Last Updated: 2nd Feb, 2022
- Information We Collect
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:
- Personal Data That You Provide Through the Services
- Contact Information
Where you choose to import to sync your Google account, contacts, iCal or similar accounts or services with our Services, we will collect and store information such as your contacts’ email address, name, address, website URL, phone number and other metadata assigned to that contact; we obtain this data in order to create profiles, suggest existing profiles for you to connect with and invite new persons to use the Services. If you activate Gmail integration on your account you will be able to use the Services to send emails to your customers and create calendar events.
- Bank Account Information
- Other Information
- Non-Identifiable Data: When you interact with TinyWhale through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
- Cookies: In operating the Services, we may use a technology called “cookies.” Please refer to our Cookie Notice for more details on our cookie use, including information on how you can opt-out of certain cookies.
- Aggregated Personal Data
We at TinyWhale continuously strive to better understand and serve YOU. As such, we often conduct research on our customer demographics, interests and behavior based on the Personal Data and other information provided to us, including information available in any vendor contracts and related proposals that you may upload. Rest assured that we definitely do not use or aggregate Contact Information for these purposes. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
- Location Information
Our Services and third parties that are integrated into our Services may collect and use your location information (for example, by using the GPS on your mobile device) to better provide certain functionality of our Services. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.
- Tracking and Analytics
- Social Networking Services
With that being said, we have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that are enabled within the Services, so we strongly recommend that you also read through the policies of such third parties to educate yourself on how they use, store and disclose your information.
- Personal Data That You Provide Through the Services
- How we Use the Information We Collect
This includes for the following:
- Operate and improve our Services;
- Send you advertising or promotional materials;
- Provide and deliver the Services or other services you request, process transactions, and send you related information;
- Send you technical notices, updates, security alerts, and support and administrative messages;
- Respond to your comments, questions, and requests and provide you with requested customer support;
- Monitor and evaluate trends, usage, and activities in connection with our Services;
- Secure our systems, prevent fraud, and help us to protect the security of your account;
- Prevent, detect, and investigate potentially prohibited or illegal activities and to enforce our terms and policies;
- Personalize and improve the Services, and provide content, communications, or features that match users interests; and
- Link or combine with other information we obtain from third parties to help understand your needs and provide you with better service.
- How we Share/Disclose your Personal Data and Other Information
There are some situations where we may share your Personal Data with selected third parties without further notifying you. For example:
- Service Providers, Agents, Consultants and Third Parties
Like many other businesses, we sometimes engage or work with other companies to perform certain business-related functions in the provision of our Services to you. For example this may include processing payments, advertising and marketing, security, infrastructure and IT services, mailing information etc. When we engage another entity to perform such functions, we only provide them with the information that they need to perform that function.
- Business Transfers
As we grow, we may buy or sell business or assets. Where we conduct a corporate sale, merger, reorganization, dissolution or something similar (individually known as a “Corporate Transaction”), Personal Data may be part of the transferred assets. On top of this, we may provide certain Personal Data to an investor or prospective investor and their legal or business advisors in anticipation of and/or in connection with a potential Corporate Transaction. We’ll definitely update you if we disclose any Contact Information in connection with a Corporate Transaction.
- Related Companies
- Legal Requirements
We may disclose your Personal data if required to do so by law, or in the good faith believe that this is necessary to:
- Comply with a legal obligation;
- Protection and defend our rights or property;
- Act in urgent circumstances to protect the personal safety of users of the Services or the public; or
- Protect against legal liability.
We may share Personal Data with your consent.
- Service Providers, Agents, Consultants and Third Parties
- Where we Store Your Personal Data
- Data Storage
All the data that you provide to us through our Services is stored on secure servers located in the U.S. Any payment transactions will be encrypted using SSL technology; all payment data is stored by our payment processors and is never stored on our servers. Where we have given you (or where you have chosen) a password that enables you to access your account and the Product, you and you alone are responsible for keeping this password confidential. We recommend that you not share your password and that you change it often.
- Data Security
We take reasonable measures to protect your Personal Data and your content from loss, misuse, and unauthorized access, disclosure, modification, and destruction and to ensure that your content remains protected and available to you. However, the transmission of data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your Personal Data sent through the Services. Please note that all transmissions are at your own risk.
- Data Retention
We store the information we collect for as long as necessary for the purpose for which it was originally collected and in compliance with our legal obligations. The retention periods applied by TinyWhale comply with applicable legislation then in effect, namely:
- For data relating to your account, such data will not be retained beyond your request that your account be deleted.
- For transactional data relating to your purchases, such data is kept for the entire period of our contractual relationship, then in accordance with legal obligations and applicable statute of limitations periods. Please note that this data does not include payment card information, which is processed by our third-party payment processors and not TinyWhale.
- For data collected based on your consent to receive marketing communications, we will use the data until you withdraw your consent or applicable law requires that such data is no longer used.
- For data collected in connection with your requests or questions, such data is kept for the period necessary to process and reply to your request or question.
- When cookies or other trackers are placed on your computer, they may be retained for a period of 12 months.
We may retain certain information for legitimate business purposes or as required by law.
