Privacy Policy

Last Revised: June 26, 2019

Eturi Corp. (“Company”, “we”, or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy (“Policy”) to describe our practices regarding the personal data we collect from users of our electronic portfolio, comprising our website, located at (the “Site”) and, our mobile applications, including the applications entitled “OurPact” and “OurPact Jr.” (each, an “App”), and online services (collectively, the “Services”). This Policy generally applies to users of our Services who are of the age of digital majority or older. For users underage in their country, please refer to our Children’s Privacy Policy available at: This Policy does not apply to websites, applications or services that do not display or link to this statement or that display or link to different privacy statements.

1. Types Of Data We Collect

1.1 Information You Provide

We collect information about you in various ways when you use our Services. When you agree to our Privacy Policy, you consent to our collection of this information and permit us to use it for the purposes described in this Privacy Policy.

We collect personal data you provide to us. When you register for an account on our Services, we collect the name and email address you enter. We also collect information that you voluntarily submit to us, such as your child’s name, age, birthdate, gender, and profile photo.

In addition, if you contact us for customer support or provide us with feedback, we will collect the data included in the communication. Please contact us at if you have questions about the information we collect.

If you participate in a contest, sweepstakes or other promotion, we will collect any data you provide in connection with that promotion. We may also obtain information from other sources and combine that with information we collect on our Services.

If your child is identified as under the age digital majority in your jurisdiction, please see our Children’s Privacy Policy available at for a description of how we collect, use and share information we collect from children underage.

1.2 Information Automatically Collected Via Technology

When you use our Services, some information is automatically collected. For example, when you use our Services, we collect some specific device information, such as: device operating system, Internet Protocol (“IP”) address, access times, browser type and language, and device identifier numbers.

We also collect information about your usage and activity throughout our electronic portfolio. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

Cookies: We may automatically collect information using “cookies”. Cookies are small data files stored on your computer’s hard drive by a website. Among other things, cookies help us improve our Services and your experience. We use cookies to store user session data, remember your account settings and determine if your system is compatible with certain technologies, such as Flash and JavaScript.

2. Use Of Your Data

We use personal data collected through our Site, App, and Services for purposes described in this Policy or disclosed to you on our Site, or in connection with our Services. We do use your information to: (i) operate and improve our Services, App, and Sites; (ii) understand you and your preferences to enhance your experience and enjoyment using our Site, App, and Services; (iii) respond to your comments and questions and provide customer support; (iv) to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; (v) communicate with you about new contests, promotions, rewards, upcoming events, and other news about Services offered by Company and our selected partners; and (vi) link or combine it with other personal data we get from third parties, to help understand your needs and provide you with better service.

From your personal data, we may also create anonymous and de-identified data records so that we may better understand usage of our Services and improve our offering. Company reserves the right to use and disclose anonymous and de- identified data records to third parties at its discretion.

To reiterate, we do not sell your personally identifiable data.

3. Payment Data

If you sign up for our Paid Services, or make other purchases through the Service, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work.

We also collect certain details of your transaction history which are necessary to provide the Paid Services. In addition, the payment processors generally provide us with information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments if you authorize automatic renewals, and your card’s type, expiration date, and certain digits of your card number.

4. Sharing Of Personal Data

We do not share your personal data with third parties other than as follows: (1) with your consent; (2) with third party vendors, consultants and other service providers who work for us and need access to your information to do that work, and are required by contract not to use your personal data other than to provide the services requested by the Company; (3) to (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of the Company, our agents, customers, members, and others including to enforce our agreements, policies and terms of use or (iii) in an emergency to protect the personal safety of the Company, its customers, or any person; (4) in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company; or (5) in the event of insolvency, bankruptcy, or receivership, your information may also be transferred as a business asset.

You understand and agree that a Third Party Application’s use of information collected from you (or as authorized by you) is governed by the Third Party Application’s privacy policies and your settings on the relevant service, and the Company’s use of such information is governed by this Privacy Policy and your account settings.

We may also share aggregated or de-identified information in our sole discretion.

If you are a California resident, California law permits such users 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 data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those third parties. See the “Contact Information” section for where to send such requests. We do not share personal data with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal data to third parties for their direct marketing purposes by withholding consent.

5. Your Right To Withdraw Consent To Processing

Where you have provided your consent to the processing of your personal data by the Company you may withdraw your consent at any time by sending a communication to the Company specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal data, in particular where (i) you contest the accuracy of your personal data; (ii) the processing is unlawful and you oppose the erasure of your personal data; (iii) we no longer need your personal data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of the Company override your own.

6. Your Choices Regarding Your Personal Data

We allow you to choose which forms of communication you receive from us, how you manage your public information, and how you set your sharing preferences. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out of receiving promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

We also provide European Union data rights as outlined in Sections 7. And 8. Right below:

7. Your Personal Data Rights

You have the following rights with respect to your personal data where and to the extent they apply to your particular processing:

  • The right to request a copy of your personal data which the Company holds about you;
  • The right to request that the Company corrects any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary for the Company to retain such data;
  • The right to withdraw your consent to the processing of your personal data at any time;
  • The right to request that the Company provide you with your personal data and where possible, to transmit that data directly to another data controller (where applicable);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing; and
  • The right to lodge a complaint with a European Union Data Protection or Supervisory Authority.

8. Exercise Of Your Rights With Regard To Eturi

You may let us know of your desire to enforce any of the rights described in this Privacy Policy by sending an email to, and we will respond within 30 days. Please note that we may ask you to verify your identity before taking further action on your request. Please also note that laws and contractual frameworks limit your exercise of these data rights; we welcome you to ask us questions any time, and will answer them as described above.

9. Storage and Transfer of Your Personal Data

The data that we collect from you will be processed and stored at a destination located in the United States.

We transfer data to destinations outside the European Union as a necessary part of the performance of the Services, or with your consent, as applicable.

As described in Sections 2, 4, 5 and throughout this Privacy Policy, we do not sell, otherwise allow use by or disclose to third parties, your personal data.

10. Notice To Previous Child Users Of OurPact Services Who Have Reached The Age Of Digital Majority in Your Jurisdiction

If you are a previous user of OurPact Services that has now reached the age digital majority, the primary account holder may contact us via to have personal data that could be used to personally identify you, such as your name, age, birthdate, and profile photo removed from OurPact’s system. Descriptions of such personal data is provided in the “Information You Provide” section.

11. Security Of Your Personal data

The Company is committed to protecting the security of your personal data. We use a variety of industry-standard security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. While Company uses reasonable efforts to protect your personal data, no security measure is completely secure, and we cannot guarantee the security of your information.

12. Retention of your Personal Data

We keep your personal data to enable your continued use of the Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you.

13. Contact Information

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at or, by mail, to: Eturi Corp., Attn: Data Protection Officer - Legal, 12255 El Camino Real STE 125, San Diego CA 92130.

14. Changes To This Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your personal data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site, as required by law. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Services. Please note that at all times you are responsible for updating your personal data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of personal data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your personal data, you must notify us prior to the effective date of the changes. Continued use of our Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

15. Complaints To Supervisory Authorities

We invite you to let us know about any and all issues regarding our data processing activities or this Privacy Policy, and we will respond to you within 30 days of receipt of such notification.

If you consider that our processing of your personal data infringes European Union data protection laws, in particular if you are an EU resident, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Ireland this is the Data Protection Commissioner.