Walcony Privacy Policy
Last Updated January 22, 2018 

Walcony LLC is committed to protecting your privacy. This Privacy Policy applies to TubeGrow.com and governs data collection and usage including Tube Grow website and email services. TubeGrow.com is a site owned and operated by Walcony LLC. This Privacy Policy is effective upon beta request submissions, acceptance in registration for new registering members, and is otherwise effective on the date noted above for all Tube Grow members. 
Walcony LLC, referred to on this website as Walcony is a WA Limited Liability Company.
While the word "privacy" may mean different things to different people, we believe that once you understand how we use your information, the steps we take to protect it, and the resulting benefit to you, you will not only feel confident when sharing information with us, but will also find your participation in the program a most rewarding experience. 

1. Collection of Information
Walcony collects both personal and non-personal information using the methods listed below. Our primary purpose in collecting such information is to provide you with a personalized Tube Grow experience by displaying content and delivering offers that are likely to be of interest to you according to your preferences.

Tube Grow may also use Google Analytics Advertising Features to collect data on its website visitors and users. These data may be used for remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers. This means that Google Analytics collects data about the visitors and users via Google advertising cookies and anonymous identifiers, in addition to data collected through a standard Google Analytics implementation on Tube Grow. Note that you can visit Google's currently available opt-outs for Google Analytics.

2. Information Collected at Beta or Sign-up request
To evaluate if a candidate is going to be able to help Tube Grow and the community of the members that use the site, Tube Grow collects personal information, including email address, YouTube channel, location, type and version of the internet browser used by the user, as well as IP address. We may also ask for a user to provide additional personal information, including basic contact information (such as your first name and last name), demographic information (such as your zip code, age and gender), social media account information, and the users topics of interests (such as playing games, blogging topics, sports, etc.). The enrollment information requests may change from time to time. Although additional demographic information may be requested at the time of registration, only information marked "required" is necessary for registration and utilization of our services. Once you submit information to Tube Grow, you are not anonymous to us.

3. Information Collected at Registration
To take advantage of the offers available at Tube Grow, you must register for our service and become a Tube Grow Member. Tube Grow collects personal information when you register with us and when you use Tube Grow or Walcony services. We may combine information about you that we have with information we obtain from business partners or companies. During registration, we require members to give us basic contact information (such as your first name, last name and e-mail address) and demographic information (such as your zip code, age and gender), as well as information to identify your YouTube channel (such as YouTube channel ID). The registration form information requests may change from time to time. Note that submitting information to Tube Grow including to register, will result in you no longer being anonymous to us.

As part of the program, we may be sharing your YouTube channel ID or URL with other members of Tube Grow through the website

We do not knowingly collect any Personal Information from children younger than the age of 13. If you are under 18, you should use Walcony and Tube Grow sites and features and our services only with involvement of a parent or guardian. If you are under 13, you should not submit any Personal Information to us. If we learn that we have inadvertently collected Personal Information from a child younger than 13, we will take commercially reasonable efforts to delete such Personal Information from our databases.

4. Automatic Information Collected though Participation in the Tube Grow Program
When you sign in to the Tube Grow website, the server may automatically recognizes you by your cookie. This cookie acts as a unique identifier, and is linked to your personal information, which allows us to personalize the website to your specified interests and allows you to access your personal information. It also allows us to keep track of your activity on our site and allows us to properly credit points to your account. This information may be added to your personal profile and used to deliver offers and advertisements that are most relevant to your interests. 

The program makes active use of third-party cookies; therefore, full participation in the Tube Grow is dependent upon you setting your browser configuration to accept third-party cookies. We also use cookies to tailor the program to your interests and, most importantly, to ensure that only you can access your account. We also review "log-file" data to monitor site performance and analyze traffic patterns and usage of our site. 

Walcony and Tube Grow services also may retrieve the following information from your browser:

Additionally, for each visitor to our website, our server may automatically recognize the following:

This information, sometimes called log-file or clickstream data, may be used to monitor site performance and ensure the Program functions properly. It may also be appended to your personal profile so that we may further tailor the Program to your interests. 

We and our advertisers currently use third-party cookies and clear pixel GIFs (also referred to as "web beacons") to measure page views on both Tube Grow and advertisers' web sites and email responses. These devices allow us to identify unique visitors to Tube Grow' site, member visits to advertisers' sites, and act as a counter for ongoing monitoring of site, email and corresponding future transaction activity related to a specific offer for both TubeGrow.com and its advertisers. These commonly used counters collect absolutely no personal information and, as always, this technology is only used to enhance the program and make it more relevant to your personal interests.

Third-party cookies are also used to count unique page views, email responses and future activity corresponding to specific offers. Tube Grow will also capture and store your interactions details, which may include your visit and subscription to peer YouTube Channels that we provide to you, date and time of purchase. This information is used to credit your contribution to the peer community and to adjust your account in the event of discrepancies. This information is also used by the Member Services department while assisting you in resolving account inquiries. We may also use your transaction information to provide you more timely relevant offers, products and services. 

