Effective Date: May 25, 2018.
- Introduction and Overview.
If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.
- Data Controller.
EU data protection law makes a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). Tempo Strategic may act as either a data controller or a data processor in respect of your personal data, depending on the circumstances. Tempo Strategic, located at the address in the section entitled “Contact Us” below, is the data controller with respect to information you provide through the Service.
- Information Collection.
- Information You Provide.
We collect information you provide directly via the Service, such as when you access our content or communicate with us. We may use Service Providers (defined below) to collect this information.
The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information we collect include the following:
- Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.
- We collect the content of messages you send to us, such as feedback and product reviews you write, or questions and information you provide to customer support.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
- Information Collected Automatically.
We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:
- Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the time of day you browse, your referring and exiting pages, and other similar information.
- Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, and other device identifiers.
We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:
- Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.
- Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.
- Information on Behalf of Our Clients.
For further information on your rights and choices regarding Client Data, see the section entitled “Your Rights and Choices” below.
- Information from Other Sources.
- Social networks when you reference our Service or grant permission to Tempo Strategic to access your data on one or more of these services.
- Partners with which we offer co-branded services or engage in joint marketing activities.
- Publicly-available sources such as open government databases or other data in the public domain.
For further information on Third Party Services, see the section entitled “Third Parties” below.
- Use of Information.
We use information about you for our legitimate interests, including to:
- Manage our Service.
- Perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service.
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Monitor and analyse trends, usage, and activities.
- Conduct research, including focus groups and surveys.
- Improve the Service or other Tempo Strategic websites, marketing efforts, products and services.
- Develop and send you direct marketing, including advertisements and communications about our and third party products, offers, promotions, rewards, events, and services.
We also use information about you with your consent, including to:
- Serve advertising tailored to your interests on our Service and Third Party Services.
- Fulfill any other purpose disclosed to you and with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
- Sharing of Information.
We share information about you as follows:
- Service Providers. We share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as payment processing, data analytics, marketing and promotional services, Promotions, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
- We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, and technical operations.
- We share your information with our clients in connection with us processing your information on their behalf. For example, we share your information with our clients in order to respond to your questions and comments, comply with your requests, market and advertise to you, and otherwise comply with applicable law.
- Business Partners. We may share your information with our business partners in connection with offering you co-branded services or engaging in joint marketing activities.
- Third Parties. We may share your information with third parties for purposes of facilitating your requests and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
- Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
- We may share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
- Third Parties.
- Third Party Services.
- Third Party Features.
- Liking and Sharing. We may embed a pixel or SDK on our Service that allows you to “like” or “share” content on your Tempo Strategic account through, Third Party Services, including social networks such as Facebook and Twitter. If you choose to engage with such a Third Party Service through our Service, we may collect any information you have authorized the Third Party Service to share with us (such as your user ID, public profile information, e-mail address, birthday, and other account and profile data). Likewise, if you choose to engage with such a Third Party Service through our Service or visit our Service while logged in to that Third Party Service on your device, the Third Party Service may receive information about your activities on our Service and be able to associate that information with information the Third Party Service already has about you.
- Analytics and Interest-Based Advertising.
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.
- Your Rights and Choices.
- Tracking Technology Choices.
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
- Analytics and Interest-Based Advertising.
You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit http://www.aboutads.info/choices for the website opt-out. In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI“). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or Tempo Strategic’s ongoing business relations. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions.
- Your California Privacy Rights.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
Tempo Strategic will not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Tempo Strategic is not required to respond to requests made by means other than through the provided e-mail address or mail address.
- Your European Privacy Rights.
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
Tempo Strategic acknowledges that you have rights in connection with Client Data. If your information has been processed by Tempo Strategic on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make your request directly to Tempo Strategic, please provide the name of the Tempo Strategic client on whose behalf Tempo Strategic processed your information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. Tempo Strategic does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Tempo Strategic has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.
- Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.
- International Transfer.
- Contact Us.
205 Lexington Avenue, 5th fl
New York, NY 10016