PRIVACY POLICY
Last Updated: March 31, 2019
Protecting your private information is our priority at Choco Products, LLC. This Privacy Policy informs you of our policies regarding the collection, use and disclosure of personal data Users of the Web site and/or Services. Choco Products, LLC attaches great importance to ensuring that your personal data and crawled data are collected, used, processed and erased in accordance with the current applicable regulations as stipulated by local, state, national, federal, and other data protection legislation. Protecting your data is a matter of great importance to our company. If you have requests concerning your personal information or any questions please contact us support@thebassettway.com.
If you have objections to the Privacy Policy, you should immediately discontinue use of the Web site and our Services.

Definitions

For purposes of this Privacy Policy references to “Customer” mean a registered, paying User of the Services. 

For purposes of this Privacy Policy references to “us,” “we,” “our,” and/or “Choco Products, LLC” mean ChocoProducts, LLC, a Texas limited liability company with a registered place of business located at 30 N Gould, Suite R, Sheridan, Wyoming 82801, and its subsidiaries, parents, and affiliates.
References to the “Services” mean those consulting services provided by us. 

References to the “Web site” mean the Web sites bearing the URL www.thebassettway.net, as well as any other site owned and/or operated by or under the Choco Products LLC brand.
References to “you,” and/or “User,” mean the User of the Web site and/or the Services.

Agreement to be Bound

The following Data Protection and Privacy Policy Statement governs the collection and use of private information via the Web site and the Services. By accessing the Web site and/or registering for the use of our Services you represent that you have read and understand the Privacy Policy and that you agree to be bound by thereby.

This Privacy Policy may be additionally subject to our Terms of Service for those Customers who use our Services.

Modifications and Changes to the Privacy Policy 

We may modify, add to, suspend, or delete the Privacy Policy, in whole or in part, at our sole discretion at any time, with such modifications, additions or deletions being effective thirty (30) calendar days following their posting to the Web and emailing a notice to registered Users. Your access of the Web site and/or use of our Services, after modification, addition or deletion of the Privacy Policy Statement shall be deemed to constitute acceptance by you of the modification, addition or deletion. 

Collection of your Personal Information

We collect both personally-identifiable information or personal data and non-personally-identifiable information from you. Often, you choose what information to provide to us, but, sometimes, we may require certain information for you to use and for us to provide the Services. Specifically, we collect the following: 

Registration & Account Set Up collected via the Web site. In order to register you as a Customer, provide you with support, process your transactions, or allow you to participate in a contest, we will collect personal data, which may include your full name; telephone number; and email address. We also will collect a user name and password.

In addition, you should note that our payment processors may collect and store sensitive financial information, including your credit card number, expiration date, and billing details for those Customers who pay us via credit card. We store the same only as anonymous data and have no access to or control over the sensitive financial information you may provide. 

Automated Information. Choco Products, LLC automatically receives and records information from each User’s browser or your mobile device when you visit the Web site or use certain other Services, such as your IP address in an anonymized fashion or unique device identifier, cookies and data about which pages you visit in order to allow us to operate and provide the Services, and data about the type of device you use to connect to our Services and/or Web site. This information is stored in log files and is collected automatically. We may combine this information from your browser or your mobile device with other information that we or our partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for our Users, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.

We may also automatically collect device-specific information when you install, access, or use our Services. This information may include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers.

Location Information: We may collect information about your use of the Services for advertising, analytics, to serve content and to protect the Services, including your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). We may obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as general location information from GPS or information about wireless networks or cell towers near your mobile device. We may use and store information about your location to provide features and to improve and customize the Services, for example, for our internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for mapping services; and (using non-precise location information) marketing. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the site to function. We will only share your geo-location details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. 

Analytics Information: We use data analytics to ensure site functionality and improve the Services. We do not link the information we store within the analytics software to any personally identifiable information that you submit.

Use of your Personal Information

We may use your personally-identifiable information to process transactions; to provide and improve customer service administration; to personalize your User experience; to contact Users via e-mail, SMS text, or telephone; to respond to inquiries, and/or other requests or questions; to send company news, updates and other related info via our mailing list; and to facilitate registration for and use of our Services .

