Privacy Policy
Privacy Policy Tumella
Last Updated: December 31, 2020
Introduction
Your privacy and the safety of your personal data is important to us. Therefore, we created this privacy policy to let you know how we handle your data and what our legal obligations are regarding the safety of your personal information.
Tumella ("us", "we", or "our") operates the website www.tumella.com (the "Service").
The reason why we use your data is to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from. If you have any questions regarding this Privacy Policy you can contact us by sending an email to: privacy@tumella.com.
Table of Contents
- Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
- California Consumer Privacy Act (CCPA)
- Information Collection And Use
- Transfer Of Data
- Security Of Data
- How long does Tumella keep your information?
- Service Providers
- Links To Other Sites
- Children's Privacy
- Changes To This Privacy Policy
- What are your legal rights with regard to Tumella processing your data?
- Contact Us
- Privacy and the European General Data Protection Regulation (GDPR)
As we are a company based in the European Union, we need to comply to the General Data Protection Regulation (GDPR). The legal grounds for processing Personal Data under the GDPR described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
We may process your Personal Data based on several legal grounds. One of the grounds is because we need to perform a contract with you. This is for example the case when we need to comply with the agreements we made together according to the Terms of Service.
Another legal basis is your given permission. When we ask you for example if we may send you a newsletter, you are asked for your permission to do so.
In some cases, however, we need to collect and save your personal data because this is required by law. For instance, when it is needed to process and store your data for tax liabilities.
2. California Consumer Privacy Act (CCPA) & California Online Privacy Protection Act (CalOPPA)
If you are a Californian resident, the California Consumer Privacy Act & California Online Privacy Protection Act (“These Laws”) are applicable to you. According to These Laws you have the right to be informed about the categories of personal information we collect about you and the purposes for which we use the categories of information. Please have a look at section 3 of this Privacy Policy to have a clear overview on what we do.
Furthermore, under These Laws you have the right to request access to or deletion of personal information. You can contact us via email to execute such rights.
And to conclude, we will not discriminate anyone for exercising your rights under These Laws.
3. Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you. These different types of data consist of personal data, usage data and tracking and cookies data. We have shortly explained where the different types of data exist of.
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personal identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- IP-address
- Internet browser and device type
- Bank information
Most of the times we need this information to comply with the agreements ensuing from the Terms of Use or other agreements we made.
Usage Data
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We simply need this information to improve the Service.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
For a more detailed description of how we use cookies, please have a look at our cookie policy.
If not mentioned already, Tumella will use the Personal Data for the following purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
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To detect, prevent and address technical issues
4. Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the Netherlands and choose to provide information to us, please note that we transfer the data, including Personal Data, to the Netherlands and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Tumella will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
One of the ways we can realize this is to close ‘processor agreements’ with the relevant parties, so we are sure they handle your data with the same care as we do.
5. Security of Data
The security of your data is important to us. Therefore, we took the necessary steps to make sure your Personal Data is safe and will be protected against losses and/or leaks of this information. Nevertheless, we have to inform you that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
6. How long does Tumella keep your information?
We will store your personal data as long as is necessary for the purposes named in this Privacy Policy. This is for example the case to provide and maintain our Services. Obviously, we need your account information otherwise we simply don’t know who you are. We also need to keep this data to make sure you can log in every time you want.
If you are not logged in to your account for five (5) years we will delete your data or anonymize it in case, we still need the data to meet for example our legal obligations.
In some cases, we also need to keep your data because this is required by law. For personal data that is related to taxes for example, we have to keep your data for a minimum seven (7) years. Also, in this case, we will delete your data, or anonymize it in case we still need the data to meet for example our legal obligations.
7. Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service. A third-party Service Provider is for example Google Analytics.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
8. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
9. Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
10. Changes to This Privacy Policy
This Privacy Policy will change from time to time if new developments give reason to do so. The most accurate privacy policy can be found on our website. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. You will always see the last date of change on top of the Privacy Policy.
- What are your legal rights with regards to Tumella processing your data?
You have the right to an understandable and transparent explanation of how we handle your personal information and what rights you can exercise in that regard. We have therefore extensively explained in this privacy policy which data we collect from you and how we handle your data. However, this is not everything. Probably the most important part we have not told you yet. You have a couple of rights related to your personal data. Please find all your rights written below.
Right to view
You have the right to request us to show, at any time, which information we have about you.
Right to rectify
You have the right to have your personal information corrected if this information is incorrect or outdated or not complete.
Right to object
You have the right to object to the processing of your personal information, if you do not agree with the way in which we process your personal data.
Right to data portability
You have the right to request us to provide you with the data that you have provided to us in a machine-readable format, so that you can store this data in a database of you or another party.
Right to limit how to process your personal information
You have the right to request a restriction on the processing of your data. This means that we can save your personal information, but we cannot use it. This right exists in a number of cases. If you think this is the case, you can contact us.
Right to be forgotten
You have the right to ask us to remove all personal information that we have from you. When you submit a request to delete your personal information, we will delete information that is traceable to you, except for the information that we must or may retain based on the law.
Right to make a complaint
You have the right to make a complaint about the way we handle your data. If you have a complaint, we prefer to resolve it with you personally. For this, you can contact us by email: privacy@tumella.com. Also, you have the right to submit your complaint to the Dutch Data Protection Authority.
12. Contact Us
With this Privacy Policy we gave you an impression of how we take care of your Personal Data. If you have any questions about this Privacy Policy, or if you have suggestions about the way we can improve it in some way, please feel free to contact us. We are happy to hear from you. You can contact us:
- By email: support@tumella.com
- By visiting this page on our website: tumella.com