Effective as of October 2, 2023. 


This privacy policy (the “Privacy Policy”) applies to the information collection and 
use practices of our online services, which are made available to you through a variety of 
platforms, such as through the Collective615 mobile application (the "App"), our website 
located at www.collective615.com (the "Site"), and through our social media accounts on 
Instagram and Facebook, and LinkedIn (collectively, "Social Media"), all owned and 
operated by Collective615 LLC, a Tennessee limited liability company ("Collective615," 
"we," "us," or "our"). The App, the Site, and our Social Media accounts are collectively 
referred to as the "Platform." We have created this Privacy Policy to tell you what 
information the Platform collects, how we use that information, and who we will share that 
information with, if at all. This Privacy Policy does not address the privacy practices of 
any third parties that we do not own, control, or are affiliated with. Capitalized terms not 
defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By 
visiting and/or using our Platform, you are agreeing to the terms of this Privacy Policy and 
the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to 
use the information it contains to help you make informed decisions. 



In the course signing up for our services or purchasing products on our Site or 
operating the App, we will collect and/or receive the following types of information. You 
authorize us to collect and/or receive such information. 


(a) Personal Identification Information. We only receive or collect information 
that identifies you personally. When you sign up to become a user or contact us, you will 
be required to provide us with personal information about yourself (collectively, the 
"Personal Information"). Such Personal Information may include your name, e-mail 
address, physical address, phone number, videos or images. When you visit our website or App, your 
IP address is automatically received and stored by servers. We do not collect any 
Personal Information from you when you use the App unless you provide us with the 
Personal Information voluntarily. 


(b) Third-party Log In. If you register or visit the App through an email service 
provider, Facebook Connect, or another social media website, you are authorizing us to 
collect, store, and use, in accordance with this Privacy Policy, any and all information that 
you agreed that the social media website would provide to us through its Application 
Programming Interface ("API"). We do not receive or store your passwords for your social 
media accounts. 


(c) Payment Information. If you choose to make a purchase or subscribe to a 
feature or service ours that requires a fee, you will be required to provide us with your 
payment information, including, without limitation, bank account numbers, credit card or 
debit card numbers, cardholder names, billing address, account details, ACH information, 
and similar data (collectively, "Payment Information"). Such Payment Information will be 

collected and processed by our third-party payment vendors pursuant to the terms and 
conditions of their privacy policies and terms of use, and we do not obtain access to any 
Payment Information in connection with such purchases or subscriptions. 


(d) Geolocational Information. Certain features and functionalities of the App 
are based on your location. In order to provide these features and functionalities while 
you are using your mobile device, we may, with your consent, automatically collect 
geolocational information from your mobile device or wireless carrier and/or certain third-
party service providers (collectively, "Geolocational Information"). Collection of such 
Geolocational Information occurs only when the App is running on your device. You may 
decline to allow us to collect such Geolocational Information, in which case we will not be 
able to provide certain features or functionalities to you. 


(e) Third-Party Analytics. Information you choose to share with our company 
may be treated as public information. We and the third-party technology providers, ad 
exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which 
we work use third-party analytics services (e.g., Google Analytics) to evaluate your use 
of the App, compile reports on activity, collect demographic data, analyze performance 
metrics, and collect and evaluate other information relating to the App and mobile and 
Internet usage. These third parties use cookies and other technologies to help analyze 
and provide us the data. The third-party analytics provider does not receive personally 
identifiable information through the use of cookies. We have also limited the provider’s 
ability to see your full IP address. 


You consent to the processing of data about you by these analytics providers in 
the manner and for the purposes set out in this Privacy Policy. For more information on 
these third parties, including how to opt out from certain data collection, please visit 
[URLs]. Please be advised that if you opt out of any such service, you may not be able to 
use the full functionality of the App. 


(f) Other Information. In addition to the Personal Information, Payment 
Information, and Geolocational Information, we may automatically collect or receive 
additional information regarding you and your use of the App; your interactions with us 
and our advertising; and information regarding your computer and mobile devices used 
to access the App (collectively, the "Other Information"). Such Other Information may 

(i) From You. Additional information about yourself that you voluntarily 
provide to us, such as your gender and your product and service 


(ii) From Your Activity. We may collect or receive information regarding: 

(A) IP address, which may consist of a static or dynamic IP 
address and will sometimes point to a specific identifiable computer 
or mobile device; 

(B) browser type and language; 

(C) referring and exit pages and URLs; 

(D) date and time; and 

(E) details regarding your activity on the App, such as search 
queries and other performance and usage data. 


