Tiltsta, Inc. Privacy Statement

Effective Date: 23 April 2018

Tiltsta, Inc. (collectively, “Tiltsta, we, us, our and similar expressions) is a technology company providing integrated eCommerce solutions.

By accessing our website located at a domain or subdomain owned by us, including the website www.tiltsta.com (“Website”), using our products or services including the Tiltsta Mobile Application (“Application”), or otherwise providing us with your Personal Data (as that term is defined in section 3), you signify and confirm that you have read and accept the terms of this Privacy Statement and expressly consent to the collection, storage, use and disclosure of your Personal Data in accordance with the terms of this privacy statement (“Privacy Statement”).

If you do not feel comfortable with any aspect of this Privacy Statement or do not agree to the terms of this Privacy Statement, you must immediately leave the Website and discontinue your use of our products and services, including the Application. In order to fully understand your rights, we encourage you to carefully read this Privacy Statement.

1. Changes to this Privacy Statement

We may update this Privacy Statement from time to time. If we change the Privacy Statement in any material way we will notify you of the change by contacting you through our Website, our services, or by sending you an email prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

2. Our Privacy Commitment

Your privacy is important to us. Your Personal Data will be collected, used, stored and disclosed by Tiltsta in accordance with this Privacy Statement.

If you have any queries relating to this Privacy Statement, or the manner in which we collect, store, use or disclose your Personal Data, please contact our Privacy Officer using the contact details at the end of this document.

3. Information We Collect

So that we can provide you with our Website, and our products and services including the Application (collectively, “Services”), we may need to collect information from you or about your use of our Services as described below which may identify you or by which you may be reasonably identifiable (“Personal Data”).

Please be aware that you can choose whether to provide us with the types of information described below, but your choices may affect our ability to offer you part of or all of our Services. If you do not provide us with the information we request, we may not be able to supply you with all or part of our Services. Any information that we do not require you to supply is information that you provide to us voluntarily.

  • Information you provide to us when accessing or using our Services. We collect information you provide to us, including, but not limited to:
    • Registration information. By registering with us, you authorize us to collect any information that you make available to us when accessing or using our Services. We may collect information about you including your first and last name, email address, website address, company name, and contact and address details.
    • Order information. If you purchase products or services from us or through our Services, our payment gateway provider or third party suppliers may also require your credit card details, order and billing information to process your transaction. Your credit card details are not stored in any form by us or on any internal or external databases that are accessible to us.
    • Third party information. We may receive information about you from third parties that you have authorized to share such information with us. For example, if you link your social media account with our Services, we may receive information about you from your social media account.
    • Communications with us. When you communicate with us in any way (e.g., telephone, email, SMS, etc.), we will collect your contact information and any other information you may choose to provide to us.
  • Information about your use of our Services. We also collect information about you passively when you use or access our Services. We will combine this information with information you give to us and information we collect from you. For example, we collect information which may include, but is not limited to:
    • Mobile data. You may access or use our Services via a mobile device or application. We may collect information about you and your device, such as your IP address, location or device information, and any other information provided by your mobile device. If you do not want us to collect your location information you can disable the GPS or location-tracking function of your device.
    • Third-party plugins. In some cases, we may have integrated a third-party plugin into our Services and the use of such third-party plugins results in data collection by both Tiltsta and the relevant third party. Please refer to the third party’s privacy statement to understand their data handling practices as we do not control the information you may share with them.
    • Cookies and similar tracking technologies. We use both first-party and third-party cookies, and similar tracking technologies on our Services. A cookie is a small data file that is stored on your device and collects information, such as your IP address or information about your use of or your activities on our Services. Further information about this is detailed below in the section titled ‘Website Usage, Tracking Information and Cookies’.
    • Log data. We collect log data about your use of our Services, which may include your IP address, data, and time of your access or use of our Services, page views, the referring URLs, and any other information about your activities on our Services.
    • Accessing and using our Services in any other way. When you use or access our Services, we may collect information such as any interactions with other users and any other activities on our Services.

