Updated: March 2019

Introduction

We are committed to protecting the privacy and security of the personal information we receive or collect from you. Our company values transparency and trust; accordingly we are committed to informing you about how we treat your personal information.

Tell Analytics (also referred to as “we,” “us,” and “our”) has established this Privacy Policy (this “Policy”), together with our Terms of Service, and any documents referenced therein, to provide you with clear and concise information regarding the nature of information collected on www.tellanalytics.com (the “Website”), and the ways in which we use and share this information. This Policy also describes certain rights and options that you have with regard to your personal information. This Policy does not apply to information you may provide to us offline or through means other than through our Website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITE.

Who is Responsible for your Personal Information?

Tell Analytics is responsible for implementing the applicable data protection principles and for safeguarding the personal information you provide to us through our Website. If you are a user in the European Union (the “EU”) or European Economic Area (“EEA”), for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), Tell Analytics acts as data controller for the personal information we collect from you via our Website.

What Information Do We Collect?

We may collect and process the following personal information from you for the purposes set forth below:

Category	Type of Data and Purpose
Contact Information	When you visit our Website or request our services, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.
Business Information	When you seek services from us in the course of contractual or customer relationships between you, your organization, and us, we collect business contact information and other personal information in order to provide you with the services you have requested.
Location Information	When you use our Website, we may collect information about your use of our Website, your interaction with advertising and analytics services, to serve you content, and to protect the Website and services. Location information collected may include your Internet Protocol (IP) address or unique device identifier.
Cookies	When you visit our Website, we may collect cookies and use similar technologies to, among other things, provide you with a more personal and interactive experience on our Website, to improve our marketing efforts, and for Website usage analytics (e.g., page response times, download errors, length of visit, webpages visited, etc.). If you choose to disable cookies and similar technologies, some areas and features of the Website may not work properly.
Automated Information	When you visit our Website, we automatically collect information from your browser or your mobile device, which may include your Internet Protocol (IP) address or unique device identifier, cookies and data about which pages you visit in order to allow to operate and provide the Website and our services. This information is used to maintain and improve the security of our Website and services, to analyze and improve the quality of our Website and services, to understand how you interact with the Website, and to provide you with advertising and a more personalized experience.
Email Interconnectivity	If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message, click on any links or banners it contains and make purchases. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the number was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.
Feedback / Support / Inquiries	If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, email address, other contact information and other information needed to respond to your feedback, provide the requested support, or to answer your question.
Mailing List	When you sign up for one of our mailing lists, we collect your contact information, including your email address.
Employment	If you apply for a job, or become an employee, we collect personal information necessary to process your application or employment. This may include, among other things, your contact information, your social security number, employment history, etc.

How Do We Use Your Personal Information?

Tell Analytics collects and uses the types of personal information listed above in an effort to improve your experience on the Website and our provision of services to you. We may also use personal information to help target specific offers to you. Additionally, we may use your personal information in the following ways:

• To provide you with the services and products you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary in the service of our business relationship with you;
• To present and improve the Website’s content and functionality;
• To respond to visitor, subscriber, and customer inquiries;
• To determine user interests, needs, and preferences;
• To provide notice of changes to our Website or the services and products we offer or provide through them;
• To deliver services to you and honor our contract with you, including our Terms of Service, but not limited to, providing you with access to digital publications and content;
• To conduct research and analysis; To develop new products and services;
• To manage and maintain the security of our Website and services;
• To market our services and products to you. We will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose.
• To comply with our legal and compliance obligations, including maintaining records, performing compliance audits, etc.
• For insurance purposes;
• To exercise and defend our legal rights, or to comply with court orders;
• For any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your personal information was provided to us;
• In any other way we may describe when you provide the information; and For any other purpose to which you have consented or for which we have a legal basis under law.

We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:

• Because it is necessary to perform the services you have requested, to comply with your instructions or other contractual obligations between you and Tell Analytics;
• To comply with our legal obligations as well as to keep records of our compliance processes;
• Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
• Because you have chosen to publish or display your personal information on a public area of the Website, such as a comment area;
• Because it is necessary to protect your vital interests;
• Because it is necessary in the public interest; or
• Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above. We rely on your express opt-in consent to (1) send marketing communications; (2) for third-party data-sharing relating to advertising; and (3) for the use of cookies and similar technologies.

Sharing and Disclosure of Your Personal Information

We may share your personal information in the following contexts:

Category	Disclosure Contextse
Subsidiaries and Acquisitions	We may share your personal information with our corporate subsidiaries and affiliates. In addition, we may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred. For example, if another company acquires Tell Analytics, we will share your personal information with that company.
Disclosures With Your Consent	We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.
Disclosures Without Your Consent	We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our Terms of Service.
Directories	You may consent through account registrations to having your contact information shared with other account holders.
Third Parties	Tell Analytics may provide personal information about you to third parties that offer products and services specifically requested by you.
Service Providers	We may share your personal information with our service providers. Among other things, service providers may help us to administer the Website, support our provision of services requested by you, provide technical support, send marketing, promotions and communications to you about our services, payment processing and other legitimate purposes permitted by law.
Aggregated Data	We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development.

