Toni McKinley, LLC

Privacy Policy

Last updated: July 23, 2018


Welcome to Toni McKinley, LLC

This Privacy Policy describes how we, Toni McKinley, LLC, obtain and use information about you and your visits to our website at and your participation in Toni McKinley, LLC and your use of Toni McKinley, LLC mobile applications. To offer the personalized experience of Toni McKinley, LLC, we collect personal information about you (“Personal Data”). This policy describes how we collect, use, and share your Personal Data with your Host and other Members in connection with your use of the Service, including our mobile applications. Unless defined here, capitalized words have the same meaning as in the Toni McKinley, LLC  Terms of Use, which this Privacy Policy is part of.


I. Information we collect and how we use it

When you visit our website, interact with us or your Host through the Service, or use our mobile applications, we, as the service provider for your Host, collect Personal Data and other information from you (collectively, “Data”). We use your Personal Data to be able to provide the Service to you:

  • We collect Personal Data when you share it voluntarily.

  • We collect some Personal Data automatically when you visit our website, use the Service or use our Toni McKinley, LLC mobile applications.

  • We and your Hosts use your Personal Data to provide and improve the Service, understand how you and other Members are using Toni McKinley, LLC and to inform you about products and services that may be of interest to you.

  • Data does not include Your Content or User Generated Content. As we explain in our Terms of Use, you (and the people you license Your Content from) keep complete ownership of all Your Content. By posting Your Content on the Service, you grant us a license to use it, but you and your licensors still own it.


A. Personal Data you provide directly

‘Personal Data or Personal Information’ means any information relating to you from which you can be identified, directly or indirectly, including your name, identification number, location, online identifier such as your IP address or device ID, or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

‘Special Categories of Personal Data’ means data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and data concerning your health, sex life or sexual orientation.

‘Aggregated Data’ is data in a summary form for statistical analysis. A common purpose of aggregation is to get more information about particular groups based on specific variables such as age, profession, or income level.

‘Pseudonymisation’ means the processing of your personal data in a way that the personal data can no longer identify you without the use of additional information, so long as the additional information is kept separately and is subject to technical and organizational measures to prevent you from being identified or identifiable.

Name and Email Address. When you register as a Host or Member of a Toni McKinley, LLC, we ask you for your real name and your email address. Both we and the Host of the Toni McKinley, LLC receive access to this information and use it to communicate with you about the Service. In addition, we and your Host may use this address to email you about products or services believed to be of interest to you.

If you a paying Host or Member, we may also collect your mailing address and zip code for billing purposes. Hosts may decide to collect your mailing address, via our Services.

Other Personal Data You Provide Directly. You may also provide us Personal Data when you use certain features of the Service such as participating in conversations or polls in your Networks, contact us with inquiries, or respond to one of our surveys.

B. Personal Data and Information we collect automatically

Information About Your Use of the Service. Our servers automatically record your visits to the Service. Like all other website and mobile app servers, ours compiles a log that records the date, time, browser (i.e., Firefox), device type (i.e., iPhone), operating system (i.e. Android), and originating IP address of each page you visit.

We use cookies to collect information about your visits to our website and Service. Cookies are text files placed on your computer by websites to collect standard log information and visitor behavior information. Our cookies collect the following information about you: which website or ad you visited right before ours, which pages you visited on our Service, and how much time you spent on each section of our Service. We may also collect other data about your visit, such as search requests and results. We use this information for our legitimate interests to track usage of our Service, to measure the number of unique visitors to the different sections of our Service, to understand how Members find Toni McKinley, LLC, and to help us make our Service more valuable to every Host and Member. The use of this information is called “analytics.” Often information used for analytics is aggregated.

You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our Service features may not work properly without cookies. Most browsers accept cookies automatically but allow you to disable them. For more information about cookies visit


C. Personal Data and Information Third Parties collect automatically

Third-Party Cookies for Site Use Analysis. We use third parties such as Google to help us analyze how people are using our Service. We also use the Google Analytics service to provide us with demographic data about our Hosts and Members, such as age and gender. Google uses a cookie that can be recognized by Google or its affiliate DoubleClick when you visit other websites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy-Partners website at

Third-Party Cookies Used to Target Ads to You When You Use the Service or are on Other Websites. “Beacons” are transparent pixel images that are used in collecting information about website usage across websites and over time. Our Hosts may use their own or third-party cookies or beacons to target Host ads to you when you visit other websites. Our Hosts may also work with other companies who use their cookies or beacons to target third party ads to you on other websites based on your prior visits to the Host’s Network on our website Service. This is called online behavioral advertising (“OBA”) because you receive ads based on your prior online behavior. We do not have access to these cookies; it is third parties who engage in OBA.

