Privacy Policy
Last updated: 4th January, 2024
Our Policy
This Privacy Policy (“Privacy Policy”) describes how tuulbox LLC and its subsidiaries and affiliates (collectively, “tuulbox,” “us,” “we,” or “our”) ,may collect, use, and share your personal information in connection with the websites we own and operate that link to this Privacy Policy (collectively, the “Site”) and our related services, events, social media pages, and email and other electronic communications (collectively, and together with the Site, the “Services”), and the choices you have with respect to your personal information. We may update this Privacy Policy from time to time. We will notify you of changes by posting the new Privacy Policy on this page and changing the “Last Updated” date at the top of this page. In some cases, such as where required by law, we may notify you about updates by sending you an email, posting a notice on the Site about the update, or using other reasonable means to contact you. In all cases, your continued use of the Services following posting of any changes constitutes your acceptance of such changes. We encourage you to review this Privacy Policy periodically for any updates.
Collection of Personal Information
The table below describes the categories of personal information (with non-exhaustive examples) that we may collect about you:
- Identifiers
- Contact information, such as first and last name, email address, phone number, and mailing address.
- Online identifiers, such as Internet Protocol (IP) address, device ID, and other identifiers.
- Commercial Information
- Financial and transaction information, such as payment amounts and debit or credit card number or financial account details used for payments. We work with a third party payment processor who handles debit or credit card payments on our behalf.
- Account information, such as your log-in details, information that you store in your account, and other details about your use of the Services.
- Order history, such as records of services you have purchased from us.
- Preferences, such as any preferences you set in your account and any marketing or communications preferences.
- Survey responses, such as the information you provide in response to our surveys and questionnaires.
- Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us.
- Internet or Network Activity
- Online activity information, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
- Professional Information
- Professional information, such as company name, job title, company location, and other details we may collect about your business or profession.
- Audio, Electronic, Visual, or Similar Information
- Customer service call or chat recordings, which we may record for training and quality assurance purposes.
- Inferences Drawn from Personal Information
- Profiles reflecting preferences, characteristics, predispositions, or behavior, such as the lead insights we create as part of our Services.
We may obtain personal information about you from a variety of sources, including the following sources.
Personal Information that You Provide. We collect the personal information that you provide to us, such as when you fill in forms on the Site, use the Services, register for an account, subscribe to our emails, or communicate with us.
Personal Information Collected Automatically. We, our service providers, and our advertising partners may automatically log information about you, your computer, or your mobile device, and your activity over time on our Services and on other sites and online services, such as the online identifiers, online activity information, and device information described in the table above. Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as.
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, remembering the items you place in your shopping cart, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Services, and remember your preferences.
- Session replay technologies, which are third-party software used to record a video replay of users’ interactions with the Services. The video replay may include a user’s clicks, mouse movements, scrolls, typing, and other activity taken during the session. We may use these replays for research and development purposes, such as to help us troubleshoot problems with the Site, understand how users interact with and use the Services, and identify areas for improvement.
Personal Information from Third Parties. We may also collect personal information from third parties, such as our customers and business partners, service providers, social media networks, advertising partners, publicly available sources, third-party platforms that our users connect to the Services, and companies that provide us with personal information to supplement what we already know about our contacts, customers, and clients or to help us identify new contacts, customers, or clients. For example, in order to provide our Services, we collect business contact information from publicly available online sources such as business websites, public “yellow pages,” blogs, social media sites, search engine results, and other locations. We may merge or combine such personal information with the other types of personal information we collect about you, including to supplement or update our records, to improve and provide our Services, and for the other purposes described in this Privacy Policy.
Referrals. Users of the Services may have the opportunity to refer colleagues, friends, or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
Use of Personal Information
We may use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.
To Provide Our Products and Services. We use personal information to provide our products and services. For example, we use personal information to:
- provide and operate the Services and our business;
- enrich, improve, and supplement our lead generation databases;
- create, manage, monitor, and maintain your account on the Services;
- provide you with the products and services you request;
- monitor and improve your experience on the Site;
- review and respond to your inquiries and requests;
- send you updates about your order and store your information for future orders;
- contact you by phone, email, or other form of communication; and
- process your transactions and monitor your orders.
Research and Development. We use personal information for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purpose.
Direct Marketing. We may send you tuulbox-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices” section below.
Interest-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above in the section called “Personal Information Collected Automatically”) over time across our Services and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.
To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Services and our products and services, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
Transfer of Personal Information
tuulbox is headquartered in the United States and we have service providers in the United States and other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service. Users in Europe can view more information about cross-border transfers in the section below titled “Notice to European Users".
Security
The security of your personal information is important to us, but remember 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 information, we cannot guarantee its absolute security.
Your Choices
In this section, we describe the rights and choices available to individuals. California residents should review the section below titled “Your California Privacy Rights” for additional information specific to Access, Modify, or Delete Your Account Information. You may access, modify, or remove certain information saved in your account by logging into your account and updating or correcting your profile information. You may also submit a request by emailing us at [email protected]. Opt-Out of Promotional Email Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us using the contact information at the bottom of this Privacy Policy. You may continue to receive service-related and other non-marketing emails. Opt-Out of Text Messages. We may offer communications via SMS texts or similar technology sent by tuulbox or our service providers, such as when we send you text messages for customer service, account-related, or marketing purposes. Message and data rates may apply for these services. You can opt-out of texts by following the instructions for the applicable texting program you enroll in or by emailing us your request and mobile telephone number to [email protected]. Third Party Platforms. If you connect the Services with a third party service, application, or other platform, you may have the ability to limit the information that we obtain from the third party through your account settings with the third party platform. Please note, if you withdraw our ability to access certain information from a third party platform, that choice will not apply to information that we have already received from that third party. Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. Analytics. The Site uses Google Analytics to help us analyze how the Site is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here . To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here . Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms, such as Facebook and Google. You can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here. You can learn more about Facebook’s privacy practices and manage your Facebook ad preferences by clicking here. Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you. Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Declining to Provide Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
Children
The Services are not intended for use by anyone under the age of 16, and we do not knowingly collect personal information from children. If you are a parent or guardian and you are aware that your child has provided us with personal information online, please contact us. If we become aware that we have collected personal information from children without verification of parental consent as required by law, we take steps to remove that information from our servers.
