Tassl Privacy Policy

This Privacy Policy is effective January 1st, 2019.

1. Who We Are

Tassl Services:

Tassl is an engagement management company that helps networks connect engagement opportunities like events, groups, programs and initiatives, to their constituents. Our network constituent related services are available through Tassl Mobile App and Tassl Web Registration Pages and IFrames. For network administrators, Tassl offers a cloud-based back-end management and analytics platform, Tassl Connect Admin, to more easily manage participation and better understand the impact and reach of their initiatives within their constituent base. Tassl's products and features are available (a) online through various Tassl LLC properties including without limitation, Tassl, Tassl App, Tassl Connect Admin Hub, Tassl Connect Leader Hub, Tassl Connect Group Hub, Tassl IFrame Widgets and (b) through Tassl mobile app, webpages, application programming interfaces, and subdomains ("Applications".) (a) and (b) are collectively referred to as "Tassl Services".

Who's Who:

When this Privacy Policy users the term "Administrators" we mean the network staff administrators, group, and/or volunteer administrators who utilizes our Services to create engagement opportunities for consumers using our Services (a) to consumer information about or register for network initiatives or (b) for any other reason. Consumers and third parties using our Services are all referred to in these Terms collectively as "Users", "you" or "your".

Tassl LLC is a a Delaware Limited Liability Company with its principal place of business at 1608 Walnut Street, Floor 12, Philadelphia, PA. ("Tassl,""us," "we" or "our"). If you are resident in the EEA or Switzerland, Tassl LLC is the responsible party with respect to Personal Data (defined below) collected through the Services.

If you have any questions or concerns at any time, please do not hesitate to contact us at the address above or by contacting us at privacy@tassl.com.

2. Privacy Statement

Application:

This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person ("Personal Data") that is collected from Users on or through the Services. We take the privacy of your Personal Data seriously. Because of that, we have created this Privacy Policy. Please read this Privacy Policy as it includes important information regarding your Personal Data and other information.

"Non-Personal Data" as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.

3. Personal Data That We Collect

When you use or interact with us through the Services, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of an Organizer using our Services to manage their engagement programs and initiatives. This is an important distinction for EU data protection law purposes and is explained in more detail in below.

All Users:

Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and other information that enables Users to be personally identified.

Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services ("Automatic Data"). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar technologies. You can find out more information about how we use Cookies and other similar tracking technologies in our Cookie Statement.

When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.

Administrators:

As an Administrator we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of the Network granting your administrative access.

Consumers:

As a Consumer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of an Administrator.

Information you provide via Tassl or Applications: :

If you register for a paid engagement opportunity you will provide financial information (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data. In addition, Administrators can set up engagement opportunity registration pages to collect virtually any information from Consumers in connection with registration for an Administrator's engagement opportunity listed on the Services. Tassl does not control an Organizer's registration process nor the Personal Data that they collect. Personal Data collected on behalf of Administrators is provided to the Administrators of the applicable engagement opportunity in accordance with "How We Disclose and Transfer Your Personal Data: Organizers" below. Information we obtain from other sources: We may also collect or receive Personal Data from third party sources, such as Administrators, other Consumers, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.

4. Use of Your Personal Data

We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows:

  • Specific Reason: If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
  • Access and Use: If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
  • Internal Business Purposes: We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.
  • Tassl Communications: Where it is in accordance with your marketing preferences, we may use your Personal Data to contact you in the future regarding product updates, including without limitation, to inform you about services or opportunities we believe might be of interest to you. You can "opt out" from our electronic email communications at any time.
  • Administrator Emails: If you registered for an event on the Services, your email address is available to that Administrator. However, Administrators may also import the email addresses they have from external sources and send communications through the Services to those email addresses, and we will deliver those communications to those email addresses on the Administrator's behalf. The Administrator and not Tassl is responsible for sending these emails.
  • Other Purposes: If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.
  • Aggregated Personal Data: As a service to your Adminstrators, we aggregate personal data to help Administrators to understand and serve Users better. We analytics on customer demographics, interests and behavior based on Personal Data and other information that we have collected. This analysis is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.
5. Disclose And Transfer Your Personal Data

No Sale:

We will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.

Administrators:

If you are a constituent or registrant of an Administrator, your Personal Data will be available to that Administrator's Organization. That Organization can share your Personal Data with their authorized Third Parties. It is important that you review the applicable policies of the Administrators, and if applicable and available, their appointed Third Parties.