II. Our Sharing of your Personal Data and other information

We consider personalizing Toni McKinley, LLC experience an important part of our Service. We want you to understand what Personal Data gets shared with your Hosts, other Hosts or Members of our Service, and other third parties as part of the Service.

'Third Party' means a person or company who is not a Host or another Network Member, and government bodies and public agencies and authorities. Third Parties include our service providers whom we authorize, through a data processing agreement, to process your personal data or information to help us with: development, maintenance, and support of our websites and mobile applications, marketing and advertising, marketing research and analysis, communications, and customer service. We do not permit our Third Party service providers to use your personal data for any other purpose. We do not share Personal Data with any person or company unless we have an agreement with them that controls their use of the data.

'Processing' or ‘Process’ means any operation or set of operations performed on personal data or on sets of personal data, including by automatic methods, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing, transmitting, sharing or otherwise making available, aligning or combining, restricting, erasing or destroying.

'Consent’ or ‘Agree’ means your freely given, specific, informed and unambiguous expression of your wishes through a statement or other clear affirmative action such as checking a box which indicates your agreement to our processing of personal data relating to you.

If you are not comfortable with this type of sharing, don’t use our Service.


A. Personal Data shared within the Service

Your Host

Your Host, or Hosts if are there more than one, will have access to your name, email address, and all personal or contact information that you provide when you register for that Host’s Toni McKinley, LLC Network. In order to facilitate Member engagement, our Host will also have access to Data regarding your usage activity, in both aggregated and personally identifiable forms. For example, Hosts will be able to see aggregated Member activity within Toni McKinley, LLC Network, as well as specific information like how many people cheered in response to a comment you made. Your Host also will be able to associate Your Content, and any Personal Information it contains, with your contact information. If you have agreed, your Hosts may communicate with you outside of the Service about Toni McKinley, LLC or relevant topics of interest to you, and may retain your personal information after you leave Toni McKinley, LLC. You should only join Toni McKinley, LLC Network if you are comfortable sharing your personal information with the Host of Toni McKinley, LLC.

Searching and Messaging by Others

Visitors to our Service may be able to search for you by your name and location if you are a Member of Toni McKinley, LLC Network. Members of Toni McKinley, LLC Network can search for you by location, Topics, or other personal information so that they may message you within the Toni McKinley, LLC Network. Whether your information is available to other Visitors and Members depends on whether the Toni McKinley, LLC Network is Public, Private, or Secret.

Public, Private, and Secret

 A Host can select whether to make Toni McKinley, LLC Network Public, Private, or Secret.

  • In Public Toni McKinley, LLC, all Visitors (including Hosts and Members) can see your name and photo (“Profile”), as well as Your Content and activity. Unless your Host specifies otherwise, in a Public Toni McKinley, LLC Network, search engines like Google index all public activity, including Profiles. In a Private Toni McKinley, LLC Network, only Hosts and other Members can see Profiles, Your Content, and activity.

  • In Private Toni McKinley, LLC Network, any Visitor can find the Toni McKinley, LLC Network, but cannot enter without an invitation or membership request approval.

  • In Secret Mighty Networks, only Hosts or other Members of that Toni McKinley, LLC Network can see Profiles, Your Content, and activity. Only Members directly invited can find a Secret Toni McKinley, LLC Network. It is not available to search engines.


Personal Information Included in Your Content

 If you include personal information in Your Content, it will be displayed to other Members based on the privacy levels defined above.


B. Personal Data and Information shared with Third Parties

Legal Requirements. We may disclose your Personal Data if required doing so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) cooperate with a legal investigation or a request from a government authority, (iii) protect and defend the rights or property of Toni McKinley, LLC, (iv) protect the legal rights, safety, and security of users of our website and the Service, (v) protect our legal rights and legitimate interests, and those of our business partners, service providers, and customers; (vi) prevent fraud; (vii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (v) protect against legal liability.


C. Aggregated data shared

We disclose aggregated statistics, such as the number of Hosts and Members, in order to describe our Service to current and prospective business partners, and to our Third Party service providers for our legitimate interests and other lawful purposes.


III. Your Personal Data Rights

You have rights regarding the Personal Data and Information we have about you.