Links to Other Websites and Services
The Services may contain links to other websites and online services that are not operated by us. These links are not an endorsement of, or representation that we are affiliated with, any third party. If you click on a third party link, you will be directed to that third party’s site or service. In addition, our content may be included on web pages or online services that are not associated with us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to review the privacy policies of other websites and other online services that you visit or use.
Notice To California Residents: Your California Privacy Rights
This section applies only to California residents. It describes how we collect, use, and share personal information of California residents when we act as a “business” as defined under the California Consumer Privacy Act (“CCPA”), and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given under the CCPA but does not include information exempted from the scope of such law. In some cases we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section. Personal Information That We Collected and Purposes of Collection and Use. We describe:
- the categories of personal information we collect, or may have collected about you in the preceding 12 months from the “Last Updated” date of this Privacy Policy, and the categories of sources from which we collect such personal information, in the section above called “COLLECTION OF PERSONAL INFORMATION;” and
- the purposes, including the specific business and commercial purposes, for which we collect and use these categories of personal information in the section above called “USE OF PERSONAL INFORMATION.”
- To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Services, detect security incidents and prevent fraud, and to verify and maintain the quality of the Services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents. Personal Information Disclosed for a Business Purpose, “Sold,” or “Shared.” Each of the categories of personal information listed above may been disclosed for business purposes in the preceding 12 months to any of the third parties set forth in this Privacy Policy under the section titled “SHARING OF PERSONAL INFORMATION.” tuulbox has disclosed each of the categories listed in the section above titled “COLLECTION OF PERSONAL INFORMATION” for the business purposes set forth in this Privacy Policy to any of the third parties described under the section titled “SHARING OF PERSONAL INFORMATION.”
- The CCPA defines a “sale” of personal information to mean when a business discloses a California resident’s personal information to a third party for monetary or other valuable consideration. Where a business discloses personal information for purposes of cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA.
- In the 12 months preceding the “Last Updated” date of this Privacy Policy, tuulbox has “sold” or “shared” Identifiers and Internet or Network Activity to our Advertising Partners for purposes of advertising our Services (including tracking the success of our advertising campaigns) and measuring activity on the Services. During the same period, we have “sold” or “shared” Identifiers and Professional Information to our Customers and Business Partners as part of the products and services that we offer. We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.
- Retention of Personal Information. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Your California Privacy Rights. The CCPA provides California residents with the rights listed below. Please note, these rights are not absolute and in some cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity
- Right to Know/Access. You have the right to request that tuulbox disclose certain information to you about our collection and use of your personal information, including:
- The categories of personal information we collected about you.
- The categories of sources of the personal information we collected about you.
- Our business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- Right to Erase/Delete. You have the right to request that tuulbox delete any of your personal information that we have collected from you.
- Right to Correct. You can ask us to correct inaccurate personal information that we have collected from you.
- Right to Opt-Out of Sales or Sharing. If we “sell” or “share” your personal information according to California law, you can opt-out. In addition, if you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
- Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
How to Exercise Your California Privacy Rights. Requests to exercise your California privacy rights may be submitted using the methods below:
- Access/Know, Correction, or Deletion. You can request the access or deletion rights described above by:
- Emailing us at [email protected], or
- Sending us a request via mail at tuulbox LLC, PO Box 21772, Castro Valley, CA 94546
- Opt-Out of “Sales” or “Sharing.” You can opt-out of the “sale” or “sharing” of your personal information by:
- Emailing us at [email protected], or
- Clicking here: Do Not Sell or Share My Personal Information.
- Broadcasting the Global Privacy Control (GPC) signal when visiting our Site. The GPC signal will only apply to the “sale” or “sharing” of Identifiers and Internet or Network Activity via cookies and similar technologies on our Site. To opt-out of other “sales” or “sharing,” please use the methods listed above. Due to technological limitations, if you visit our Services from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the Site and rebroadcast the GPC signal.
When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You may also designate an authorized agent to make a request on your behalf. If you do so, we may require the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive. We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
Notice To European
The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is tuulbox LLC, PO Box 21772, Castro Valley, CA 94546 Legal Bases for Processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at [email protected]. The list below describes our legal basis for each processing purpose (as described above in the “USE OF PERSONAL INFORMATION” section):
- To Provide our Products and Services
- Processing is necessary to perform the contract governing our operation of the Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interests as further described in this Privacy Policy.
- Research and Development
- Processing is based on our legitimate interests in performing research and development as described in this Privacy Policy.
- Direct Marketing / Interest-Based Advertising
- Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or in the Services.
- Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
- To Comply with Laws and Regulations
- Processing is necessary to comply with our legal obligations.
- For Compliance, Fraud Prevention, and Safety
- Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property
- With Your Consent
- Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.
Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us at the contact information listed below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us using the information below for further information about any such transfers or the specific safeguards applied.
Contact Us
If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact us at [email protected] or write to us at the address below:
tuulbox LLC
Attn: Privacy Policy
PO Box 21772
Castro Valley, CA 94546