Privacy Policy (Tackle Platform)

1. The California Consumer Privacy Act (“CCPA”)

This California Consumer Privacy Act Notice (“CCPA Notice”) applies to California residents that are “Consumers” as defined by the CCPA and is a supplement to our other privacy policies or notices that apply to our Services, including, without limitation, the remainder of this Privacy Notice. In the event of a conflict between any other of our policies, statements or notices and this CCPA Notice, this CCPA Notice will prevail as to California Consumers and their rights under the CCPA. Capitalized terms not defined in this CCPA Notice shall have the meaning given to them in our Privacy Notice.  

The CCPA requires covered businesses to disclose whether they sell Personal Information (“PI”) for the twelve months preceding the date this CCPA Notice was last updated, except to the extent such PI is exempt from the notice obligations of the CCPA. 

Consistent with the CCPA, this CCPA Notice, including the Consumer Rights described herein, does not apply to PI collected about job applicants, current and former employees and independent contracts (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business (“B2B Contacts”).

• Collection, Use and Disclosure of PI.

Tackle may collect, retain, use, and share your PI for the purpose of establishing, maintaining, and supporting the Services that we provide to customers, including the following CCPA categories and non-exhaustive examples within such categories.

• Identifiers:  Name; employer; email address; internet protocol address.
• Customer Account Details / Commercial Information: Name.
• Commercial information: Purchase records regarding the Tackle customer products purchased through the Marketplace; work email, business phone number.
• Internet Usage Information: Data related to the interaction with the Tackle.io Services.
• Professional or Employment Information: Employer; title.
• Inferences from PI Collected: your preferences, or your likelihood of interest in certain of our services

We collect, use and share the PI we collect for the CCPA-defined business purposes in the bulleted list below and also for the purposes described in our Privacy Notice (our operational purposes) (collectively, our “Business Purposes”). 

CCPA-defined Business Purposes (CCPA Section 1798.140)

• Providing the Service, including maintaining and servicing your account on the Service, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services
• Detecting security incidents and protecting against malicious, deceptive, or illegal activity
• Debugging the Service to identify and repair errors
• Internal research and development
• Quality and safety assurance, and improving, upgrading, and enhancing the Service
• Processing and managing interactions and transactions on the Service

Tackle.io obtains the categories of Personal Information Listed Above from the Following Categories of Sources:

Users

• • Your device and browser
  • Our Service Providers, suppliers, and Marketplaces
  • Affiliates
    • Directly and indirectly from activity within the Services

• From third parties that interact with us in connection with the Services

Tackle.io will not collect additional categories of PI or use the PI we collect for materially different, unrelated, or incompatible purposes without providing you notice.

• Sharing Personal Information.

We may disclose your PI to a third party for our Business Purposes, as described above. For example, we disclose your PI for our Business Purposes to the following categories of third parties:

• Service Providers.
• Marketplaces.
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the services we provide to you.
• Government representatives as required by law.

In the preceding twelve (12) months, we do not believe we have Sold any Personal Information.

• CCPA Privacy Rights

The rights described in this section do not apply to Personnel or B2B Contacts. California Consumers have the right to exercise certain privacy rights under the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”).  

Unless you are able to provide us with certain information, we will be unable to verify your identity to fulfill a request to know or delete. We verify identity using your email address and name. We reserve the right to ask you to provide additional information in order to help us verify your identity. The request must:

• Be sent to dataprocessing@tackle.io.  
• Provide sufficiently detailed information to allow Tackle.io to reasonably verify that you are the person to whom the requested PI pertains or their authorized representative. At a minimum, you must provide the e-mail address you use to access the Services.
• Include sufficient detail to allow us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you.
• Making a Verifiable Consumer Request does not require you to create an account with us.
• Tackle will only use Personal Information provided in a Verifiable Consumer Request to verify the requestor’s identity or authority to make the request.

Response Timing and Format.

We will attempt to respond to Consumer requests in as timely a fashion as possible, and within 45 days of receipt of your request. In the event that we are unable to fulfill your request within 45 days, we will inform you of the reason and extension period in writing, but in no event greater than 90 days. Any disclosures we provide will only cover the 12-month period preceding the verifiable receipt of a Consumer request. The response we provide will explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before fulfilling your request.

Some personal information we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

• Right to Know
• Categories

You have the right to send us a request, no more than twice in a twelve-month period, regarding certain categories of PI collected, used, and sold.  

• Specific Pieces

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to your request.

• Right to Deletion

You have the right to request that we delete any of your PI that we have collected directly from you and are maintaining, except to the extent we have a basis for retention under CCPA, which we will explain in relation to any deletion request you make. 

You may alternatively exercise more limited control of your PI by by canceling or modifying your preferences for the email marketing communications you receive from us. You can do so by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

• Right to Opt Out of Sale of PI

We do not believe that we “Sell” your PI as such is defined under the CCPA. However, while there is not yet a consensus, and although we think otherwise, data practices of third-party cookies and tracking technologies associated with our Services may potentially be determined to constitute a “Sale” of your PI as defined by the CCPA. Because we do not think these third-party activities are a Sale by us, we do not offer an express “Do Not Sell” option. However, the rest of this section explains how you can exercise control over cookies, essentially opting out of their data collection, and in some cases provide certain opt-outs directly to cookie operators. Please also see Analytics and Advertising Tracking Technologies in our Privacy Notice for information on how to opt out of certain interest-based advertising. 

Some third parties that may collect PI in association with your use of our online services for advertising, analytics and other purposes, and may Sell that PI downstream, provide you the opportunity to opt-out of their Sales. Please visit https://www.privacyrights.info/ to opt-out of the Sale of PI by participating third parties.  You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. To learn more about interest-based advertising and additional opt-out choices related to it, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/?c=1.

Clearing Cookies or changing settings may affect your choices and you have to opt-out separately via each browser and other device you use. Cookie-enabled opt-out signals may no longer be effective if you delete, block or clear cookies. We are not responsible for the completeness, accuracy or effectiveness of any third-party notices, tools or choices.

We will not knowingly sell the PI of Consumers under 16.

We may disclose your PI for the following purposes, which are not a Sale:  (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst us and our Affiliates, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

Authorized Agents

You may use an authorized agent to submit a consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent. 

You or your authorized agent can make a request by emailing us at dataprocessing@tackle.io (Subject: Privacy). In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so.

Non-Discrimination 

In accordance with the CCPA’s requirements, we will not discriminate against you for exercising any of your CCPA rights.

• California Minors

While we do not permit anyone under the age of majority to use the Service, California law requires us to state in our Privacy Notice that any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting us, detailing where the content or information is posted and attesting that you posted it. 

J. NOTICE UPDATES/CHANGES

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. Any changes to this Privacy Notice will be communicated by us posting an amended Privacy Notice on the website. Once posted on the Sites, the new Privacy Notice will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice. Any use or access of the Services after such change has been made, will constitute acceptance to the modified policy.  

K. HOW TO CONTACT US

Tackle.io, Inc. 
104 S. Capitol Blvd. #201A
Boise ID 83702
208-296-5765

Email Contact Information

General Privacy: General Legal: 
Privacy@tackle.ioLegal@tackle.io

Processing of personal data:
Dataprocessing@tackle.io

Technical Support: Product Feedback: 
support@tackle.ioFeedback@tackle.io