You may object to, or restrict, our collection, use, sharing, transfer and/or storage of your personal information. You may also request a copy of the information that we have about you. You may also ask us to correct or remove personal information you think is incorrect.

If a Host (the data controller) is using the Service to process your personal information, you may contact the Host to object, restrict, access, correct or delete your personal information. If you need help finding contact information for your Host’s privacy officer, please contact us using our contact information below.

If you have a registered account in the Service, you may object, restrict, access, correct, or request deletion or a copy of some or all of your Personal Data or Information by logging in to your account.

If you do not have a registered account in the Service and you would like to object, restrict, access, correct, delete, or request a copy of some or all of your personal information, please mail us at the following address: Toni McKinley, LLC.

P.O. BOX 170525 Austin, TX 78717

We will respond to your request within a reasonable period of time.

Please note, we will keep your personal information for as long as necessary for us to provide the Service to you. We will also keep and use your personal data or information to comply with laws including tax laws and other applicable laws. We will also keep your Personal Data and Information as necessary for backup, archiving, audit, preventing fraud, resolving disputes, and troubleshooting problems.

If you are located in the European Union (EU), European Economic Area (EEA) or Switzerland, please see also the EU-US and Swiss-US Privacy Shield section below about how to make complaints regarding personal data collected in the EU and transferred to the U.S. under the Privacy Shield Frameworks.

You may also make a privacy or data use complaint about us to the Data Protection Authority in the EU/EEA Member State where you live or work by visiting the Office of the Data Protection Commissioner list of Data Protection Authorities at Our GDPR Article 27 Representative is Antonius Kromwijk, Managing Director, Glownexus Nederland B.V., Wilsonsplein 15, 2011 VG Haarlem, Netherlands. You can email him at Our Data Protection Officer is at


IV. Your choices

A. Join Toni McKinley, LLC and Hosts you trust

You get to decide if  Toni McKinley, LLC is the network you want to join. You also get to decide whether you trust your Host with the information sharing described in this policy.

B. Public, Private, or Secret Toni McKinley, LLC settings

A Host can choose to make a Toni McKinley, LLC Network Public, Private, or Secret as described above.

C. Adjust your notification settings

In your account settings, you can control the frequency, type, and mode of notifications you receive through the Service. You can choose to be notified by email or mobile alerts, both, or neither. You can choose to turn on or off your notifications by types, such as cheers on your posts, and questions you can help answer.

D. Opt out of email

We would like to send you information about our services that you may be interested in. If you have agreed to receive marketing messages from us, you may opt-out at any time. We provide an opt-out link at the bottom of each email message. Because we plan our communications in advance, it may take several weeks for your opt-out request to take effect. If you continue to receive marketing messages from us or a Host after you opt-out, please let us know so that we can investigate the situation.

E. Opt out of Google Analytics

To prevent your data from being used by Google Analytics, click here for instructions.

F. Opt out of Google behavioral advertising

To opt out of Google behavioral advertising, click here to see your Google ad settings.

G. Opting out of tracking

Please see our Cookie Policy for important information about non-Google cookies that are placed by us or by our business partners on your computer, mobile phone or other device and how to opt out. We do not have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other devices by non-affiliated, third-party ad technology, ad servers, ad networks, or any other non-affiliated third parties. If you would like to learn more about OBA or to opt out of having this information used by companies that are part of the Network Advertising Initiative to deliver targeted ads, please visit, or if you are located in the European Union/European Economic Area, please visit European Interactive Digital Advertising Alliance (EDAA) Your Online Choices website at Please note you will continue to receive generic ads.

H. Deleting cookies

To manage or delete browser cookies, please see your browser's privacy settings.


V. Account termination

You can leave one or more of your Toni McKinley, LLC Networks, or delete your Toni McKinley, LLC Network account (on a Network by Network basis). As soon as you leave, we stop collecting your Personal Data for that Toni McKinley, LLC Network. 


VI. Exclusions

This Privacy Policy does not apply to any Personal Data collected by Toni McKinley, LLC outside the Service, such as a telephone call. This Privacy Policy does not apply to any unsolicited information you provide to Toni McKinley, LLC through the Service or through any other means, such as information posted to any public areas of the Service, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Toni McKinley, LLC shall be free to reproduce and use such Unsolicited Information without limitation or attribution. We respect your copyrights in Your Content, as outlined in our Terms of Use.

If your Host has an additional privacy policy covering the Host’s use of Personal Data, you should review it carefully, because it may be different from this Privacy Policy.


