Privacy Policy (Tackle Website)

Effective Date: December 14, 2022

Thank you for visiting our website or other online service or application (“Website”) owned or operated by Tackle.io, Inc. (“Tackle”, “we”, “us”, “our”).   This Privacy Policy applies only to Websites that post a link to this Privacy Policy. It will provide you with information as to how we collect, use, and share information about you, including the choices We offer with respect to that information, and applies to your use of any Website, regardless of how you access or use it.  It does not apply to our data collection activities outside of the Website (unless otherwise stated below or at the time of collection), such as the Tackle.io Platform, which has a separate privacy policy and terms of use. For certain Websites, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.

By visiting or otherwise using the Website, you agree to the Website’s Terms of Use and acknowledge that you have read and understood our data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Website.  If you do not agree and consent, please discontinue use of the Website.

Your State Privacy Rights

Residents of California have certain privacy rights detailed in the State Privacy Notice [Link] section. To the extent that there is a conflict between this Privacy Policy and the State Privacy Notice section, the State Privacy Notice section will control.

GDPR Rights

If you are located in the UK or from a country within the EU/EEA, then you have additional privacy rights under the General Data Protection Regulation (EU 2016/679) (“GDPR”) which may apply in conjunction with local laws. Details of this can be found in the UK/EU/EEA Visitors section. To the extent that there is a conflict between this Privacy Policy and the UK/EU/EEA Visitors section, the UK/EU/EEA Visitors section will control.

1. Information We Collect.

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

Information that We, our Service Providers and/or Third-Party Services may collect from you includes: your first and last name, institution/company, e-mail address, user name, Third-Party Services logins and other credentials, phone number, address, payment information and other information that personally identifies you (“Personal Data”).

B. Information Collected Automatically. We, our Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Website (“Usage Information”).  Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Website, device you use, the web page you visited before coming to our sites, and identifiers associated with your devices and your devices (depending on their settings) may also transmit location information to the Website.  You can manage these technologies easily on our websites.

The methods that may be used on the Website to collect Usage Information include cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”). These may be used to collect information about interactions with the Website or e-mails, including information about your browsing and purchasing behavior. To learn more about each category of cookie, you can visit our cookie consent tool by clicking on the “Cookie Preferences” link on the bottom of the Tackle website you are visiting. Such Tracking Technologies may include:

  • Cookies: We use “cookies” to store specific information about you. A “cookie” is a small text file that is sent to your browser and stored on your device, such as session ID cookies or tracking cookies. Tracking cookies remain longer and help in understanding how you use the Services and enhance your user experience.  Cookies may remain on your hard drive for an extended period of time.  If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result, some features, and functionalities of the Services may not work. See Section 11 below on how to control and delete cookies.
  • Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
  • Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Tackle’s web server, or from a third party with which Tackle works and is active only while you are connected to the Service and deleted or deactivated thereafter.
  • Device Recognition Technologies: Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
  • Device and Activity Monitoring: Technologies that monitor, and may record, certain of your interactions with the Service, including without limitation, keystrokes, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.
  • Content Personalization: Tackle uses Mutiny Personalization Software to enhance user experiences and deliver tailored content. Cookies are used to store and retrieve user preferences, historical interactions, and other data points. You can manage your preferences by clicking here to enable or disable personalized content.

Some information about your use of the Website and certain other online Websites may be collected using Tracking Technologies across time and Websites and used by us and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Website and certain other online Websites.  See Section 11 regarding certain choices regarding these activities.

C.  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.

D.  Limitations. To the extent any non-Personal Data, or Personal Data collected outside of the Website or by Third-Party Services, is combined by or on behalf of us with Personal Data we collect directly from you on the Website (“Company-Collected Personal Data”), we will treat it in accordance with this Privacy Policy.  Notwithstanding the foregoing or anything to the contrary, unless required by applicable law, this Privacy Policy is not intended to limit our activities regarding information that does not personally identify you such that it does not constitute Personal Data, including Personal Data that has been “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements), and non-Company-Collected Personal Data (including third-party-sourced, or non-Website-sourced, information) that is not combined with Company-Collected Personal Data.

The definition of Personal Data and personal data under certain state laws differs from the definition of Personal Data used in this Privacy Policy.

2. How We Use the Information We Obtain.

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

  • To fulfill or meet the reason for which the information is provided.
  • To provide you with information or products or services that you request from us.
  • To provide you with email alerts and other notices concerning our Website or products or 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 Website 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 Website or our products or 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 Data 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

We may contact you for marketing purposes. Please visit Section 11.C for information regarding your choices as to promotional communications.