4. Why We Collect Personal Data

We collect Personal Data so that we can carry out our business activities in a professional and efficient manner, and improve our Services. We also collect your Personal Data for the purposes stated below:

  • set-up and configure customer accounts;
  • facilitate and fulfil your requests and orders for products and services;
  • identify our customers, potential customers and people acting on their behalf;
  • improve our service offerings including contacting you in relation to present, past and abandoned orders;
  • record and maintain user details and profile information;
  • provide information on services available to subscribers;
  • provide client and user support;
  • deliver marketing materials to you regarding services and offers we believe may be of interest to you;
  • collect fees and payments owing to us;
  • comply with legal obligations;
  • resolve disputes;
  • enforce agreements with third parties;
  • detect, prevent, and investigate potential or actual fraud or other harmful activity to you, us, or any third parties;
  • respond to your enquiries and concerns and resolve disputes;
  • advertise our Services or the services and products of third parties;
  • contact you regarding your use of our Services; and
  • compare information provided by you for accuracy and verify it with third parties,

and any secondary purposes related to the above.

5. Disclosure of Personal Data

In carrying out our business, we may disclose your Personal Data to others, including, but not limited to:

  • related entities of Tiltsta;
  • service providers contracted by Tiltsta, including information technology service providers, printers and distributors of marketing material, creditors, bankers, financiers, credit providers, mortgage insurers or trade insurers, and external business advisers (such as auditors and lawyers);
  • third parties authorized by you;
  • third parties as required by law, such as to comply with a subpoena or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, to protect the safety of you, others, or us, to investigate, or to respond to a government or law enforcement request;
  • third parties involved in a business transaction with us, such as in the case of a merger, acquisition, or sale of all or a portion of our assets, as permitted by applicable law;
  • detect and prevent fraud;
  • protect the rights, property, and safety of Tiltsta, you, and others;
  • enforce our policies and agreements;
  • members of Tiltsta’s user groups. For example, discussion groups where you have opted-in to that user group, or where you take part in any interactive areas of the Websites or your account; and
  • any third-party plugins. Your interactions with third-party plugins will be governed by the privacy statement of the company providing the third-party plugin.

6. Overseas Disclosure of Personal Data

As a global organization, we may store, use, transfer, and otherwise process your Personal Data in countries outside of the country of your residence (which may include the United States and Australia). By using our Services, you consent to Tiltsta’s transfer to, and handling of, your Personal Data in a jurisdiction which may have different (and less stringent) data protection rules than the country in which you reside.

7. Marketing

Where we use your Personal Data to send you marketing and promotional information, we provide unsubscribe links or an opt-out mechanism for your convenience. You may change your communication preferences at any time.

8. Website Usage, Tracking Information and Cookies

We collect limited information about people who use our Services so that we can track the use of those resources, maintain and improve our Services, and understand how our users interact with our Services. We do not use these technologies for tracking of any information about your use of other websites or services which are not connected to our Services. Information we collect may include:

  • server and/or internet protocol (IP) addresses;
  • top level domain names;
  • the date, time and duration of your visit;
  • pages accessed and documents downloaded;
  • referring and exit pages;
  • whether you are a returning visitor;
  • the type of browser used,
  • the hardware type and operating system of the device used,(collectively, “Usage Information”).

In order to collect Usage Information, we may use software embedded in our Websites (such as JavaScript) and we may place small data files (cookies) on your computer or other. We may also use similar means, including third party services such as Google Analytics, to track Usage Information in relation to our products and services.

Unless you have registered for an account with us, we will not link Usage Information to your Personal Data such as your user name. If you register for an account with us, Usage Information will be associated with your registration data. If you do not register for an account with us, Usage Information will be aggregated with that of other unregistered users and will not be associated with an identifiable person.

You may decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our Websites, products and services. You can refer to the ‘help’ section of your browser or installed applications for instructions on blocking, disabling or deleting cookies. Google provides further information about its own privacy practices and offers a browser add-on to opt out of Google Analytics tracking.