(iii) About Your Mobile Device. We may collect or receive information 

(A) type of mobile device; 

(B) advertising Identifier ("IDFA" or "AdID"); 

(C) operating system and version (e.g., iOS, Android or 

(D) carrier; and 

(E) network type (WiFi, 3G, 4G, LTE). 


(iv) From Cookies. A cookie is a file containing an identifier (a string of 
letters and numbers) that is sent by a web server to a web browser 
and is stored by the browser. The identifier is then sent back to the 
server each time the browser requests a page from the server. When 
you visit the Site or the App, we may send cookies or other similar 
tracking technologies to your computer or to any other device you 
use. We use cookies and similar tracking technologies to track your 
preferences and to know how you use our services. We may use 
both session cookies, which expire once you close the App, and 
persistent cookies, which stay on your mobile device until you delete 
them and other technologies to help us collect data and to enhance 
your experience with the App. Cookies are small text files an app can 
use to recognize a repeat visitor to the app. We may use cookies for 
various purposes, including to: 

(A) type of mobile device; 

(B) personalize your experience; 

(C) analyze which portions of the App are visited and used 
most frequently; and 

(D) measure and optimize advertising and promotional 


If you do not want us to deploy cookies in the App, you can opt out by setting your 
mobile device to reject cookies. You can still use the App if you choose to disable cookies, 
although your ability to use some of the features may be affected or result in its blocking. 


For further information visit allaboutcookies.org Cookies are used for user 
identification and proper assignment of historical user data collected during previous 



As described above, we use your personal information and data to provide you 
with targeted advertisements or marketing communications we believe may be of 
interest to you. For example: 

 (a) We may use Google Analytics to help us understand how our 
customers use the Site. You can read more about how Google uses your Personal 
Information here: https://www.google.com/intl/en/policies/privacy/. You can also 
opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 
(b) We may use a Facebook pixel on our website. Using the pixel, 
Facebook collects information about the users and use of our website. The 
information is used to personalize Facebook advertisements and to analyze the 
use of our website. To find out more about the Facebook pixel and about 
Facebook's use of personal data generally, see the Facebook cookie policy at 
https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at 
https://www.facebook.com/about/privacy. The Facebook cookie policy includes 
information about controlling Facebook's use of cookies to show you 
advertisements. If you are a registered Facebook user, you can adjust how 
advertisements are targeted by following the instructions at 
(c) We may publish Google AdSense advertisements on our website, 
together with advertisements from advertisers and advertising networks that are 
distributed by Google. The advertisements may be personalized to reflect your 
interests. Google and its partners use cookies to help determine your interests. 
You can opt out of Google's personalized advertising by visiting 
https://www.google.com/settings/ads and you can opt out of third party cookies 
used for personalized advertising by visiting http://www.aboutads.info. You can 
review Google's privacy policy at https://policies.google.com/privacy. 
(d) We may share information about your use of the Site, your 
purchases, and your interaction with our ads on other websites with our advertising 
partners. We collect and share some of this information directly with our advertising 
partners, and in some cases through the use of cookies or other similar 

 For more information about how targeted advertising works, you can visit the 
Network Advertising Initiative’s (“NAI”) educational page at 


You can opt out of targeted advertising by: 

 FACEBOOK - https://www.facebook.com/settings/?tab=ads 
GOOGLE - https://adssettings.google.com/authenticated 
Additionally, you can opt out of some of these services by visiting the Digital Advertising 
Alliance’s opt-out portal at: https://optout.aboutads.info/. 


 We can use different type of cookie or tracking technologies while you are visiting 
our website and/or application: 

(a) Strictly necessary cookies: These types of cookies enable you to access 


and browse websites and use their features. Without these cookies, 
services like billing or shopping baskets cannot work properly. 
(b) Performance cookies: These cookies collect information and data about 
how you use our websites and/or application. The data collected can be 
used to optimize our websites and/or applications. These cookies are 
used to know where our visitors and users are coming from. These 
cookies do not collect information that identifies you personally. 


(c) Functionality cookies: These cookies allow our website or application to 
remember your choices. They can be used to memorize your 
localization, or your preferences such as language settings or font size. 

You can set your browser not to accept cookies and the above website and/or 
application tells you how to remove cookies from your browser. However, some of our 
websites and/or applications might not work properly without the use of cookies. 


