Privacy Policy (Tackle Platform)

Tackle.io Platform Privacy Notice

Last Updated Date: August 29, 2022

Tackle.io, Inc. (“Tackle”) is transforming the way independent software vendors (“ISVs”) buy and sell software. Tackle’s customers (also referred to herein as “sellers”) use the Tackle products and services (“Services”) to sell their products on various business to business cloud marketplaces (each, a “Marketplace”). When a Marketplace purchaser transacts with a seller, the purchaser will need to provide certain details to Tackle, as described in further detail below. The purchaser reviews and accepts the seller’s privacy policy and terms before they navigate to the Tackle platform and interact with the Services.         

SCOPE OF THIS PRIVACY NOTICE

This Privacy Notice applies to the Tackle products and services (collectively, the “Services”), regardless of how the User accesses or uses it, and sets out how we collect, use, and disclose information in relation to the Users of our Services, including the choices we offer with respect to that information. 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.  

By using the Services, you agree to the Services’ Terms of Use [Link to Platform Terms of Use] and consent to our data collection, use, and disclosure practices, and other activities as described in this Privacy Notice, and any additional privacy statements that may be posted on an applicable part of the Services. If you do not agree or consent, please discontinue use of the Services.

You can find additional privacy terms that may be relevant to your specific location below. California residents have certain privacy rights detailed in our Additional Disclosures for California Residents [Link] section below.

We encourage you to contact us (see How to Contact Us [Link] section below) if you have any questions or concerns.

 

Table of Contents:

A. INFORMATION WE COLLECT

B. HOW WE USE THE INFORMATION WE COLLECT

C. DISCLOSURE OF INFORMATION

D. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, ADVERTISING AND ANALYTICS

E. YOUR RIGHTS AND CHOICES

F. MINORS

G. SECURITY MEASURES

H. UK/EU/EEA SUPPLEMENT

I. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

J. NOTICE UPDATES/CHANGES

K. HOW TO CONTACT US

 

A. INFORMATION WE COLLECT

Privacy is important to Tackle, and as part of this commitment we attempt to limit our collection of information to what is necessary for us to provide the Services. To enable us to provide our Services and for the other purposes described herein or at the time of collection, we, our Service Providers, and Third-Party Services collect certain information from or about Users that personally identifies such Users (“Personal Data”) when they access or use the Services. We will collect, use, and share User Personal Data for purposes that are not inconsistent with this Privacy Policy or our other privacy disclosures, or for other purposes that are permitted or required under applicable laws. Notably, the definition of “personal data,” “personal information” or “personally identifiable information” under certain laws, such as state privacy laws, may be different than Personal Data as defined in this Privacy Policy. California residents can learn more about their privacy rights here [Link to Additional Disclosures for California Residents section].

1. Information Provided by Users

We and/or our Service Providers (defined below) may collect information that Users provide directly to us and/or our Service Providers via the Services. For example, we collect information when Users use or register for the Services, or communicate or transact through the Service. In addition, when Users interact with Third-Party Services (defined below), Users may be able to provide information to those third parties.

For example, when a purchaser-User registers or makes a purchase from a Tackle customer, Tackle may collect directly from Users a first name, last name, business address, and other business contact details (phone, email, address) that personally identifies the User. In addition, Tackle will have information related to the product or services a User is purchasing 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.  

  1. Purchaser creates an account with the Marketplace.
  2. Purchaser finds the software they want to buy (the “Listing”) from an independent software vendor selling on the Marketplace (an “ISV”).  
  3. 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). The webform is a registration page that is part of the Services and ‘sits’ between the Marketplace and the ISV. 
  4. The registration information is sent from Tackle’s platform to the ISV. 
  5. 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. 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. The terms and conditions and privacy notices and policies of such Marketplaces, Tackle customers, and other Third-Party Services will govern the information collected by such parties, respectively. Most ISVs list such terms and conditions on the Listing. Tackle is not responsible or liable for the accuracy of the information provided by such third party or for third-party policies and practices.

2. Information Collected Automatically

Like many software applications, we, our Service Providers, and/or Third-Party Services may automatically collect certain information about you when you access or use the Services (“Usage Information”). For example, the Services use Cookies, web beacons, and other technologies (“Tracking Technologies”) to receive and store certain types of information when you interact with us through your computer or mobile device subject to your opt-out preferences (see Your Rights and Choices [Link] section). For example, using these technologies helps us customize your experience with our Services, improve your experience, and tailor marketing messages. In addition, a Tackle customer may choose to collect metadata from buyers for tracking transactions such as quote numbers. Here are some of the types of information we, our Service Providers, and Third-Party Services collect through the Services:

  • Log & Device Data

“Log data” includes information that your browser sends whenever you visit our website, such as 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 approximate geographic location. Using some of this information we collect, we may also infer your location, subject to your preferences within the Services or on your browser or device. 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.