9. “Do-Not-Track” Signal

You may disable cookies through your browser settings, but at this time we do not honor “Do-Not-Track” signals.

10. Storage of Personal Data

We will retain your information for as long as permitted to conduct the Tiltsta business, comply with our legal obligations, resolve disputes, and enforce our agreements. When we dispose of Personal Data, we ensure that it is destroyed or de-identified in a secure fashion according to industry standards and as required by law.

11. Security of Personal Data

We take all reasonable steps to keep the Personal Data we hold about you secure and free from loss, misuse or interference. Personal Data we collect and store is stored on secure servers, and is only accessible by those persons who need access to the information in order to carry out their business functions. We also maintain physical security measures to protect the use and storage of physical records containing Personal Data. However, you acknowledge that no method of transmission or electronic storage is completely secure, and Tiltsta cannot control the security of data collected, stored, and disclosed on third party platforms. You transfer and store your information at your own risk. You are also responsible for the security of your Personal Data by taking precautionary measures, such as keeping your account password confidential and using secure wireless connections.

If your information is disclosed to third party service providers, we will enter into arrangements which require them to maintain the security of your information.

12. Accessing Your Personal Data

You may request that we provide you with access to the Personal Data we hold about you by contacting us using the contact details provided at the end of this Privacy Statement. However, privacy and data legislation in your jurisdiction may set out certain circumstances where we may deny, or only partially comply with such a request. These circumstances may include, for example, where:

  • access would pose a serious threat to the life, safety or health of any individual or to public health or public safety;
  • access would have an unreasonable impact on the privacy of other individuals;
  • the request is frivolous or vexatious;
  • denying access is required or authorised by a law or a court or tribunal order;
  • access would be unlawful; or
  • access may prejudice commercial negotiations, legal proceedings, enforcement activities or appropriate action being taken in respect of a suspected unlawful activity or serious misconduct.

If you require access to any information we hold about you, we request that you identify, as clearly as possible, the type of information requested.  We will respond to your request to provide access to your Personal Data within a reasonable period after the request is made, and you agree we may charge you our reasonable costs incurred in supplying you with access to this information as permitted by the jurisdiction you reside in.

13. Updating Your Personal Data

We take such steps as are reasonable in the circumstances to ensure that:

  • the Personal Data we collect and store, is accurate, up to date and complete; and
  • the Personal Data we use and disclose is accurate, up to date, complete and relevant.  

If you believe that information we hold about you may not be up to date, complete and accurate, you may notify us by contacting us using the contact details below.

You accept that we will take reasonable steps to verify your identity if you contact us with such a request.

14. Anonymity and Pseudonymity

If you are making a general enquiry only, you may deal with us on an anonymous basis or through the use of a pseudonym. However, we will not be able to provide you with any specific information about your account if you fail to identify yourself to us.

15. Third-Party Links

Our Website and Services may include links to other websites whose privacy practices may differ from ours. If you provide your Personal Data to any of those sites, your information is governed by their privacy policies.

16. Children’s Privacy

We do not knowingly request or collect Personal Data from any person under the age of 16 years old, or equivalent minimum age depending on the jurisdiction. Children under 16 should not provide Personal Data to us on our Website or services. Please notify us if you know of any children using our Website or services so we can take action to prevent access to our Website and services and delete their information.

17. Queries, Concerns and Complaints

If you have any queries, concerns or complaints about the manner in which we have collected, stored, used or disclosed your Personal Data, please contact the Tiltsta Privacy Officer using the details below:

Attention:

Privacy Officer
Tiltsta, Inc.
25 W 39th Street, 14th Floor
New York NY 10018

Email: privacy@tiltsta.com 

We will treat your complaint confidentially and, after investigating your complaint, discuss the ways in which we can remedy the situation. We will ensure that we respond to your complaint within a reasonable time (and in any event within the time required by privacy and data protection legislation in your jurisdiction).