Tackle.io Platform Privacy Notice
Last Updated Date: August 23, 2021
We deliver an exceptional value to our customers, in part, by gathering information about how they use our products so that we can better understand more about our customer’s needs. Tackle has adopted a global view on privacy with the intent of providing our customers with strong privacy rights regardless of where they are located. We have attempted to recognize and implement high standards for privacy rights compliance on a global scale and our use of terminology in this Privacy Notice should be interpreted to reflect that intent. You can find additional privacy terms that may be relevant to your specific location below.
We encourage you to contact us (see “How to Contact Us” below) if you have any questions or concerns.
SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice applies to the Tackle products and services (collectively, the “Services”) and sets out how we collect, use, and disclose information in relation to the users of our Services. These users include customers, partners, or other individuals who are purchasing from a Tackle customer on a Marketplace (collectively, “Users”). This Privacy Notice applies to these Users regardless of their geographic location during their interactions with the Services.
Table of Contents:
- INFORMATION WE COLLECT
- Information Collected Voluntarily
- Information Collected Automatically
- HOW WE USE THE INFORMATION WE COLLECT
- HOW WE SHARE THE INFORMATION WE COLLECT
- YOUR RIGHTS REGARDING INFORMATION
- Third Party Analytic Services
- SECURITY MEASURES
- EU/EEA SUPPLEMENT
- ADDITIONAL DISCLSOSURES FOR CALIFORNIA RESIDENTS
- HOW TO CONTACT US
A. INFORMATION WE COLLECT
Privacy is important to Tackle, and we attempt to not collect more information than is necessary for us to provide the Services. To enable us to provide our Services, Individuals need to provide certain information and some categories of data we collect may be classified as personal data under the applicable laws (“Personal Data”).
- Information Collected Voluntarily.
Tackle may collect directly from Users a first name, last name, business address, and other business contact details (phone, email, address). In addition, Tackle will have purchasing information related to the product or services a User is or has purchased from a Tackle customer through the Marketplace.
In other words, when a Marketplace purchaser procures software on the Marketplace from an ISV, this is done in the following 5 steps.
- Purchaser creates an account with the Marketplace
- Purchaser finds the software they want to buy (the “Listing”) from an independent software vendor selling on the marketplace (an “ISV”).
- If that ISV is a Tackle customer, then when the purchaser clicks to buy from the Listing, they will be presented with a Tackle webform to complete (along with this Privacy Notice). This is part of the Tackle Services and ‘sits’ between the Marketplace and the ISV
- The registration information is sent from Tackle’s platform to the ISV
- All payment information is processed through the Marketplace.
Keep in mind that the User may directly provide the same information to the respective Marketplace and to the Tackle customer prior to providing the information to Tackle. The terms and conditions and privacy obligations from such third-party will govern the respective information. Most ISVs list such terms and conditions on the Listing. Therefore, the same information may be subject to multiple privacy policies based on where and when the information was collected, and who collected the information.
- Information Collected Automatically.
When you use Tackle.io, our servers automatically record information (“log data”), including information that your browser sends whenever you visit our Website. This log data may include the web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.
- Other Website Analytics Services.
Subject to your opt-out preferences (see ‘Your Rights Regarding Information’ below), we use third-party Service Providers such as Google Analytics to provide certain analytics and Viewer interactions services to Tackle.io in connection with our operation of our Services, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors to Tackle.io. You may opt-out of relevant cookies using opt-out features on their respective websites.
B. HOW WE USE THE INFORMATION WE COLLECT
We collect and use your Personal Data for the following purposes:
- verifying your identity;
- verifying your eligibility as a user of the Services;
- processing your registration as a registered user of the Services, providing you with a log-in credentials for the Services; and maintaining and managing your account;
- providing you with customer service;
- providing the Services to our customers;
- performing research or statistical analysis to improve the content and layout of the Services, and to improve our product offerings and services;
- Cookies or other similar technologies may be used. Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes; and
- We may also use your Personal Data for other purposes such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, if and where this is permitted by applicable data protection laws.
C. DISCLOSURE OF INFORMATION
We may disclose and transfer your Personal Data to our customers or partners, as well as to service providers assisting us to provide the Services. Such service providers must abide by similar data privacy and security requirements and are only permitted to use your Personal Data in connection with the purposes specified above, and not for their own purposes. We may also disclose your Personal Data to any other person with your consent to the disclosure. For customers in the EEA/EU the list of organizations that may receive your data is listed here: https://info.tackle.io/tackle-subprocessors
If we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations, or as otherwise required or permitted by applicable laws. We may disclose your Personal Data to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, if we inform the buyer, it must use your Personal Data only for the purposes disclosed in this Privacy Notice. We retain your Personal Data if we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.