  • Cookie Data

Depending on how you’re accessing our Services and subject to your preferences, we may use cookies (a small text file sent by your computer each time you visit our Website, unique to your Tackle.io account or your browser) or similar tracking technologies to record log data (“Cookies”). When we use Tracking Technologies, we may use ‘session’ Cookies (that last until you close your browser) or ‘persistent’ Cookies (that last until you or your browser deletes them). For example, we may use Cookies to keep you logged into Tackle.io. Some of the Cookies we use may be associated with your Tackle.io account (including personal information about you, such as the email address you gave us), and other Cookies are not. More detailed information regarding the types of Tracking Technologies we use has been included in the table below:

Tracking Technology Purpose Duration
Google Analytics Analytics
FullStory
Pendo

 

  • Other Website Analytics Services.

Subject to your opt-out preferences (see ‘Your Rights and Choices’ below), we use Third-Party Services such as Google Analytics to provide certain analytics 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 Google Analytics’ here [Link to https://tools.google.com/dlpage/gaoptout] and of FullStory here [link to https://www.fullstory.com/optout]. You may opt-out of relevant Cookies using opt-out features on their respective websites. Please visit the “Your Rights and Choices” section below for more information on how to opt-out of collection and/or other activities by certain Third-Party Services.

3. Information We Collect from Other Sources.

We may also obtain information about you from other sources, including Service Providers and Third-Party Services. We are not responsible nor liable for the accuracy of the information provided by third parties or for third-party policies or practices.

 

B. HOW WE USE THE INFORMATION WE COLLECT

We collect and use your Personal Data for purposes not inconsistent with the statements in this Privacy Notice or disclosed in writing at the time of collection, and not prohibited by law, including, without limitation, the following purposes:

  • To process 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.
  • 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 or offers 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 develop and improve our Services and future generations of Tackle products and services.
  • For testing, research, analysis and service development.
  • As necessary or appropriate to protect Tackle.io and our Users or any third parties.
  • To verify your identity, preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • To verify your eligibility as a User of the Services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • 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.
  • 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

Generally, we may share information about you for any purposes not inconsistent with our statements under this Privacy Notice, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

  • 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 (collectively, “Service Providers”). 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 your actions are inconsistent with our Platform Terms of Use or other applicable terms or policies, or to protect the rights, property, life, health, security, and safety of Tackle, the Services, its Users, or any third party.
  • To comply with law, law enforcement or other legal process, and, where permitted, in response to governmental requests or legal process (for example, a court order, search warrant or subpoena.

In addition, we may share information about you as follows:

  • Marketing:  Subject to your communications choices (explained more below) and the rights of California residents (also explained more below), we may use or share your information to send you marketing communications or in order for another party to send you marketing communications.
  • With Your Disclosure or Consent:  As more fully described in the Information Provided by Users [Link] section and Third-Party Content, Third-Party Services, Advertising and Analytics [Link] section, your activities on the Services may, by their nature, result in the sharing of your information with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties.  Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not us.
  • Corporate Transactions:  We may disclose your Personal Data in connection with or during negotiations of any proposed or actual financing of our business or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all, or a portion of, our business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
  • Data Retention:  As described more below, we retain your PII pursuant to an ongoing legitimate business need, as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.

 

D. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, ADVERTISING, AND ANALYTICS

The Services may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other services (“Third-Party Service(s)”).  These Third-Party Services may use their own Cookies, web beacons, and other Tracking Technologies to independently collect information about you and may solicit Personal Data from you.  

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as Marketplaces and Tackle customer products.  

Tackle may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use Cookies and other Tracking Technologies to help Tackle analyze Services Users and how they use the Service. Information generated by these analytics services (e.g., your IP address and other log data) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Service’s activity, and providing other services relating to Services activity and other Internet usage.  

Tackle is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Services, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.  

 

E. YOUR RIGHTS AND CHOICES

1. Your Rights

Under 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 located in the UK or European Union, please refer to UK/EU/EEA VISITORS [Link] section below for more information. California residents should refer to the Additional Disclosures for California Residents [Link] section. 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 dataprocessing@tackle.io or call 208.296.5765.