Here are some of the main explanation on how to delete cookies on your browser: 

CHROME https://support.google.com/chrome/answer/95647 


FIREFOX https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-


OPERA - https://help.opera.com/en/latest/security-and-privacy/ 


INTERNET EXPLORER - https://support.microsoft.com/en-


SAFARI - https://support.apple.com/en-gb/guide/safari/manage-cookies-and-


EDGE - https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-


For mobile devices, if you don’t want to receive targeted advertising based on your 
center of interest coming from a mobile application, please check the parameters of the 
operating system of your mobile device and follow these instructions: 1) iOS Users: to 
enable “Limited Ad Tracking” follow the instructions given by Apple. 2) Android Users: to 
enable the option “deactivate ad personalization”, follow the instructions given by Google 
on Google Play. 3) You might want to download the DAA mobile AppChoices application 
to control behavioral advertising online. 



(a) You provide us with most of the data we collect. We collect data and process 
personal data and information when (1) you register online or use services online or (2) 
use the website or application when cookies are set on your device. 


(b) Our company might also receive data and information indirectly from the 
following sources: 


 Flurry (https://www.flurry.com) 

Firebase (https://www.firebase.google.com) 

Count.ly (https://count.ly) 

AppsFlyer (https://www.appsflyer.com) 

Facebook App Event (https://developers.facebook/coom/docs/app-events) 


(c) We may share Other Information about your activity on the App with third 
parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., 
behavioral, contextual, retargeting, analyzing, managing, reporting, and optimizing of 
ads). These third parties may use cookies, pixel tags (also called web beacons or clear 
gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags 
enable us and these third-party advertising companies to recognize a browser's cookie 
when a browser visits the site on which the pixel tag is located in order to learn which 
advertisement brings a user to a given site. In addition, we may receive Other Information 
from advertisers and/or their service providers such as advertising identifiers, IP 
addresses, and post-conversion data. 



If you wish to opt out of third-party interest-based advertising, please visit 
http://www.networkadvertising.org and http://www.aboutads.info/choices for details on 
how to do so. Additionally, users of mobile Devices can follow the below instructions: 


Android Users: For Android devices with OS 2.2 and up and Google Play Services 
version 4.0 and up: Open your Google Settings app & go to; Ads & go to; Enable "Opt out 
of interest-based advertising." 


iOS Users: iOS 7 or Higher: Go to your Settings & go to; Select Privacy & go to; 
Select Advertising & go to; Enable the "Limit Ad Tracking" setting. 

iOS 6: Go to your Settings & go to; Select General & go to; Select About 
& go to; Select Advertising & go to; Enable the "Limit Ads Tracking" 



(a) You authorize us to use the Personal Information, Payment Information, 
Geolocational Information, and the Other Information (collectively, the "Information") to: 

(i) provide and improve our App; 

(ii) provide our services; 

(iii) administer our promotional programs; 

(iv) solicit your feedback; and 

(v) inform you about our products and services. 


(b) Within our company we restrict access to personally identifiable information to 
employees, contactors, and vendors, subject to non-disclosure requirements who require 
access to information in order to perform their official duties and exercise controls to limit 
what data they can view based on the specific needs of their position. 


(c) In order to provide our services and administer our promotional programs, we 
may share the Information with our third-party promotional and marketing partners, 
including, without limitation, businesses participating in our various programs. 


(d) We engage third-party companies and individuals to perform functions on our 
behalf. Examples may include providing technical assistance, customer service, 
marketing assistance, and administration of promotional programs. These other 
companies will have access to the Information only as necessary to perform their 
functions and to the extent permitted by law 


(e) In an ongoing effort to better understand our users, the App, and our products 
and services, we may analyze certain Information in anonymized and aggregate form to 
operate, maintain, manage, and improve the App and/or such products and services. This 
aggregate information does not identify you personally. We may share and/or license this 
aggregate data to our affiliates, agents, business and promotional partners, and other 
third parties. We may also disclose aggregated user statistics to describe the App and 
these products and services to current and prospective business partners and investors 
and to other third parties for other lawful purposes. 


(f) We may share some or all of your Information with any of our parent companies, 
subsidiaries, joint ventures, or other companies under common control with us. 


(g) As we develop our businesses, we might sell or buy businesses or assets. In 
the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar 
event, the Information may be part of the transferred assets. 


(h) To the extent permitted by law, we may also disclose the Information: 

(i) when required by law, court order, or other government or law 
enforcement authority or regulatory agency; or 


(ii) whenever we believe that disclosing such Information is necessary or 
advisable, for example, to protect the rights, property, or safety of us or 
others, including you. 



