TARTLE Privacy Policy

Last Update: 11-July-2023

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.

I. THE INFORMATION WE COLLECT, HOW WE COLLECT IT, 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 Profile Information

We collect contact information on our Digital Properties when you choose to provide it to us; 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.

In order to create an account with us, we will ask you to provide a username and password and potentially additional information that will assist us in authenticating your identity when you log-in in the future (collectively, the “Login Credentials”).

Once you have created an Account, we will 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 (“Profile Information”). This information is checked against international databases to screen out bad actors. If you are a Seller, you can choose to transfer all or part of the Profile Information to become part of your Seller Data. In that case, the transferred Profile Information will become your first Published Data Packet that you can choose to sell for profit.

Seller Data

a) What Seller Data Will Be Used For

As described in more detail in our Terms of Use, 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 to or download through the Platform. Unless we act as a Buyer and purchase the data ourselves, we have no access to any of the Seller Data. Our Platform merely facilitates the transactions between Buyers and Sellers.

b) Uploading Seller Data

After creating your account, you will be able to add data to sell in three different ways. Integration packets allow you to connect TARTLE to a third party, for example, LinkedIn, and automatically pull data into TARTLE. This occurs only when you choose to sync the data, and TARTLE does not keep credentials or access to your account after syncing the data. You will have a chance to review the data retrieved by visiting the completed packet page after completing a data sync. Questionnaire packets allow you to enter information to each question, save your progress, and publish the packet to be able to sell the data. Finally, certain packets provide the ability to upload documents, photos, and other file types.

c) Deleting Seller Data

You may, at any time, ask us to delete the data uploaded, recorded, or downloaded to your Account on the Platform by you or at your request. You can do so by visiting https://source.tartle.co/sellers/account_settings and clicking on the button “Delete Account”. You may also send account deletion requests to [email protected]. You may be asked to provide additional identity verification when requesting account deletion via email.

On deleting your Account, we will destroy all Seller Data you have stored in your Account on the Platform, and disable any access to the Account. The only data we will keep are (i) the empty Account, which is identified via a pseudonymized account identifier; (ii) the email associated with it; and (ii) the Financial Transactions Data associated with the Account. We do so to comply with anti-money laundering and other legal requirements.

Financial Transactions Data

When you sell a published data packet, we link the transaction to your account and a record is kept of the packet sold. We will log the time of the transaction, the amount of money paid to you, and a transaction link (“Financial Transactions Data”). The Financial Transactions Data does not include any additional information about the Data Package that was sold. We log and keep the Financial Transactions Data in order to comply with anti-money laundering and other legal requirements.

Server Logs

Like most websites today, our web servers automatically collect and store 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 “cookies” 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). For more information on how to disable cookies or opt out of certain data collection, please refer to the section “Your Choices” below.

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, tracking pixels, 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 how to disable cookies or opt out of certain data collection, please refer to the section “Your Choices” below.

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 how to disable cookies or opt out of certain data collection, please refer to the section “Your Choices” below.

Information From Other Third-Party Sources

We may collect personal information from users and visitors of other sites on which you have interacted with us. We will do so in accordance with the terms of use and privacy policies of those sites and applicable law. This includes our social media pages on places like Facebook, Instagram, TikTok, YouTube and Twitter. For example, we may collect the information you shared on our social media pages through an application or form, which will have a link to this Privacy Policy. We may also receive personal information when you comment on our social media posts, post comments about us, or tag TARTLE in a public-facing social media post. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about visitors’ use of our social media pages. This allows us to better understand and analyze our visitors, general demographic information about the visitors of these pages, and interaction with the content that we post. Overall, this information may be used to help us understand the types of visitors of our social media pages and how they interact with the content. This Privacy Policy does not cover personal information collected by such third-party social media sites. For more information on their privacy and security practices please review the privacy policies and terms of use on their respective websites.

Usage and Aggregate Data

As described above, we monitor the performance and use of the Digital Properties by you, and we collect data in connection therewith, including, without limitation, date and time that you access the Digital Properties, the portions or pages of the Digital Properties visited, the frequency and number of times such pages are accessed, and other usage data (the “Usage Data”). In an ongoing effort to better understand our users and the Digital Properties, we may aggregate Profile Information (“Aggregate Data”) and analyze it together with Usage Data. We may also combine Aggregate Data and Usage Data and analyze it 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.

II. WHEN AND HOW WE MAY SHARE YOUR INFORMATION WITH THIRD PARTIES

We will only share your information as provided in this Privacy Policy or otherwise disclosed to you on our Digital Properties, or as required under applicable law. If 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 if needed.

Third-Party Service Providers

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. Additionally, we may use third-party credit card processing companies to process and remit payments. These other companies will have access to your information only as necessary to perform their functions and to the extent permitted by law.

For Advertising And Marketing Purposes

We may share information about your activity in connection with your use of the Digital Properties, including tracking data, with third-party advertisers and remarketers to serve advertisements on our behalf across the internet. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Digital Properties and other sites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

We may also work with third-party social media sites, such as Facebook, Google, and other media platforms, to serve ads to you as part of a customized campaign, unless you notify us that you prefer not to have information about you used in this way. For more information about how you can opt out of customized campaigns, please see “Your Choices” below.

Affiliates and Successors

We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us, with your consent where required by law. Further, as we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your information may be part of the transferred assets.

Compliance with Legal Requirements

We (and our Service Providers) may disclose your information if required or permitted to do so to:

  • Comply with applicable laws and legal processes;
  • Respond to requests from law enforcement authorities, public and government agencies or officials, or other persons or entities with appropriate legal authority or justification to receive such information, including persons or entities outside your country of residence (including in jurisdictions where we or our Service Providers are located); and
  • Protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

Aggregated, De-Identified Information

As mentioned above, we may share Usage Data and Aggregate Data (which do not identify you personally) 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.

III. YOUR CHOICES

1. Opt-Out Of 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 emails related to the Digital Properties.

2. Deletion Of Information

If you would like us to delete any or all information, first begin by using the self-service tool found in the seller application at https://source.tartle.co/sellers/account_settings/account_info . If you are in need of further assistance please email us at [email protected]. To the extent compatible with our legal or regulatory record keeping requirements, we will use commercially reasonable efforts to process such requests in a timely manner. Our internal data retention policy states that we will keep a record of all deactivated accounts for 2 years before complete deletion from our records.

3. Targeted advertising; website analytics; Do Not Track

Depending on where you access the Digital Properties from, you may be presented with a cookie banner or other tool to provide permissions prior to the setting of non-necessary cookies. In this case, we will only set these non-necessary cookies with your consent. Where this option is available, you may revoke your consent at any time with future effect by clicking on the cookie settings link.

You can also limit online tracking via the following methods:

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

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

IV. 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 email.

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, 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.

V. CHILDREN

We do not knowingly collect personal information from children under the age of 18 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.

VI. 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.

VII. NOTICE TO RESIDENTS OF THE EEA AND UK

If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), you have additional rights under the General Data Protection Regulation and the United Kingdom General Data Protection Regulation (the “GDPR” and the “UKGDPR,” respectively). For more information about your rights under these laws, please visit our GDPR Privacy Notice.

VIII. NOTICE TO CALIFORNIA RESIDENTS

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].

IX. NOTICE TO NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. 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, however, that we do not sell your personal information as sales are defined under Nevada law.

X. 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.

XI. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the “last update” 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.

XII. HOW TO CONTACT US

If you have questions about this Privacy Policy, please email us at [email protected] with “Privacy Policy” in the subject line.


GDPR notice