VII. Disputes with Hosts or other Members

Toni McKinley, LLC cannot control the actions of Hosts or other Members; if you have a privacy-related dispute with a Host or another Member, you should contact that person directly. You should alert us if you believe that a Host or another Member has violated this Privacy Policy.


VIII. Children

Toni McKinley, LLC does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not use the Service or submit any Personal Data through the Service. If you have reason to believe that a child under the age of 13 has provided Personal Data to Toni McKinley, LLC through the Service, please contact us at and we will look to delete that information from our databases.


IX. Links to other web applications

This Privacy Policy applies only to the Service. The Service may contain links to other websites not operated or controlled by Toni McKinley, LLC (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Service do not imply that Toni McKinley, LLC endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices.


X. Security of Your Personal Data

We use appropriate technical and organizational measures including encryption, aggregation, and pseudonymization to protect your Personal Data provided via the Service from loss, misuse, and unauthorized access or use, disclosure, alteration, or destruction. However, no Internet, email, or other electronic transmission is ever 100% secure or error free, so we cannot guarantee that your Personal Data will never be accessed, used, or disclosed, so you should take special care in deciding what information you share on the Service.

“Phishing" is a scam designed to steal your Personal Data or Information. If you receive an e-mail that looks like it is from us asking you for information about you, please contact us.


XI. Your California data privacy rights

California law permits Visitors who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their personal information for direct marketing purposes in the prior calendar year, as well as the type of personal information, disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to


EU-US and Swiss-US Privacy Shield

Toni McKinley, LLC strives to comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of your Personal Information transferred from the European Union and Switzerland transferred into the United States under the Privacy Shield Frameworks.

We will comply with the Privacy Shield Principles for as long as we keep the Personal Information we collect about you under the EU-US and Swiss-US Privacy Shield Frameworks. To learn more about the Privacy Shield List please visit

As explained above in this Privacy Policy in Section II(b), we sometimes share your Personal Information with Third Party service providers so they can perform services for us. Our business model does not allow us to share your Personal Information with Third Parties who are not our service providers. If that changes, we will seek your consent to share your Personal Information with them. See also Section IV(e), (f) and (g) for how to opt out of cookies. If we share Personal Information we have received under the Privacy Shield Frameworks with a Third Party, that Third Party’s access, use, and disclosure of your Personal Information must also comply with our Privacy Shield obligations. We may be liable for any failure by any of our Third Parties to comply with the Privacy Shield Principles unless we prove that we are not responsible for the event giving rise to the damage.

Under the Privacy Shield Frameworks, we are subject to the regulatory and enforcement authority of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information requested by government authorities, including for national security or law enforcement purposes.

In compliance with the Privacy Shield Principles, Toni McKinley, LLC commits to resolve complaints about our collection or use of your Personal Information. If you are located in the European Union (EU), Switzerland or European Economic Area (EEA), and have a question or complaint regarding data collected in the EU, EEA or Switzerland and subsequently transferred to the U.S. under the Privacy Shield Frameworks, you should first direct your question or complaint to You can also write us at the following address: Toni McKinley, LLC P.O. BOX 170525 Austin, TX 78717.

Toni McKinley, LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.

If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit more information or to file a complaint. The services of the BBB EU Privacy Shield are provided free of charge to you.

Finally, as a last resort and in limited circumstances, EU & Swiss individuals with residual complaints may be eligible to request binding arbitration before a Privacy Shield Panel described on the Privacy Shield Annex I website found at



XII. Access to information; contacting us

We acknowledge the right of EU and Swiss individuals to access their personal data under the Privacy Shield. Section III (“Your Personal Data Rights”) explains how to contact us to access your data. To keep your Personal Data accurate, current, and complete, please update your account settings or contact us at the email address below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Service.

Please also feel free to contact us if you have any questions about Toni McKinley, LLC Privacy Policy or the information practices of the Service. Our email address for privacy issues iss Our postal address is Toni McKinley, LLC, PO Box 170525 Austin, TX 78717.


XIV. Changes to Toni McKinley, LLC Privacy Policy

We keep this Privacy Policy under regular review, and we will notify you when we make changes in the future. Please review this policy periodically, and especially before you provide any Personal Data to us. We will also place any updates on our website. This privacy policy was last updated on July 23, 2018 .

We have no liability or responsibility for the privacy policies or practices of our Hosts or other actions of any Integrated Service that may be enabled within the Service.