Privacy Policy

What’s a Rich Last Updated: June 20, 2022, effective date June 20, 2022.

We are Gear Seven Creative, LLC, d/b/a “Eleven Willow”, with registered address at 11 Willow St., Ste. 7, Nashville, TN 37210. We have produced this privacy policy and notice to keep you informed of how we handle your personal data. This notice contains important information on who we are and how and why we collect, store, use, and share your personal information. This notice also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.  

All handling of your personal data is done in compliance with applicable federal and state law and in the event you have any questions concerning your personal data you may contact our Data Privacy Lead at hey@11w.co.

1. Key Terms. For ease of reference and explanation, we use certain key terms throughout this privacy policy. Please see the following key terms contained in this privacy policy:

“We”, “Us”, “Our”, or “Company” refer to Eleven Willow as well as our subsidiaries and affiliates. 

“Personal Information” refers to any information relating to an identified or identifiable individual. 

2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, consumer, or household:

Categories of Personal Information and Types of Personal Information Collected: 

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—whether it be in-person, by telephone, text or email, and/or via our website. However, we may also collect information:

4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The following explains what we use (process) your personal information for and our reasons for doing so:

5. Promotional Communications. We may use your personal information to send you updates (by email, telephone, or mail) about our products/services, including offers, promotions or new products/services we have begun offering.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside Gear Seven Creative, LLC, and its subsidiaries and affiliates.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We routinely share personal information with:

Our affiliates, including companies within the Gear Seven Creative, LLC, group;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, person, consumer or household:

8. Where Your Personal Information is Held. Information may be held at our offices and those of our Gear Seven Creative, LLC, group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. 

When it is no longer necessary to retain your personal information, we will delete it.

10. What Are Your Rights Under the CCPA?

You have the right under the California Consumer Privacy Act of 2018 (“CCPA") and certain other privacy and data protection laws, as applicable, to exercise free of charge:

11. How to Exercise Your Rights Under the CCPA.

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email or in writing, you will need to provide us with:

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

12. What We Do With Cookies. Our website uses cookies. A cookie is a small file of letters and numbers that is stored on your device when you visit a website.

Cookies are useful as they help us to provide you with a good experience when you browse our site, for example by storing your preferences and maintaining your settings. They also help us to improve the site. By continuing to browse the site, you are agreeing to our use of cookies, and you accept that cookies (as listed below) may be used. Please note that information gathered by the cookies on our site is anonymous and cannot be used to identify you personally.

We use the following types of cookie:

  1. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  2. Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences.
  3. Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Some of these are third party cookies which analyze website usage.
  4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests. This information is anonymous and cannot identify you personally, but we may share it with third parties to help tailor advertising to your particular interests.

You can block cookies by activating settings on the website browser that you are using. However, if you use the settings to block all cookies (including essential cookies) you may not be able to fully access all areas of our website.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

13. Changes to This Privacy Notice. This privacy notice was published on June 20, 2022 and last updated on June 20, 2022.

We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email.

14. How to Contact Us. Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you. You may reach our Data Privacy Lead at hey@11w.co.

15. Do You Need Extra Help? If you would like this notice in another format (for example, audio, large print, braille) please contact us (See “How to Contact Us” above).

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