LAST UPDATED: December 06, 2025
Data Privacy Framework Program (DPF) Privacy Policy
This DPF Policy (“DPF Policy“) is in accordance with Tori Avey, LLC’s (the “Company,” “we,” or “us“) compliance with the EU-US Data Privacy Framework (“EU-US DPF“), the UK Extension to the EU-US DPF and the Swiss-US Data Privacy Framework (“Swiss-US DPF“) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information (“Personal Data“) transferred from the European Union (“EU”), as well as Norway, Liechtenstein and Iceland (collectively the “EEA”), the United Kingdom (and Gibraltar) (collectively, the “UK”), or Switzerland (together with the EEA and the UK, the “EEA, UK and Switzerland”) to the United States (“US”). The Company has self-certified to the US Department of Commerce that it adheres to the EU-US DPF Principles (EU-US DPF Principles) with regard to the processing of personal data received from the EEA in reliance on the EU-US DPF and from the UK in reliance on the UK Extension to the EU-US DPF. The Company has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this DPF Policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles (collectively, the “Principles”), the Principles shall govern. To learn more about the Data Privacy Framework program (“DPF Program“) and to view our certification, please visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission has jurisdiction over the Company’s compliance with the EU-US DPF and the UK Extension to the EU-US DPF, and the Swiss-US DPF.
The Swiss-US DPF will only be relied upon for transferred data from the US to Switzerland from the 15 September 2024. This is the date of entry into force of Switzerland’s adequacy decision by the Swiss Federal Administration. This DPF Policy supplements our Website Privacy Policy located at https://toriavey.com/privacy-policy/ and unless specifically defined in this DPF Policy, the terms in this DPF Policy have the same meaning as the Website Privacy Policy.
Definitions
“Data Subject” means the individual to whom any given Personal Data covered by this DPF Policy refers.
“Personal Data” means any information relating to an individual residing in the EEA, UK, and Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.
“Sensitive Personal Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or information specifying the sex life or sexual orientation of an individual.
Your Rights
Under the DPF Program, you have rights in relation to your Personal Data. These include:
- Information on the types of Personal Data collected.
- Information on the purposes of collection and use.
- Information on the type or identity of third parties to which your Personal Data is disclosed.
- Choices for limiting use and disclosure of your Personal Data.
- Access to your Personal Data.
- Notification of the organization’s liability if it transfers your Personal Data.
- Notification of the requirement to disclose your Personal Data in response to lawful requests by public authorities.
- Reasonable and appropriate security for your Personal Data.
- A response to your complaint within 45 days.
- Cost-free independent dispute resolution to address your data protection concerns.
- The ability to invoke binding arbitration to address any complaint that the Company has violated its obligations under the Principles to you and that has not been resolved by other means.
You can also verify our self-certification to the DPF Program and check the information we have provided by viewing our details on the DPF Program list.
Personal Data Collection and Use
Our Website Privacy Policy located at https://toriavey.com/privacy-policy/ describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. We may receive the following categories of Personal Data in the US: https://toriavey.com/privacy-policy/. We process Personal Data for the following purposes: https://toriavey.com/privacy-policy/. The Company will only process Personal Data in ways that are compatible with the purpose that the Company collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. The Company maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
Choice
In accordance with the DPF Program, the Company limits the use and disclosure of Personal Data of Data Subjects. If Personal Data covered by this DPF Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized or is to be disclosed to a non-agent third party, the Company will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy. Where required by the DPF Program, we enter into written agreements with those third- party agents and service providers requiring them to provide the same level of protection the DPF Program requires and limiting their use of the Personal Data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our DPF Program obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.
Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third- party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the purposes described in our Website Privacy Policy. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of Sensitive Personal Data, if applicable, where you have opted-in if the DPF Program requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the DPF Program requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements. We will only do so in accordance with the Principles.
Security
The Company maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the DPF Program.
Access Rights
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF Program. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances, we may charge a reasonable fee for access to your information.
Questions or Complaints
In compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, the Company commits to resolve Principles-related complaints about our collection and use of your Personal Data. EEA, UK, and Switzerland individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF should first contact the Company at info@toriavey.com. In addition, in compliance with the EU-US DPF, the UK Extension to the EU- US DPF, and the Swiss-US DPF, the Company commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF to JAMS, an alternative dispute resolution provider based in
the United States. If you do not receive timely acknowledgment of your Principles-related complaint from us, or if we have not addressed your Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. Both parties will bear equally the cost of arbitration (exclusive of legal fees and expenses). In certain circumstances, the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF provide the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Data Privacy Framework.
Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with the Company and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see https://www.dataprivacyframework.gov/framework-article/D–Binding- Nature-of-Decisions .
Contact Us
If you have any questions about this DPF Policy or would like to request access to your Personal Data, please contact us as follows: info@toriavey.com.
Changes to This Policy
We reserve the right to amend this DPF Policy from time to time consistent with the DPF Program’s requirements.
Effective Date: December 05 , 2025