3. Information We Share with Third Parties.

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

  • With our agents, vendors, consultants, and other service providers (collectively “Service Providers”) in connection with their work on our behalf, including assisting in the provision of the Website. These parties provide Websites such as authentication, billing and collections, payment processing, customer support, or data storage. We contractually require these Service Providers to protect your Personal Data and use it in a manner that is consistent with this Privacy Policy;
  • If we believe your actions are inconsistent with our terms of use or other applicable terms or policies, or to protect the rights, property, life, health, security and safety of us, the Website, or 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); and
  • In other circumstances in which we have a good faith belief that a crime has been or is being committed by a user.

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

Marketing: Subject to your communications choices explained in Section 11.C, and the rights of data subjects or consumers in certain jurisdictions explained in Sections 12 and 13, we may use or share your information to send you marketing communications[ or in order for another party to send you marketing communications on our behalf.

With Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Advertising and Analytics), your activities on the Website 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: In addition, we may share information about you 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”).

4. Sweepstakes, Contests, and Promotions.

We may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Data and other information.  If you voluntarily choose to enter a Promotion, your information, including Personal Data, may be disclosed to us, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy.  Please review those rules carefully.

5. Information You Disclose Publicly or to Others.

The Website may permit you to post or submit User-Generated Content (“UGC”) including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Data.  If you choose to submit UGC to any public area of the Website, to the extent public areas are made available to you, your UGC will be considered “public” and will be accessible by anyone, including us.  Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Data included in UGC is not subject to our usage or sharing limitations, or other obligations, regarding Company-Collected Personal Data or other Personal Data under this Privacy Policy or otherwise, and may be used and shared by us and third parties to the fullest extent not prohibited by applicable law.  We encourage you to exercise caution when making decisions about what you disclose in such public areas.

Additionally, the Website may offer you the option to send a communication to a friend or other contact. If so, we rely on you to only send to people that have given you permission to do so.  The recipient’s Personal Data you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by us for any other marketing purpose unless we obtain consent from that person.  Your contact information and message may be included in the communication.

6. Third-Party Content, Third-Party Services, Advertising and Analytics.

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

Certain functionalities on the Website permit interactions that you initiate between the Website and certain Third-Party Services.  Examples of such interactions include connecting the Website to a Third-Party Service (e.g., to pull or push information to or from the Website).  If you enable such interactions, both we and the third party may have access to certain information about you and your use of the Website and any Third-Party Service.

We may engage and work with Service Providers, Third-Party Services, and other third parties to serve advertisements on the Website and/or on other online Websites. Some of these ads may be tailored to your interest based on your browsing of the Website and elsewhere on the Internet, which may include use of precise location and/or cross-device data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interestbased Advertising”), which may include sending you an ad on another online Website after you have left the Website (i.e., “retargeting”).

We are not responsible for, and make 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 Website, and encourage you to familiarize yourself with and consult their privacy policies and terms of use.  See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

7. Data Security and Monitoring, Retention.

The security of your Personal Data is important to us. We follow generally accepted standards to protect the Personal Data submitted to us (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction, both during transmission and once it is received. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we do not guarantee the security of your information collected through the Website. If you have any questions about the security of your Personal Data, you can contact us as set forth in Section 14 (Contact Us) below.

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.

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.

8. International Transfer.

We are based in the U.S. and the information we and our Service Providers collect is governed by U.S. law. If you are accessing the Website from outside of the U.S., please be aware that information collected through the Website may be transferred to, processed, stored, and used in the U.S.  Data protection laws in the U.S. may be different from those of your country of residence. By using  the Website, you agree to the terms of this Privacy Policy including in relation to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Data, in the U.S. as set forth in this Privacy Policy.

9. Children’s Privacy.

The Website is intended for a general audience and not directed to children less than 13 years of age. We do not intend to collect Personal Data as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA.  If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.

10. Accessing and Changing Information.

To the extent required by applicable law, we may provide web pages or other mechanisms allowing you to delete, correct, or update some of your information that we have collected and retained, and potentially certain other information about you (e.g., profile and account information).  Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

11. Choices: Tracking and Communications Options.

A. How to Control & Delete Cookies

Tackle uses UserCentrics as our cookie consent tool, which you can utilize to customize your cookie preferences. When you visit our website for the first time, a cookie consent banner will pop up and ask you to customize your cookie preferences. If you decide to change your preferences at a later date, you can easily do so by clicking on the “Cookie Preferences” link on the bottom right of the Tackle website you are visiting. Please note that Required Cookies cannot be disabled and if you decide to opt-out of Functional Cookies, certain functionality of our websites or your account may be impacted. In addition to using our Cookie Consent tool, you can use your browser settings to opt out of Functional Cookies and Advertising Cookies.