D. YOUR RIGHTS REGARDING INFORMATION
Under the applicable laws, you may have certain rights to Personal Data held by us, including the right to access the Personal Data as well as other rights. If you are from the European Union, please refer to section G. EU/EEA VISITORS below for more information. California residents should refer to section H regarding additional disclosures required for California residents. If you have any questions regarding this Privacy Notice or if you wish to access or correct your Personal Data, you may send your request to firstname.lastname@example.org or call 208.296.5765.
A “cookie” is a small amount of data that is sent to your browser and stored on the hard drive of your computer or mobile device if applicable. If you do not de-activate or erase the cookie, each time you use the same browser or mobile device to access the Services, our web servers will be notified of your visit and in turn we may have knowledge of your visit and the pattern of your usage.
You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our Services may be restricted. Keep in mind, certain features of the Services depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.
- Third Party Analytics Services
Tackle uses Google Analytics to provide it with information regarding the use of its Services.
- You may opt out of Google Analytics’ services using the Opt-Out feature on their website. The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/policies/privacy.
The Services are not targeted to minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact email@example.com in order have the information removed from our systems.
F. SECURITY MEASURES
We employ commercially reasonable security methods to prevent unauthorized access to the Services, to maintain data accuracy, and to ensure the correct use of the information we hold. For certain Users of the Services some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session. No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
G. EU/EEA SUPPLEMENT
This section of the Privacy Notice applies only if you use our Services from a country that is a Member State of the European Union or part of the EEA and supplements the information in this Privacy Notice on the data we collect (as identified above) and outlines your additional rights regarding this data.
- Processing Your Data
- Our legal basis to process Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect and process Personal Data about you only where it is: necessary for the performance of fulfilling our contractual requirements to our customers/subscribers; necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.
- If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Services, manage our relationship with you and communicate with you as necessary to provide our Services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Services, undertaking marketing, or for the purposes of ensuring the security of our Services, and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
- We retain your Personal Data if we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
- If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided under section J. HOW TO CONTACT US below.
- Your Rights
- The right to access, correct, update or request deletion of your Personal Data.
- The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
- The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
- The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section J. HOW TO CONTACT US below.
- If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
- We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
H. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (CCPA) requires businesses to disclose whether they sell Personal Data. As a business covered by the CCPA, we do not sell Personal Data.
- Information Tackle.io May Collect Regarding California Residents.
Tackle.io on behalf of its customers may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, the Services may have collected the following categories of Personal Information from California Residents within the last twelve months, for the purpose of establishing, maintaining, and supporting the Services that we provide to customers.
- Identifiers: Name; employer; email address; internet protocol address.
- Personal Information categories listed in Cal. Civ. Code Sec. 1798.80(e): Name.
- Commercial information: Purchase records regarding the Tackle customer products purchased through the Marketplace; Work email, business phone number.
- Internet or other similar network activity: Data related to the interaction with the Tackle.io Services.
Tackle.io Obtains the Categories of Personal Information Listed Above from the Following Categories of Sources
- Directly from our users
- Indirectly from our users
- Directly and indirectly from activity within the Services
- From third parties that interact with us in connection with the Services
- How California Resident Personal Information May Be Used.
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information or services that you request from us.
- To provide you with email alerts and other notices concerning our services, or news that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our Services.
- For testing, research, analysis and service development.
- As necessary or appropriate to protect Tackle.io and our users.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when your Personal Information was collected, or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Tackle.io is among the assets transferred.
- Tackle.io will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
- Sharing Personal Information.
We may disclose your Personal Information to a third-party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing your contract.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Service Providers.
- 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 have not sold any Personal Information.
- Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information that we have collected about you.
- Deletion Request Rights.
You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. All deletion requests will be managed in accordance with Tackle.io internal process and procedures. Deletion requests should be sent to firstname.lastname@example.org. Once we receive and confirm your verifiable request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug software to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Otherwise lawfully use that information in compatibility with the context in which you provided it.
- Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by reaching out to email@example.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable California Resident request for access or data portability twice within a 12-month period.
The request must:
- Provide sufficiently detailed information to allow Tackle.io to reasonably verify that you are the person to whom the requested Personal Information pertains or their authorized representative.
- Include sufficient detail to allow us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with Personal information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
- Making a verifiable consumer request does not require you to create an account with us.
- Tackle.io 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 California Resident requests in as timely a fashion as possible. In the event of delays over 60 days, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. Any disclosures we provide will only cover the 12-month period preceding the verifiable receipt of a California Resident’s 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.
In accordance with the CCPA’s requirements, we will not discriminate against you for exercising any of your CCPA rights.
- Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time and will notify you by email or through a notice on our website or through the Services.
- Contact Information
If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: firstname.lastname@example.org
I. 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.
J. HOW TO CONTACT US
104 S. Capitol Blvd. #201A
Boise ID 83702
Email Contact Information
General Privacy: Privacy@tackle.io
General Legal: Legal@tackle.io
Processing of personal data: Dataprocessing@tackle.io
Technical Support: email@example.com
Product Feedback: firstname.lastname@example.org