traffic patterns or usage collected on or through the Website with affiliated companies, its business partners or with third party advertisers or ad networks. Any data shared will be anonymous and will not identify you or any particular user.

What Rights Do You Have Regarding Your Personal Information?

You always have the right to request information about the Personal Information we have stored about you, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection.

You may also, of course, file a complaint with the competent regulatory authorities.

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient.

The data processed before we receive your request may still be legally processed.

If you no longer wish to receive communications from Company, you can opt-out from receiving such messages in the future by following the instructions in the message or contacting us directly.

You may also adjust your advertising preferences on various social media websites by adjusting your settings on the platform.

If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, or you are a citizen of a member state of the European Economic Area, you have the following rights under the EU General Data Protection Regulation (GDPR).

If you are currently a resident of the European Economic Area (“EEA”) you have certain rights related to your Personal Information.  Below are the rights that you have under applicable law, and what the Company does to protect and preserve those rights. If you have a question about any of the rights below, or would like to exercise any of these rights, please contact the Company at [].

Legal right


What the Company Does

The right to be informed


The Company has created and published this Privacy Policy to keep you and other users informed as to what the Company does with your Personal Information. We strive to be transparent about how we use your Personal Information.

The right to access


You have the right to access your information and Personal Information. Please contact the Company if you have any questions about our practices or wish to access the Personal Information the Company has about you. 

The right to rectification


If any of the information or Personal Information the Company has about you is inaccurate or not complete, you have the right to ask the Company to correct it. The Company must also ask any third parties to correct any such data in their possession if it has passed onto them in accordance with this Privacy Policy.  

The right to erasure


If you would like the Company to erase all of your Personal Information in its possession and the Company does not have a legal reason to continue to process and store it, we will erase your Personal Information in accordance with your request, applicable law, and this Privacy Policy.

The right to restrict processing


You have the right to ask the Company to restrict how your Personal Information is processed. In that case, the Company will keep just enough data to make sure we respect your request in the future. 

The right to object


You may, at any time, object to how the Company is processing your Personal Information, even if it is being done so in accordance with this Privacy Policy. 

The right to withdraw consent


If you have previously given the Company your consent to process your Personal Information, but later change your mind, then you have the right to withdraw your consent, at any time, and the Company will stop processing your Personal Information. 

The right to complain to a Supervisory Authority


You have the right to complain to a supervisory authority if you feel that the Company has not responded to your requests or complaints.  You may find your supervisory authority here: 

What is Our Legal Basis for Processing Your Personal Information?

If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we need the Personal Information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect Personal Information from you.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your Personal Information. If we process Personal Information in reliance on your consent, you may withdraw your consent at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Us” section below.

 How Do We Protect Your Personal Information?

Company safeguards the security of the data we collect with physical, electronic, and managerial procedures. We urge you to take every precaution to protect your personal data when you are on the Internet. Company uses industry-standard Secure Sockets Layer (SSL) encryption on web pages used to complete a purchase. This protects the confidentiality of your Personal Information while it is transmitted over the Internet.

While Company takes precautions to ensure the security of your data, no one can completely guarantee the safety of data transmitted over the Internet. As such, the Company cannot and will not ensure or warrant the security of any information (including payment information and Personal Information) transmitted by you or any user via the Website over the Internet, and the Company will not accept any liability for any unintentional or unauthorized results or disclosures.

It is important that you take steps to ensure the safety and security of your Personal Information, for example by not sharing passwords or other Personal Information.  

Third Party Links

The Website contains links to and from websites owned or operated by third party companies or service providers. If you follow a link to any of these third-party websites, please note that these services have their own privacy policies and that the Company does not accept any responsibility or liability for those companies or their privacy practices. You should review the individual privacy policies before you submit any information to those websites or services.

Compliance with Laws and Law Enforcement Requests; Protection Of Our Rights

In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

Public Forums

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Public Area”). You should be aware that any information that you post or provide in a Public Area is not private, and might be read, collected, and used by others who access it. We do not warrant or control how any such user will utilize any comment or information you provide in a Public Area.

California Residents

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request certain information from companies operating in the State of California, including information regarding such Company’s disclosure within the preceding calendar year of that California resident’s Personal Information to third parties for direct marketing purposes. Additionally, the law provides that a company may comply with the law by disclosing in its Privacy Policy that it provides consumers a choice, to opt-out or opt-in, before sharing Personal Information with third parties for direct marketing purposes.  

Currently, the Company does not share Personal Information with third parties or their affiliates for direct marketing purposes. Should this policy change in the future, then the Company will provide you with a choice to opt-in or opt-out prior to sharing your Personal Information with any third parties or their affiliates for their direct marketing purposes. 

If you are a resident of California, under 18 years of age, and you utilize the Services, you may ask us to remove content, information, and/or Personal Information that you have provided to the Company by writing to [].  

Please note that your request will not ensure complete or comprehensive removal of the information or Personal Information, as, for example, another user may have accessed or copied your Personal Information you provided in a Public Area.


We respect children’s privacy in particular. We do not target knowingly or intentionally collect personally identifiable information from children under the age of 13. By using the Website, you have represented and warranted that you are either 18 years of age or using the Website with the supervision of a parent or guardian. If you are under 13, you may not use the Website. If you become aware that your child has provided us with Personal Information without your consent, you are urged to email us at [].

Changes to This Policy

The Company reserves the right to modify or amend this Privacy Policy, at any time and in any manner. If we make material changes to this Privacy Policy or change how we process your Personal Information, then we will notify you and seek your consent. We will also change the date this Privacy Policy was last modified at the top of this Privacy Policy.

Notice to You

If we need to provide you with a notification or information about the Services, whether for legal or other business-related purposes, then we will send you such notifications and information via the email address you provided during the Account creation.  

Contact Us

If you would like to contact us for any reason regarding our privacy practices, please e-mail us at the following address: [