5. Information Collected Via Online Surveys, Sweepstakes and Other Promotions
From time to time we may provide you the opportunity to participate in contests, sweepstakes or surveys. If you choose to participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice as to whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address) and demographic information (such as gender and zip code). 

We use this information to notify contest winners and award prizes. We may also use the information gathered to better personalize your Tube Grow program experience. 

We may use a third party service provider to conduct these surveys, contests and sweepstakes. That company is prohibited from using your personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest, sweepstakes or survey with any third party except as allowed under this Privacy Policy or with your prior notice and choice. 
Third party service providers may request and collect information directly from you, while providing their own Privacy Policy. You will need to review their Privacy Policy regarding data collected by them and how your data will be used. This also applies to any information that such third party provider may collect from you using automated processes.

6. Information Collected at Enrollment for a Paid or Other Enhanced Product or Service
If you choose to enroll for any paid or other enhanced product or service beyond a basic registration as described in Section 2 above, you may be required to provide us with certain contact information, such as your name, e-mail address and billing address. We may also require other information necessary to access the paid or other enhanced product or service or process any applicable payment, such as a credit card or debit card number and expiration date. We may use the information you provide us to bill you for products and services you request, or to notify you of additional products and services we may offer. When you sign up for a paid or other enhanced product or service on the Site, you are consenting to our delivery of this information to our service providers, which may include banks and credit card companies that we use to process a transaction or other third parties who may provide all or a portion of the underlying transaction service, product or service on our behalf. 

7. Use and Disclosure of Personal Information
We do not rent, share, trade or sell your personal information to anyone outside of Walcony LLC or its affiliates, parent or subsidiary companies for promotional purposes without your express consent. When we do share data with our advertisers it is in aggregate form and is designed to ensure you are not identified personally. We may allow other companies, such as our marketing partners and companies that are affiliated with us, any parent or subsidiary companies, to offer their products and services to you or to co-register you on their websites, or to otherwise communicate with you about their products and services, whether through the Tube Grow website, a co-branded website hosted by the third party, or email. Whether or not you decide to participate in such an offer is up to you. If you purchase a product or service from a third party or agree to co-register on a third party's website, any of which requires you to submit financial and/or personally identifiable information, you are also consenting to our delivery of this information to that party. The offer will notify you if any financial or personally identifiable information will be shared. Such third party will be authorized to use this information in keeping with our contractual relationship with them and in accordance with their own privacy policy and information practices. We do not control these third parties and you agree that Tube Grow is not liable for their acts or any failure to act on their part. 

Tube Grow engages in content sharing, member referrals, email and direct mail marketing. Because email is an integral part of the program, you sign up to receive email targeted to your interests at the time of registration. If you later decide you wish to cease participation in this portion of the program, you may do so at any time on this page: https://TubeGrow.com/unsubscribe . To further ensure we have your consent, we make sure each e-mail we send you contains an additional opportunity to "opt out" of receiving future e-mails. If you are not interested in receiving either e-mail or direct mail marketing, you may choose to opt out from receiving the e-mail or close your membership. 

Although we house our data in the United States, it is possible that some of our data processing may occur outside of the United States. While the data protection laws of these countries may vary, we will make every reasonable effort to protect your information based upon the express terms of this Privacy Policy. By enrolling in the program, you consent to this transfer of your personal data. 

As long as you remain a Tube Grow member, opting not to receive email does not exempt you from receiving administrative emails, which include, but are not limited to, notices about vital program and membership status changes or alterations to our Terms of Service. 

We may, without your consent, access and disclose your personal information, any communications sent or received by you, and any other information that we may have about you or your account in the following circumstances: as may be permitted or required by law, regulation, rule or court order; pursuant to requests from governmental, regulatory or administrative agencies or law enforcement authorities; or to prevent, investigate, identify persons or organizations potentially involved in, or take any action regarding suspected fraud, violations of our Terms of Service, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your personal information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your personal information in any way relates to that threat. 

8. Access to Personally Identifiable Information
If your personally identifiable information changes or if you no longer desire our service, you may correct, update, or delete it by making a change on the Update My Account page, by emailing us at [email protected] , or by writing: 

Walcony - Tube Grow Member Services
2518 140TH ST SW
Lynnwood, WA 98087-1217 

9. Member Communications and Email
Tube Grow employs a strict policy against sending unsolicited email. Because email is an integral part of the program, you sign up to receive email targeted to your interests at the time of enrollment. If you later decide you wish to cease participation in this portion of the program, you may do so at any time by clicking on the opt-out links contained within each Tube Grow email or by sending an email to [email protected]

Please note that opting not to receive email does not exempt you from receiving administrative emails that include but are not limited to, notices about vital program and membership status changes, Privacy Policy and Terms of Service updates and purchase and redemption confirmation emails. 

Our Member Services Department may contact you in response to your inquiries, to provide services at your request and to manage your account. We will communicate with you by email, telephone or fax in accordance with your wishes. 