If you have provided us any Personal Information, you may access, remove, 
review, and/or make changes to the same by contacting us as set forth below. In addition, 
you may manage your receipt of marketing and non-transactional communications by 
clicking on the "unsubscribe" link located on the bottom of any of our marketing e-mails. 
We will use commercially reasonable efforts to process such requests in a timely manner. 

You should be aware, however, that it is not always possible to completely remove or 
modify information in our subscription databases. You cannot opt out of receiving 
transactional e-mails related to the App (e.g., requests for support). 


We may also deliver notifications to your mobile device (e.g., push notifications). 
You can disable these notifications by deleting the relevant service or by changing the 
settings on your mobile device. 



We take commercially reasonable steps to protect the Information from loss, 
misuse, and unauthorized access, disclosure, alteration, or destruction. 


Our company uses commonly used practices and technical controls to protect the 
information in our possession or control. These practices and controls include, but are not 
limited to, encrypting the transfer of personal information over the internet, using firewalls 
and intrusion detection systems and maintaining strict technical controls and procedures 
to ensure data integrity. 


We periodically review our processes and systems to verify compliance with 
industry best practices and to ensure the highest level of security for our website. 


Please understand, however, that no security system is impenetrable. We cannot 
guarantee the security of our databases or the databases of the third parties with which 
we may share such Information, nor can we guarantee that the Information you supply 
will not be intercepted while being transmitted over the Internet. In particular, e-mail sent 
to us may not be secure, and you should therefore take special care in deciding what 
information you send to us via e-mail. 



The App is operated in the United States and its servers are operated in France. 
If you are located outside of the United States, please be aware that your Information, 
including your Personal Information, may be transferred to, processed, maintained, and 
used on computers, servers, and systems located outside of your state, province, country, 
or other governmental jurisdiction where the privacy laws may not be as protective as 
those in your jurisdiction. If you are located outside the United States and choose to use 
the App, you hereby irrevocably and unconditionally consent to such transfer, processing, 
and use in the United States and elsewhere. 



Your app store (e.g., iTunes or Google Play) may collect certain information in 
connection with your use of the App, such as Personal Information, Payment Information, 
Geolocational Information, and other usage-based data. We have no control over the 
collection of such information by a third-party app store, and any such collection or use 
will be subject to that third party's applicable privacy policies. 


The App may contain links to third-party websites. We have no control over the 
privacy practices or the content of these websites. As such, we are not responsible for 
the content or the privacy policies of those third-party websites. You should check the 
applicable third-party privacy policy and terms of use when visiting any other websites. 



The App is not directed to children under the age of 18. We adhere to the Children's 
Online Privacy Protection Act (COPPA) and will not knowingly collect Personal 
Information from any child under the age of 13. We ask that minors (under the age of 18) 
not use the App. If a child under the age of 18 has provided us with Personal Information, 
a parent or guardian of that child may contact us and request that such information be 
deleted from our records. 



Under California Civil Code Section 1798.83, California residents who have an 
established business relationship with us may choose to opt out of our sharing their 
contact information with third parties for direct marketing purposes. If you are a California 
resident and you wish to opt out, please send an e-mail to connect@collective615.com. 



 We do not monitor, recognize, or honor any opt-out or do not track mechanisms, 
including general web browser "Do Not Track" settings and/or signals. 



This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. 
We may change this Privacy Policy from time to time. Any such changes will be posted 
on the Site and the App. By accessing the Site and/or App after we make any such 
changes to this Privacy Policy, you are deemed to have accepted such changes. Please 
be aware that, to the extent permitted by applicable law, our use of the Information is 
governed by the Privacy Policy in effect at the time we collect the Information. Please 
refer back to this Privacy Policy on a regular basis. 



(a) Our company would like to make sure you are fully aware of all your data 
protection rights. Every user has, if applicable, the right to: 
(i) The right to access: you have the right to request our company for 
copies of your personal data. 


(ii) The right to rectification: you have the right to request that our 
company corrects any information you believe is inaccurate or 
mistaken. You also have the right to request our company to 
complete information you believe is incomplete. 


(iii) The right to erasure: you have the right to request that our company 
erase your personal data under certain conditions. 


(iv) The right to restrict processing: you have the right to request that 
our company restricts the processing of your personal data under 
certain conditions. 


(v) The right to object to processing: you have the right to object to our 
company’s processing of personal data under certain conditions. 


(vi) The right to data portability: you have the right to request that our 
company transfers the data we have collected to another 
organization or directly to you under certain conditions. 


(b) If you have questions about this Privacy Policy, please e-mail us at 
connect@collective615.com with "Privacy Policy" in the subject line.