2. Your Choices
  • Tracking Technologies Generally. 

Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to certain Tracking Technologies. Please be aware that if you disable or remove certain Cookies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.  

If we ever offer mobile applications, you can make choices on your device as to App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app). However, please note that such choices do not alter Tackle’s practices in this regard and Tracking Technologies used will only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or device manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Tackle currently does not alter Tackle’s practices when Tackle receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Tackle is not responsible for the completeness or accuracy of this third-party information.  Some third parties, however, may offer you choices regarding their Tracking Technologies.  One way to potentially identify Cookies on our website is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based Cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those Cookies. Tackle is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms.  For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section.  We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding Cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third-party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:

We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services, and clearing Cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain Cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

  • Analytics and Advertising Tracking Technologies. 

Tackle uses Google Analytics to provide it with information regarding the use of its Services. You may exercise choices regarding the use of Cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of Cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”

 

F. MINORS

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 legal@tackle.io in order have the information removed from our systems.  

 

G. 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. 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.

 

H. UK/EU/EEA SUPPLEMENT

This section of the Privacy Notice applies only if you are an individual using our Services when located in the UK or a Member State of the European Union and where the UK GDPR/EU GDPR applies to Tackle’s processing of your Personal Data in connection with the Services. This section of the Privacy Notice supplements the information in this Privacy Notice only where applicable and is not intended to create any additional rights regarding this data or obligations that are not provided under applicable law.   

1. Lawful Basis of Processing
  • 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 a contract with you or to take steps to enter into a contract on your behalf; 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 those of third parties in circumstances where the interest pursued is not outweighed by the related risk to your rights; or in rare cases, based on your consent.  Where we need to process your Personal Data based on contractual necessity then your failure to provide the information when requested may mean that we are unable to enter into or perform contractual obligations which may prevent us from being able to provide Services to you.
  • Where we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), such interests 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 purposes, such as responding to your queries, improving our Services, undertaking marketing or otherwise promotion our brand or Service, or for the purposes of ensuring the security of our Services, complying with our legal obligations, including cooperating with investigations conducted by supervisory authorities or law enforcement agencies, establishing, exercising or defending legal claims, and detecting or preventing illegal activities such as fraud. Such other legitimate interests may arise and be notified to you, from time to time. Where we process your Personal Data based on consent then you can withdraw your consent at any time by contacting us using the contact details provided below.
  • 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 the How To Contact Us [Link] below.
2. Retention

We will only keep your Personal Data for as long as necessary to achieve the purposes for which it was initially collected, taking into account any applicable legal requirements and associated retention periods. We may also anonymize data for statistical purposes and in such cases will ensure that you can no longer be identified by those data, meaning that it no longer constitutes Personal Data.

3. International Transfers

We may transfer your Personal Data to jurisdictions with differing standards for the legal protection of personal data and privacy. However, we will only transfer your data to such jurisdictions where we are confident that there are appropriate measures in place.

In particular, we will only transfer your data to jurisdictions that have been deemed to offer an adequate level of protection, or where there are specific contractual protections in place with the recipient. Where do rely on contractual safeguards, then we will only use model clause approved for use by the relevant supervisory authorities. To know more about how we use model transfer clauses and instruments then please contact us using the contact details below.

4. Your Rights

In certain cases you may have rights in connection with your Personal Data, as further outlined below:

  • Right of access: subject to certain exceptions, you have the right of access to your personal data that we hold.
  • Right to rectify your personal data: if you discover that the information we hold about you is inaccurate or incomplete, you can get in touch to have this information corrected.
  • Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. 
  • Right to restriction of processing: in some cases you may have the right to have the processing of your personal data restricted. 
  • Right to object to processing: you can object to processing of your data when it’s based on our legitimate interests, for the purposes of direct marketing or statistical analysis.
  • Right to data portability: you have the right to receive or transfer your personal data to another controller if we are processing your data based on consent or on a contract and the processing is carried out by automated means.

We would always welcome the chance to deal with your concerns in the first instance, but you also have the right to make a complaint to the relevant supervisory authority in your jurisdiction if you feel that we have handled your Personal Data improperly.

 

I. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

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 [Link] 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.io Legal@tackle.io

Processing of personal data:

Dataprocessing@tackle.io

Technical Support: Product Feedback: 

support@tackle.io Feedback@tackle.io