Service Providers:

We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of Tassl to perform certain business-related functions. These companies include our database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.

Facebook and Other Third Party Connections:

You can connect your Tassl App account to your accounts on third party services like Facebook, in which case we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy. For example, if you connect with Facebook, we store your Facebook id, first name, last name, email, location, and profile picture and use them to connect with your Facebook account to provide certain functionality on the Services.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Tassl (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.

6. Storing Personal Data

We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

7. How you can Access, Update, Correct or Delete Your Personal Data

You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.

If you are a mobile User, you can exercise these rights by logging in and visiting your mobile profile and settings. Both registered and unregistered Users may also exercise these rights by contacting us directly by email or at the address specified below.

If a Consumer initiates a data deletion request, Tassl is authorized to delete or anonymize Personal Data of the requesting Consumer from the Services even if that means removing its availability to the Administrators through the Services. However, if you are a Consumer, you understand that even if Tassl deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the Administrator's own databases if transmitted to the Organizer prior to Tassl receiving or taking action on any deletion or anonymization activity.

We will consider and respond to all requests in accordance with applicable law.

8. How Long We Retain Your Personal Data

We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

9. Cookies and Browser Data

We may gather end-users' server, IP address and browser-type related information ("Browser Data") as part of the general administration and analytics in our Services. The Browser Data may be comprised of the demographic, usage and/or other characteristics of our end-users as a group without any associated personally identifiable information of end-users. When a Consumer or Administrator visits our Services, we may send a cookie and/or gif file ("Cookie") to assign an anonymous, unique identifier to the applicable end-user's Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. We do not use cookies to track your use of the Internet in any other way or to store any personally identifiable information, and we do not disclose cookie information to third parties (other than as required by legal process).

10. Your Choices

You have several choices available when it comes to your Personal Data:

Limit the Personal Data You Provide:

You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services. For instance, in order to register as an Consumer, your name and email address will be required by the Administrator.

Change your Mobile App Profile Setting to Private:

You can change your mobile app setting to "Private" in order to hide your engagement participation in your network mobile feeds. Your network participation will however still be visible to Administrators and verified connections in Tassl App.

Opt Out from Electronic Communications:

(a) Transactional or Responsive Communications

Certain electronic communications from Tassl are responsive to your requests. For instance, if you are a Consumer, we must email you your registration confirmation on behalf of the Administrator when you register through a Tassl Service. As a further example, if you email our customer support department, we will return your email. Notwithstanding any unsubscribe election that you have made, you will still receive these transactional or responsive emails. You can stop receiving these types of emails only by contacting us. By electing to stop receiving all electronic communications from us or through our system you will no longer receive any updates on engagement opportunities you are registered for(including confirmation emails). We do not recommend that you do this unless you plan to no longer use the Services, are not currently registered for an opportunities, are not currently an administrator and will have no need to receive further communications from us or through our system.

(b) Retention

It may take up to forty-eight (48) hours for us to process an unsubscribe request. Even after you opt out of all electronic communications, we will retain your Personal Data in accordance with this Privacy Policy, however, we will no longer use it to contact you. However, Organizers who have received your Personal Data in accordance with this Privacy Policy may still use that Personal Data to contact you in accordance with their own privacy policies, but they may not use our system to do so.

Do Not Track

We currently do not participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.

11. Exclusions

Personal Data Provided to Others.

This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means, including to Administrators or contact information shared when connecting with other users in the mobile app.

Third Party Links:

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

12. Children - Children's Online Privacy Protection Act

We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us and we will endeavor to delete that information from our databases

13. International Privacy Laws

If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

14. Changes To This Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, "Modifications"). Modifications to this Privacy Policy will be posted to the Site with a change to the "Updated" date at the top of this Privacy Policy. In certain circumstances Eventbrite may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications. Modifications will be effective thirty (30) days following the "Updated" date or such other date as communicated in any other notice to you.Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services/

In some cases, Tassl may choose to buy or sell assets. In these types of transactions (such as a sale, merger, liquidation, receivership or transfer of all or substantially all of Tassl’s assets), member information is typically one of the business assets that is transferred. In the event that Tassl transfers information about you, Tassl will notify you by email or by putting a prominent notice on the Site and the Apps, and you will be afforded an opportunity to close your account before information about you becomes subject to a different privacy policy.