- Third Parties
- Data Storage
- Your Choices and Rights
You can visit the Site without providing any Personal Data, but do note that you may not be able to use certain Services.
You also have several options with respect to your Personal Data as detailed here:
- You can terminate your use of the Services at any time (of course, we’d much prefer if you didn’t!). However, we would still be able to process your Personal Data in our capacity as a service provider to our customers if your Personal Data is necessary for us to provide our Services to them.
- Once you’ve created your account, you can access, change or delete your personal information whenever you want. However even if you delete certain information from your account or deactivate your account, we may continue to retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.
- You can opt out of receiving promotional emails, text messages or mail from us by emailing email@example.com or visiting your user settings via the “Edit Your Preferences” or “Completely Unsubscribe” link in any promotional email. Do note that even if you opt out, we’re still able to send you transactional or relationship messages like emails about your account, or updates to our Services.
- If you don’t have an account and want to delete any personal information you might have provided through your use of our Services and/or any other services, please email us at firstname.lastname@example.org with the header “Delete My Information” in the subject line.
These are gross, and we definitely do not knowingly permit their use and/or other similar types of software.
- Links to External Sites
- Transfer of Information Across National Borders:
If you are located outside the jurisdiction of the United States, please note that TinyWhale operates and processes data in the United States. Information we collect from you will be processed in the United States, and by using this website you acknowledge and consent to the processing of your data in the United States. Last we checked, United States has not received a finding of “adequacy” from the EEA under Article 41 of the GDPR.
- Privacy Shield
As you may be aware, TinyWhale is based in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EEA and the U.K.. Transfers of your Personal Data to us in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.
- EEA Data Subjects & Transfers Outside the EEA
For our EEA users, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. We may provide your data to third party providers who are located outside the EEA, or they may use servers that are located outside the EEA. If this happens, we will ensure that adequate protection of your data is provided as required by applicable law, for instance by concluding Standard Contractual Clauses issued by the European Commission.
- Residents of the EEA
We provide the representations and information in this section in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). If you reside in the European Territories (including the EEA, Switzerland, and the United Kingdom), our legal basis for collecting and using the Personal Data will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect Personal Data from you where the processing is in our legitimate interests. In some cases we may collect and process Personal Data based on consent.
EEA data subjects have certain rights with respect to your Personal Data that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
- Access, Correction or Deletion. You may request access to, correction of, or deletion of your Personal Data. We recommend that you check out your Account Settings to take these actions directly.
- Restriction. You have the right to ask us to suspend the processing of your Personal Data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you don’t want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Portability. You have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent. If we have collected and processed your Personal Data with your consent, you can 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 Data conducted in reliance on lawful processing grounds other than consent.
- File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your Personal Data. To file a request or act on one of your rights, please contact us at the contact details provided below. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- California Resident Notices
- California Consumer Privacy Act
Effective January 1, 2020, the California Consumer Privacy Act of 2018 (the “CCPA”) allows you, the consumer who is a California resident, upon a verifiable consumer request, to request from businesses (like us) to:
- Delete any Personal Data about the consumer which the business has collected from the consumer;
- Disclose to the consumer certain information about the Personal Data that the business collects from the consumer; and
- Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
We do not sell any consumer Personal Data to third parties. If you want to submit a data access or data deletion request, please get in touch at email@example.com. However, if your request relates to Personal Data collected through any client’s or vendor’s websites or digital products, you’ll need to get in touch with the owner of that website or product directly. We may ask you certain questions to verify your identity, and ask for your email or other confirmation, before we process your request. Consistent with California law, if you choose to exercise your rights, you will not receive discriminatory treatment from us.
In certain situations, you can designate an authorised agent to make a request on your behalf. You may be asked to provide certain verification details such as a valid power of attorney, a valid government ID, and the authorised agent’s valid government ID before we proceed with your request.
- California’s Shine the Light Law
If you reside in California, CA Civil Code § 1798.83 allows you to request and obtain from us once a year, free of charge, a list of the third parties to whom we may have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. As a general policy, we do not share personal information with third parties for their own direct marketing purposes without getting your consent first. If all this sounds awful to you, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent. Do get in touch with us at firstname.lastname@example.org if you want to make such requests.
- Do Not Track Disclosure
Regulatory agencies such as the U.S. Federal Trade Commission have promoted the concept of Do Not Track as a mechanism to permit internet users to control online tracking activity across websites through their browser settings. Since no industry standard has been adopted, we currently do not process or comply with any web browser’s “do-not-track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our Site or use our Services.
- California Consumer Privacy Act
- Any Personal Data collected by us that is not Personal Data collected through the Services;
- Any unsolicited information you provide to us through the Services or any other means, which will be considered non-confidential and which we’ll be free to reproduce, use, disclose to and share with others without limitation or attribution.
We know how important Personal Data is, and we take reasonable steps to protect the Personal Data you provide through the Services from loss, misuse, unauthorised access, disclosure, alteration or destruction. However despite our efforts, no internet or email transmission is 100% secure or error free. We strongly recommend that you take lots of special care and consideration in deciding what information you send over email. Please also keep this in mind when you disclose any Personal Data to us through the internet.
- Other Terms and Conditions
- Your Acceptance of These Terms
- Contacting Us