We may use your non-personally identifiable information to create traffic statistics for our Web site; to create User statistics for our Services; to improve customer service; and to personalize your User experience. 

Choco Products, LLC gives you the choice of providing, editing or removing certain information, as well as choices about how we contact you. You may change or correct your Choco Products, LLC account information through your account settings. You can also request the deletion of the personal information in your account.

Depending on your location, you may also have certain additional rights with respect to your information, such as: (i) data access and portability (including the right to obtain a copy of your personal data you provided to Choco Products, LLC, via your settings); (ii) data correction (including the ability to update your personal data, in many cases via settings); (iii) data deletion (including the right to have Choco Products, LLC delete your personal information, except information we are required to retain, by contacting us); and (iv) withdrawal of consent or objection to processing (including, in limited circumstances, the right to ask Choco Products, LLC to stop processing your personal data, with some exceptions, by contacting us).

You may also control the receipt of certain types of communications from Choco Products, LLC. Choco Products, LLC may send you messages about the Services or your activity. Some of these messages are required, service-related messages for Users (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive via the unsubscribe link in our emails.

If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.

Sharing Information with Third Parties

Choco Products, LLC does not sell, rent or lease its customer lists to third parties. 

Choco Products, LLC may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or provided marketing services. For example, we share data with ClickFunnels, our Web site administrator, and Google Analytics and Google Remarketing, whose services we utilize for marketing purposes. All such third parties are prohibited from using your personal information except to provide these services to Choco Products, LLC, and they are required to maintain the confidentiality of your information.

Choco Products, LLC may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Choco Products, LLC or the site; (b) protect and defend the rights or property of Choco Products, LLC; and/or (c) act under exigent circumstances to protect the personal safety of users of Choco Products, LLC, or the public. Pursuant to the California Consumer Privacy Act (CCPA), Choco Products, LLC has not sold or disclosed consumers’ personal information to a third party in the preceding 12 months.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by Choco Products, LLC. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Choco Products, LLC website.

Use of Cookies

The Choco Products, LLC website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Choco Products, LLC pages, or register with Choco Products, LLC site or services, a cookie helps Choco Products, LLC to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Choco Products, LLC website, the information you previously provided can be retrieved, so you can easily use the Choco Products, LLC features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Choco Products, LLC services or websites you visit.

Security of your Personal Information

Choco Products, LLC secures your personal information from unauthorized access, use, or disclosure. Choco Products, LLC uses the following methods for this purpose:
• SSL Protocol
• Vulnerability scanning
• PCI-Scanningf 
• S-HTTP 

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
In addition, access to your data is restricted to need-to-access individuals. 

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed. Please note that non-encrypted communication using email is not secure. Thus, we cannot guarantee data security in email communication and, therefore, recommend using physical mail for confidential information.

International Transfer

We operate globally so it is necessary to transfer your information internationally. In particular, your information will likely be transferred to and processed via servers located in Provo, Utah, United States. The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the United States, it may be accessed by government authorities in accordance with U.S. law.

To the extent that Choco Products, LLC is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:

Model Clauses. The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of Europe. We often use these Model Clauses when transferring personal information outside of Europe. You can request a copy of our Model Clauses by emailing support@thebassettway.com. 

Privacy Shield. Choco Products, LLC does not participate in Privacy Shield at this time. However, Choco Products, LLC may rely on the EU-US Privacy Shield to transfer personal information to some of our third-party service providers in the United States, where they are certified to receive such information under the Privacy Shield Program.

Necessary for the performance of the contract. Choco Products, LLC provides a voluntary service; you can choose whether or not you want to use the Services. However, if you want to use the Services, you need to agree to our Terms of Service which set out the contract between Choco Products, LLC and its Customers. As we operate in countries worldwide (including in the United States) and may use technical infrastructure in the United States to deliver the Services to you, in accordance with the contract between us, we need to transfer your personal information to the United States and to other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world.
 
Children Under Thirteen; Notice to Minors

Choco Products, LLC does not knowingly collect personally identifiable information from children under the age of thirteen (13). If you are under the age of thirteen, you must ask your parent or guardian for permission to use the Web site and Services. We request that all users of the Web site and our Services who are under the age of thirteen (13) not disclose or provide any personally-identifiable information. If we discover that a child under thirteen has provided us with personally-identifiable information, we will delete that child’s personally-identifiable information from our records. You are responsible for any and all account activity conducted by a minor under your account. 