B. 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 browsers may not be effective with regard to certain Tracking Technologies.  Please be aware that if you disable or remove these technologies, some parts of the Website may not work and when you revisit the Website your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app.  To uninstall an app, follow the instructions from your operating system or handset 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 Websites you visit.  Like many online Websites, we currently do not alter our practices when we receive 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 we are not responsible for the completeness or accuracy of this third party information.  For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.

C. Analytics and Advertising Tracking Technologies. 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 websites or tailor their online ads for you.”

You may choose whether to receive some Interest-based Advertising by submitting opt-outs.  Some of the advertisers and Service Providers that perform advertising-related Websites for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.  To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads).  Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.  Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads.  Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).  Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.  We support the ad industry’s Self-regulatory Principles for Online Behavioral Advertising [Link to https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf] and expects that ad networks we directly engage to serve you Interest-based Advertising will do so as well, though we cannot guaranty their compliance.

We may also use Microsoft Advertising Websites. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here.

We may also use Google Ad Websites. To learn more about the data Google collects and how your data is used by it and to opt out of certain Google browser Interest-Based Advertising, please visit here.

We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

D. Communications. You can opt out of receiving certain promotional communications from us at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from us to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable.  Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.  If you opt-out of only certain communications, other subscription communications may continue.  Even if you opt out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations

12. UK/EU/EEA Visitors

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

  • Legal Basis of Processing Personal 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 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, where it is 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 the Website or Our 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, administer and enable access to the Website, 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 queries submitted through the Website, improving the Website and the way we provide our Services, undertaking marketing, or for the purposes of ensuring the security of the Website and 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 Section 14 (Contact Us).

  • 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.

  • International Transfers

As described in this Privacy Policy, your Personal Data will be collected, transferred to, and otherwise processed in jurisdictions with differing standards for the legal protection of personal data and privacy, including the US. However, we will only allow your data to be processed in 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 we do rely on contractual safeguards, then we will only use model clauses 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 link provided below.

  • 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

To exercise your rights please contact us using the contact link provided below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

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.

  1. State Privacy Notices
    • California
      • 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 Websites, 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 Policy.

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 contractors (“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 Websites that we provide to customers, including the following CCPA categories and non-exhaustive examples within such categories:

  • Identifiers: g., your name, employer, email address, IP address.
  • Customer Account Details: g., your name.
  • Commercial Information: g., purchase records regarding the Tackle customer products purchased through the Tackle Marketplace (i.e., the various business to business cloud marketplaces on which Tackle customers use Tackle products and services to sell their products), work email, business phone number.
  • Internet or Usage Activity Information: g., data related to the interaction with the Websites.
  • Professional or Employment Information: g., your employer, title.
  • Inferences from PI Collected: g., your preferences or likelihood of interest in certain of our Websites.

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

CCPA-defined Business Purposes (CCPA Section 1798.140)

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

 

Tackle obtains the categories of PI 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 Websites
  • From third parties that interact with us in connection with the Websites

 

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

  • Sharing PI

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 PI in connection with the Websites we provide to you; or
  • Government representatives as required by law.

In the preceding twelve (12) months, we have not sold any PI.

  • CCPA Consumer 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 use with certain information, we will be unable to verify your identity to fulfill a request to know or delete.  We verify identity by comparing information you provide in respect of your request with information we have in our systems.  We reserve the right to ask you to provide additional information in order to help 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 an email address.
  • 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. 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 Data 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 Data (e.g., clickstream data tied only to a pseudonymous browser ID).  As required by the CCPA, we do not include that Personal Data 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 instead by canceling or modifying our 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 Website, such as administrative and Website 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 Websites 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 Websites 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.

13. Changes to This Privacy Policy.

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Website indicates your consent to the privacy policy posted at the time of use.  To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

If we change our privacy policies and procedures materially, we will post those changes to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner we will update the ‘effective date’ at the top of this page, and we may also notify you of the change via email or other prominent notice posted on this site or the Website.

14. Contact Us.

If you have any questions about this Privacy Policy, please contact us here.