How Long Do We Store Your Personal Information?

Tell Analytics will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as long as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, provide our services, and enforce our agreements.

When we no longer have a purpose to retain your personal information, we will securely destroy your personal information in accordance with applicable law and our policies. We take reasonable steps to delete the personal information we collect if your registration to use our Website lapses and you opt out of receiving further communications from us, or if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.

Choices

If you no longer wish to receive communications from us via email, you may opt-out by contacting us at privacy@tellanalytics.com and provide the name of the service for which information was provided, your full name, mailing address, phone number and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Security

Tell Analytics has put in place reasonable and appropriate security measures to protect the personal information that you share with us from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed. While our security measures seek to protect your personal information in our possession, no security system is perfect and Tell Analytics cannot promise that your personal information will remain absolutely secure in all circumstances.

The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Website, you are responsible for keeping the password confidential. Do not share your password with anyone. If a security breach causes an unauthorized intrusion into our Website or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law.

Updating Your Personal Information

If any of the personal information you have provided to us changes, please let us know. For instance, if your email changes, you wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you, use our Contact Us details provided at the end of this Policy to update your information. You may also edit your account details if you have a user account through our Website. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Your Rights To Access And Control Your Personal Information

Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit or delete your personal information or you no longer want to receive any email, postal mail, or telephone contact from us or our affiliates in the future, such requests may be submitted via the Contact Us details at the end of this Policy.

Right of Access. If required by law (e.g., under the GDPR), upon request, we will grant reasonable access to the personal information that we hold about you.

Accuracy. Our goal is to keep your personal information accurate, current and complete. Please contact us if you believe your information is not accurate or changes.

Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us, and we will let you know if we are able to agree to your request.

Right to Erasure and Deletion of Your Personal Information. You may have a legal right (for instance, if you are located in the EU or EEA under the GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the Contact Us section of this Policy. We may decide to delete your personal information if we believe it is incomplete, inaccurate or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases and our Website, but it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Withdraw Consent. If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent. To withdraw your consent, please notify us using the information in the Contact Us section of this Policy and you may follow opt-out links on any marketing communications sent to you. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Right to Complain. If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement authority, or seek a remedy through the courts. You may also lodge a complaint with us by contacting us using the information provided in the Contact Us section of this Policy.

Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. It is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on our Website or on third-party websites or online services where we may collect information.

California Residents. California residents may be entitled under California Civil Code Section 1798.83 to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Us” section of this Policy.

European Union or European Economic Area Residents. If you are located in the EU or EEA and believe we have not processed your personal information in accordance with applicable provisions of the EU GDPR, you may lodge a complaint with your local data protection or supervisory authority.

Cross Border Transfers of Personal Information

Tell Analytics is located and established in the United States and, therefore, your personal information may be transferred to, stored or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using our Website or requesting services from us, you understand and consent to the collection, storage, processing and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.

Residents of the EU / EEA. When storing, hosting, or otherwise processing your information (including personal data), we may send such data outside of the European Union (EU) and the European Economic Area (EEA). When we transfer information to the United States or other countries, we do so for the purposes set forth in this Privacy Policy and in accordance with applicable law. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU and EEA, such as your express informed consent to do so (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between us and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.

Links To Other Sites

This Website may contain links to, and media and other content from, third party websites. These links are to external websites and third parties with which we have no relationship. Because of the dynamic media capabilities of the Website, it may not be clear to you which links are to the Website and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Website to the external third-party website. You can check the URL to confirm that you have left this Website.

Tell Analytics cannot and does not (i) guarantee the adequacy of the privacy and security, practice employed by or the content and media provided by any third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Website.

Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

Children

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the internet. Our Website and the services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Website, or provide any information to or on the Website. If you are under 18, please do not use or provide any information on the Website. If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information, and delete it.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

Changes to our Privacy Policy

We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Privacy Policy change, we will post all changes we make to this Policy on this page. if we make material changes to how we treat your personal information, we will also notify you through a notice posted prominently on the home page of our website for a reasonable period of time. The date this Policy was last revised is identified at the top of this Policy.

Contacting Us

For more information, or if you have questions or concerns regarding Tell Analytics’ Privacy Policy, wish to access personal information we hold about you; believe the personal information we have about you is incorrect, or wish to lodge a complaint with us about how we have handled your personal information, you may email us at privacy@tellanalytics.com or you can send correspondence to the following address, and we will do our best to assist you:

Attn: Legal Department
Tell Analytics
149 Locust Street
Burlington, VT 05401
Email: privacy@tellanalytics.com