Commitment to Privacy
Protecting your information is of the utmost importance to us, as is maintaining compliance with any governing authority to which the processing of personal information may occur for any of our services. The European Union ("EU") maintains strict privacy laws through General Data Privacy Regulation ("GDPR"). This standard differs significantly from Canadian or U.S. law. We comply with regulations where it applies to the processing of personal data, the disclosure of the appropriate notifications, and, where applicable, with provision of a process by which you can request the erasure of your personal information.
What Information Do We Collect?
We collect personally identifiable information when you complete a Client or Publisher Application, or otherwise choose to provide personally identifiable information to us. We may also collect personally identifiable information when phone call(s) made by you or any consumer that are routed through Tulara to a Client of Tulara’s are recorded. Personally identifiable information is any information that can be used to identify or locate a particular person or entity.
How we use the information we collect depends in part on the manner in which such personally identifiable information is disclosed to us, which services of the Network you use, how you use them, and/or any preferences you have communicated to us. Below are specific purposes for which we use the information we collect:
To provide the Network services and personalize your experience.
We use information about you to provide the Network services to you, including to authenticate you when you log in, process payments to or from you, provide customer support, and operate and maintain the Network. For example, we use the name and account details you provide us to identify you to your Account.
To communicate with you about your Account.
We may send you information regarding your Account and the Network, including the status of your Account or billing.
To promote new Campaigns.
If you have a Publisher Account, we use your contact information and information about how you use the Network to send communications via e-mail about Campaigns that may be of specific interest to you. For Client or Publisher Accounts, we may also send e-mail communications with information about new features, survey requests, newsletter, or events we think may be of interest to you.
You agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your Account on the Network. If you wish to opt out of e-mail newsletters, you may do so by clicking on the unsubscribe links located at the bottom of such emails. In addition, you may request to have your personal information removed from our Network by e-mailing firstname.lastname@example.org.
We use your information to respond to your requests for assistance and general correspondence, and to resolve technical issues, if any, you may encounter.
You also agree that we may contact you at any time, via e-mail or other means with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Tulara Network.
By registering on the Site, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the "Rule") and applicable state do-not-call regulations. In addition, where you provide "prior express written consent" within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time ("TCPA"), you consent to receive telephone calls, including artificial voice and pre-recorded messages and/or calls delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to receive access to the Tulara Network, and your consent simply allows Tulara to contact you via these means. Notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, Tulara retains the right to contact you via telemarketing (where you supply your telephone number to us) in accordance with the TCPA, Rule and applicable state do-not-call regulations as set forth in this paragraph.
For quality assurance purposes.
Phone calls that we route to a Client of ours may be recorded for quality assurance purposes only. We take steps to protect such information from inadvertent disclosure, do not sell such information to third parties, and only retain such information for so long as is necessary to validate the phone calls. In those jurisdictions where consent is required for a party to record a telephone call, you consent to us recording such calls.
For safety and security.
We use information about you and your use of the Network to verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Network policies and Terms and Conditions.
To protect our legitimate business interests and legal rights.
Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent.
We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer or client stories to promote the Network, with your permission.
Legal basis for processing (for EEA users).
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Network services you use and how you use them. This means we collect and use your information only where:
We need it to provide you the Network services, including to operate the Network, provide customer support and personalized features, and to protect the safety and security of the Network;
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Network and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Network.
Portal Used in Connection with Your Account.
When you register for an Account on the Network, we use a password-protected third party portal to store your personal information, and we may share your personal information with such third party ("Third Party Agent") as is necessary for the performance of your Account and the Network.
As a general rule, and other than in connection with the limited exceptions set forth below, we will not sell, share or rent your personally identifiable information to or with others, except in limited circumstance where we have your express consent. Notwithstanding the foregoing, we may, from time to time, provide such information to certain third-party administrative vendors for efficiency purposes in providing administrative or program management services, or to serve emails on our behalf, in connection with your Account. Any third-party vendor so used has agreed to protect the confidentiality of information provided by us.
Non-Personally Identifiable Information.
We may collect certain non-personally identifiable information about you when you visit certain pages of this Site and/or register for an Account on the Network, such as the type of browser you are using (e.g., Chrome, Internet Explorer), the type of operating system you are using, (e.g., Windows 10 or Mac OS) and the domain name of your Internet service provider (e.g., America Online, Earthlink), and share such information with our Third Party Agent. We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage.
Cookies and Web Beacons.
To enhance your experience with the Site, we use "cookies." You cannot log into the Network without agreeing to accept the cookies that we use with the Site.
We may additionally collect information using Web beacons, which are commonly referred to in the industry as web bugs, pixel tags or Clear GIFs. Web beacons are electronic images that may be used on the Site, in your Account, or in our emails to deliver cookies, count visits and determine if an email has been opened and acted upon.
Aggregate cookie and tracking information may be shared with third parties. For example, we may share information from cookies on this Site with Facebook, where ads related to your visit to our Site may then be shown if you later visit Facebook. To disable and reject certain cookies, follow the instructions associated with your Internet browser. To adjust your account settings in Facebook to control how ads are displayed there, visit https://www.facebook.com/help/568137493302217?helpref=faq_content.
International Transfer of Data.
Subject to any mandatory obligations to delete data, your information may be retained by us and in our Third Party Agent portal, server logs, databases and records indefinitely.
Third Party Links.
We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. We will never knowingly collect any personal information about individuals under eighteen (18) years of age. If we obtain actual knowledge that we have collected personal information about an individual under eighteen (18) years of age, that information will be immediately deleted from its database.
We endeavor to safeguard and protect our Account holders' information. When Account holders submit personally identifiable information to the Network, their personally identifiable information is protected both online and offline. When our registration process asks registrants to submit Sensitive Information, and when we transmit such Sensitive Information, that Sensitive Information is encrypted and protected with SSL encryption software. While we use SSL encryption to protect Sensitive Information online, we protect all other user information online and offline. The Third Party Agent servers that we utilize to store personally identifiable information in are kept in a secure physical environment. The Third Party Agent has security measures in place to protect the loss, misuse and alteration of personally identifiable information stored on its servers.
Please be advised that, although we take every reasonable precaution available to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot warrant that your information will be absolutely secure. Any transmission of data at or through our Site is at your own risk. However, access to your personally identifiable information is strictly limited, and not accessible to the public. Only employees, and Third Party Agents, that need the information to perform a specific job are granted access to personally identifiable information. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable provincial, federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personally identifiable information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
You acknowledge that you provide your personally identifiable information to us with knowledgeable consent and at your own risk.
Deleting and Updating Your Information.
If you would like to delete or update the personally identifiable information that we have collected from you, simply email us at: email@example.com.
We will process your request within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
Opting Out of Receiving E-mail.
You may at any time choose to stop receiving emails containing general information regarding Tulara by following the instructions at the end of each such email or by contacting us at firstname.lastname@example.org.
Should you be contacted by our Third Party Agent through email, you can follow the instructions at the end of each such email to stop receiving such emails. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Account, as well as to respond to any inquiry or request made by you.
Can You Access the Personal Information Acquired by Us?
Your personal information can be corrected or updated within your Account in the Network, or by contacting email@example.com.
For the deletion and erasure of personal information, email firstname.lastname@example.org to begin the process and we will respond to your request within 30 days.
Your California Privacy Rights
If you are a resident of the State of California and would like to know how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please contact us at: email@example.com.
200 - 775 Topaz Ave
Victoria, BC V8T 4Z7