In addition to protecting the privacy of children under the age of thirteen (13), we are committed to protect the privacy of minors. Though neither our Web site nor our Services is not targeted to minors nor is it intended to be used by minors, if, for any reason a minor has shared information via our Web site and/or Services said minor may request and obtain removal of such information by contacting us at support@thebassettway.com. We do not knowingly collect personally identifiable information from anyone under the age of thirteen (13). If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Although we offer deletion capability, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information provided.

Do Not Track Disclosure

Please note that while you may have the opportunity to opt-out of targeted advertising as discussed in the “How to Opt-Out” section above, and you may be able to control the use of cookies through your Web browser as described in the “Use of Cookies” section below, some Web browsers may also give you the ability to enable a “do not track” setting. This setting sends a special signal to the Web sites you encounter while Web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. We do not respond to Web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Policy. For more information about “do not track,” visit http://www.allaboutdnt.org/.

Retention

Choco Products, LLC will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Choco Products, LLC account), as described in this policy, or as needed to provide the Services to you. If you no longer want Choco Products, LLC to use your information to provide the Services to you, you may close your account. Choco Products, LLC will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.

E-mail Communications; How to Opt-Out

From time to time, Choco Products, LLC may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Choco Products, LLC or click on a link therein. 

Please note that or marketing and promotional communications are opt-in. If you would like to stop receiving marketing or promotional communications via email from Choco Products, LLC, you may opt out of such communications by clicking on the UNSUBSCRIBE link.

Email marketing campaigns published by us may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but shall not be limited to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity. This information is used to refine future email campaigns and supply the User with more relevant content based around their activity.

Your Rights

You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so via your account settings or by contacting us. Upon request, Choco Products, LLC will provide you with information about whether we hold any of your personal information. By visiting your account settings, you can access, correct, change, and delete certain personal information associated with your account. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format. If you need further assistance, you can contact Choco Products, LLC through one of the channels listed below under “Contact Information.” We will respond to your request within a reasonable timeframe.

If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings.

Withdrawing Consent

Where you have provided your consent, you have the right to withdraw your consent to our processing of your information and your use of the Services. For example, you can withdraw your consent to email marketing by using the unsubscribe link in such communications or by changing your account settings. You can choose to withdraw your consent to our processing of your information and your use of the Services at any time by closing your account and then emailing support@officialkevindavid.com to request that your personal information be deleted, except for information that we are required to retain. This deletion is permanent and your account cannot be reinstated.

EU Personal Data

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your personal data. We will be the controller of your personal data processed in connection with the Site.

You have the right to fully access all of your data. Without prejudice to any other administrative or judicial remedy, every user shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the user considers that the processing of personal data relating to him or her infringes this Regulation. 

You have the right to restrict or object to any of our data retention policies. You may request corrections to data. You have the right to delete your data from the site. 

Should you select the optional opportunity to receive promotional emails from us about current offers and incentives, we will also use your email for this purpose. If you have not selected this Opt-in option, you will not receive promotional emails. If you have opted to receive promotional emails, or if you receive transactional emails about your incomplete order, you may choose to remove (Opt-out) this feature at any time and the emails will be stopped. 

Your contact information may also be used should we ever need to contact you. The user has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. Please forward any data inquiries to: support@officialkevindavid.com.

California User Consumer Rights

In accordance with California Civil Code Section 1789.3, California resident Users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. With respect to us, this privacy policy applies only to their activities within the State of California. To make such a request or if you have questions about this privacy policy, please send an email to support@officialkevindavid.com.

Contact Information
Choco Products, LLC welcomes your questions or comments regarding this Statement of Privacy. If you believe that Choco Products, LLC has not adhered to this Statement, please contact Choco Products, LLC at:
4306 N Quinlan Park Rd Apt: 4206, Austin, TX 78732

Email Address: 
support@thebassettway.com
If you live in the EEA, you may also file a complaint with your local data protection regulator.

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