Privacy Policy


TARTLE PBC ("TARTLE," "we," "us," or "our") welcomes you. We want to be clear and transparent with you, so we have created the following privacy policy (the "Privacy Policy"), which discusses how we collect, use, and protect your information when you access and use our Digital Properties. By accepting this Privacy Policy, accessing or using the Digital Properties, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy and the accompanying Terms of Use, which together make up the Agreement. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms of the Agreement, you may not access or use the Digital Properties.

If you accept or agree to this Agreement on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to the Agreement and, in such event, "you" and "your" will refer and apply to that company or other legal entity.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Use.

THE INFORMATION WE COLLECT AND HOW WE USE IT

In the course of operating the Digital Properties, TARTLE collects or receives the following types of information from visitors to our Website, Buyers, and Sellers, which may include personal information. Below we describe the various types of information we collect when you engage with our Digital Properties, how we collect it, and how we use it.

Contact and Account Information

We collect contact information on our Digital Properties; contact information typically includes your name, email address, phone number, and any information you provide in messages to us (collectively, "Contact Information"). We use such contact information for purposes such as registering you for an account on the Platform, providing you with information about the Digital Properties, responding to your inquiries, sending you email alerts (including marketing emails), or providing you the Digital Properties.

Once you create an Account, in addition to requesting your Contact Information, we will also ask that you provide us with, among other things, your birthday, gender, ethnicity, race, location, education level, relationship status, household income, causes you are passionate about, how much you plan to earn, and how much you want to donate, as applicable. This information is checked against international databases to screen out bad actors. If you are a Seller, this information will also constitute your first Published Data Packet that you can choose to sell for profit.

Seller Data

Our Platform is a data marketplace where Sellers have free reign to:\ (i) download or transmit any Seller Data to the Platform, (ii) accept Data Packet bid requests, and (iii) sell Published Data Packets, in each case, at the Seller’s direction in accordance with the Seller’s wishes. Therefore, our Platform will hold any information, including personal information, sensitive information, or otherwise, that you choose to transmit or download through the Platform. Any Seller Data transmitted or downloaded to the Platform is used to allow you to access and use the Platform, and with your consent, we may convert such Seller Data into Aggregate Data, as described in Section 4.3 of our Terms of Use.

When you establish your Account, we want to leave the big decisions you. You may choose to make Manual Submissions of Seller Data by inputting your Seller Data directly, or Automatic Submissions of Seller Data by connecting your Account to your account on a Third-Party Platform. If you make Automatic Submissions, you acknowledge that we will continuously receive information about you from the Third-Party Platform in accordance with the Third-Party Platform’s privacy policy.

Payment Information

In order for us to process and remit payments, you will be required to provide our Payment Processors certain payment information (collectively, "Payment Information"). You authorize our third-party Payment Processors, including Paypal, to collect, process, and store your Payment Information in accordance with their respective privacy policies. We reserve the right to change our Payment Processors at any time, or to use additional Payment Processors, at our discretion, and will update this Privacy Policy from time to time accordingly.

Server Logs

Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device's IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Digital Properties or the pages you’ve clicked on while on our Digital Properties). We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

Cookies

Similar to other online services, we collect information using "cookie" technology and other similar technologies. Cookies are small packets of data that a website stores on your computer's or mobile device's hard drive (or other storage medium) so that your computer will "remember" information about your visit. We use both first- and third-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

  • Session Cookies: We use session cookies to make it easier for you to navigate our Digital Properties. A session ID cookie expires when you close your browser.
  • Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s "help" file. To the extent we provide a log-in portal or related feature on our Digital Properties, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Digital Properties.

In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Digital Properties (e.g., email open rates, URL click-throughs).

If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies or similar technologies from us, certain aspects of the Digital Properties may not function properly or as intended.

Third-Party Analytics Providers

We want to understand how you are using our Digital Properties. We may evaluate your use of the Digital Properties by using our own analytics tools or third-party analytics services which compile reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Digital Properties you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These analytics tools use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using the Digital Properties, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Digital Properties.