10. Tube Grow Advertisers and 3rd Party Websites
The Tube Grow website and emails contain links to various other sites that are not owned by us. While Tube Grow makes every effort to ensure that our advertisers post clear and complete Privacy Policies and observe appropriate data practices, each of these sites has a privacy policy that may differ from that of Tube Grow. The privacy practices of other websites and companies are not covered by this policy. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collect personally identifiable information. 

Tube Grow may allow other companies, called third party ad servers or ad networks, to display advertisements on the Tube Grow website or in Tube Grow email. Some of these ad networks may place a persistent cookie on your computer. Doing this allows them to recognize your computer each time they send you an online advertisement. In this way, ad networks may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. Tube Grow does not have access to or control over the cookies that may be placed by these parties on your computer, and has no control over these parties' privacy policies or information collection practices.

Except as specifically set forth below, it is our policy not to provide your personally identifiable information to our advertisers unless you make the choice to share it with them. We occasionally pass personally identifiable information via a secure interface to certain of our advertisers for the purpose of making it easier for you to sign up for their offers. However, this information is only to be used by the advertiser if you agree to submit the information to the advertiser for the purposes of completing an offer. 

We occasionally use third parties to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, processing transactions, or performing statistical analysis of our services. We will only provide these third parties the personal information they need to deliver the service. They are required to maintain the confidentiality of your information and are prohibited from using that information for any other purpose. 

We may share non-personally identifiable information collected via the program in aggregate, anonymous form with advertisers or other third parties so that they may better evaluate what products and services are most appealing to different segments of our member base. We do not disclose your first name, last name, address, email address, or any other personally identifiable information to these third parties unless you give your express consent. 

We occasionally send the information we gather about our members (which may include personally identifiable information) to trusted third-party data processors to organize, process and/or analyze the data on our behalf. We use this information to enhance our program offerings, namely to tailor advertisements, updates, and offers to your particular interests and to ensure that your opt-out requests are honored. All such third-party data processors are prohibited from using this information except to provide these services to Tube Grow. They are contractually bound to observe the strict policy stated herein, so you can rest assured that the confidentiality of your personally identifiable information will be maintained. 

11. Testimonials
Our users may submit testimonials about Tube Grow on our site. In such cases, the user is provided choice as to whether their personally identifiable information is posted along with the testimonial. In addition, Tube Grow has forums available to its users that allow them to post opinions or testimonials about third-party products and services. You should be aware that any personally identifiable information you submit through these forums can be read, collected or used by other users of these forums, which they could then use to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. 

12. Refer-a-Friend
If you elect to use any of our referral services for informing friends about our site, you will be asked to provide your friends' names and e-mail addresses. You may enter this information manually, or you can also choose to import your contacts from your email address book, in which case you will be asked to provide us with your email address and password, which will be used solely for the purpose of importing your contacts within the referral service. We will then automatically send your friends a one-time e-mail, plus a reminder email (both of which may include your name and email address) inviting them to visit our site. We ask for this information for the sole purpose of sending these emails and tracking the success of our referral program. 

13. Data Verification and Supplementation
Data verification involves the use of third-party data processing services to standardize and clean your provided enrollment information so that it is easily identified and accessed in our database. Data supplementation involves appending any publicly available information about you to your personal profile. 

In order to provide you with the most rewarding experience, we might send your information to data processors so that they can clean your address and standardize to ensure it is most accurate and up-to-date. Next, we might seek out any information about you that is publicly available on the open market and overlay this data onto ours for comparison purposes. All of this results in a program that is tailored to your personal interests and provides you with the most relevant opportunities. 

We use this information solely for the purpose of enhancing the offerings of the Tube Grow Program, namely to tailor content, advertisements, updates, and peer interactions to your particular interests. All such third-party data processors are contractually bound to observe the strict policy stated herein, so you can rest assured that the confidentiality of your personal information will be maintained. 

14. Security
TubeGrow.com has established company-wide industry-standard security practices for your protection. These practices include, but are not limited to, firewall security, the use of appropriate encryption technology (such as Secure Socket Layer (SSL) software), and the use of multiple levels of password security to limit access to data on a "need-to-know" basis. 

We may use contractors or vendors to help us provide some of the services at our site. If we disclose personal information for them to provide the services, it is with the requirement that the information is kept confidential and used only for those services. All contractors and employees are required to familiarize themselves with, and abide by, these safeguards. 

15. Changes to this Privacy Policy
We may amend this policy from time to time. If we make any material changes in the way we use your personally identifiable information collected at this site (TubeGrow.com) we will notify you by email and at the top of this Privacy Policy web page. For questions and concerns about the information collected or used at this site, please contact [email protected]

If you have any questions or suggestions regarding this Privacy Policy, please contact us at [email protected] or at: 

Walcony LLC
Attention: Tube Grow Member Services (Privacy)
2518 140TH ST SW
Lynnwood, WA 98087-1217