For Google Analytics, please visit: https://support.google.com/analytics/answer/6004245?hl=en and https://tools.google.com/dlpage/gaoptout

Third-Party Advertisers/Remarketers

To personalize our advertisements and otherwise understand how you engage with our advertisements, we may share or receive information about you with/from third parties, including, but not limited to, advertising and remarketing providers. These third parties may use cookies, pixel tags, or other technologies to collect information in furtherance of such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. Information that we may receive from these third parties, including through their service providers, may include advertising identifiers, IP addresses, reports, and campaign data.

By accessing and using the Digital Properties, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please note that this list may be subject to change based on the campaigns that we run.

Usage and Aggregate Data

In an ongoing effort to better understand our users and the Digital Properties, we might analyze Usage Data and Aggregate Data to operate, maintain, manage, and improve the Digital Properties. Usage Data and Aggregate Data do not identify you personally. We may share this data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe the Digital Properties to current and prospective business partners and to other third parties for other lawful purposes.

How We Transfer Your Information to Third Parties

We will only share your information as provided in this Privacy Policy or otherwise disclosed to you on our Digital Properties. In the event you believe we are using your information in a manner not disclosed to you, please notify us immediately and we will take prompt steps to rectify it.

Like many businesses, we hire other companies to perform certain business-related services. The types of companies that may receive personal information and their functions are: hosting services, storage providers, cloud software providers, technical assistance, database management/back-up services, use analytics, advertising/remarketing, email marketing platforms, customer relationship management, customer service, and payment processing.

Sellers are able to choose how they want to sell to Buyers Published Data Packets containing their Seller Data. One way is by creating your own Published Data Packets with your Seller Data and selling that through the Platform. Another way is by responding to Buyer Data Packet bid requests. When a Buyer submits a bid for a Data Packet, if your demographics match the parameters of the Data Packet bid request, you can set your Account preferences to either (i) require your approval before responding to a bid and sending the Buyer a Published Data Packet ("Manual Sale"), or (ii) automatically complete the Data Packet with your Seller Data and sell the Published Data Packet any time you meet the Data Packet parameters ("Automatic Sale"). You can also be more specific with your choices, such as requiring Manual Sales if bids are below market price and approving Automatic Sales when bids are at or above market price. You can change your preferences at any time through your Account.

Business Transfers

In the event of a merger, dissolution, bankruptcy, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger, the acquiring entity, or our creditors. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon TARTLE and its legal successors-in-interest.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

OPT-OUT FOR DIRECT MARKETING; EMAIL MANAGEMENT

You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to [email protected] or by clicking on the "Unsubscribe" link located on the bottom of any TARTLE marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Digital Properties.

HOW WE PROTECT YOUR INFORMATION; THIRD PARTY SECURITY RISKS

TARTLE takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. E-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

As mentioned in our Terms of Use, we disclaim liability for the risks, which may include security risks, associated with the various third-party services that may be used in connection with our Digital Properties. For example, when you connect your Account to your account on a Third Party Platform, while the information is under the custody and control of the Third Party Platform, including during the transfer through their API, we have no control over its security. Please read each connected Third Party Platform’s terms of use and privacy policy carefully. Additionally, if you make or receive payment using the Wallet and Virtual Currency, TARTLE has no control over Virtual Currency networks and there are various risks you should be aware of, including the risk of malicious software introduction. Please see Section 3.4 of our Terms of Use for more information.

CHILDREN

We do not knowingly collect personal information from children under the age of 13 through the Digital Properties. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected], and we will endeavor to delete that information from our databases.

IMPORTANT NOTICE TO ALL NON-US RESIDENTS

Our servers are located in the US. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Digital Properties, you do so at your own risk.

CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact TARTLE via email at [email protected].

DO NOT TRACK

Where technically feasible, TARTLE responds to "Do Not Track" settings or other related mechanisms at this time.

NEVADA PRIVACY RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A because TARTLE obtains your consent to sell your information and uses your information for purposes consistent with your reasonable expectations.

LINKS TO EXTERNAL WEBSITES

The Digital Properties may contain links to third-party websites ("External Sites"). TARTLE has no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting any such External Sites.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Digital Properties after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Policy, please e-mail us at [email protected] with "Privacy Policy" in the subject line.