Tangled Tales ONLINE PRIVACY POLICY

Tangled Tales LLC (“Tangled Tales”) respects your privacy as a visitor to its website and has developed the following privacy policy (“Privacy Policy”) to inform you about how Tangled Tales handles your personal information after receiving it. This Privacy Policy governs Tangled Tales’ use of your information both on the Tangled Tales Website (http://www.tangledtalesllc.com) and internally.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Tangled Tales’ website is not intended for children and we do not knowingly collect data relating to children.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@tangledtalesllc.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.

Controller

Tangled Tales is the controller and responsible for your personal information (“Tangled Tales, “we”, “us” or “our” in this privacy policy). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out in Section 16 below. You have the right to make a complaint at any time to EU supervisory authorities for data protection issues (https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en). We would, however, appreciate the chance to deal with your concerns before you approach such authorities. We ask that you contact us in the first instance.

Types of Information Collected and Stored Personal Information Summary.

When you engage in activities such as sign up to receive a Tangled Tales publication, shop on our website, or otherwise use the Tangled Tales website, Tangled Tales may gather your personally identifiable information (“Personal Information”). Your Personal Information may include, but is not limited to, your name, address, phone number, email address, birthdate, electronic signature, personal identification numbers, IP addresses, mobile device identifiers, geo-location, or any other personally identifying data collected from you by Tangled Tales or its authorized agents. By using the Tangled Tales Website, you agree to allow Tangled Tales and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.

Specific Data Collected.

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data. When you use the Tangled Tales website to shop in Tangled Tales’ online store, make donations to Tangled Tales or otherwise make payments to Tangled Tales, Tangled Tales utilizes third-party payment processors as its agents (“Payment Agents”) to process your payment and provide payment verification to Tangled Tales concerning your payment. Tangled Tales and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information. Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant. As a result, Tangled Tales does not collect or store your credit card numbers or other similar financially-related Personal Information and it isn’t exposed more than necessary. For more information about PCI DSS please visit https://www.pcisecuritystandards.org/about_us/.

Transaction Data includes details about contributions, purchases, and payments to and from you and other details of Tangled Tales products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your Tangled Tales purchases or orders made by you, your interests, preferences, feedback, and survey responses.

Usage Data includes information about how you use the Tangled Tales website, products, and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data / Analytics Information. We also collect, use, and share Aggregated Data. In an effort to improve visitors’ experiences on the Tangled Tales Website, Tangled Tales gathers this Aggregated Data related to individuals’ website visits. This information is used solely to measure and improve our Website and services and to better serve our members and customers. Tangled Tales uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following: Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.

Non-personal information, such as language, zip code, area code, location, and the time zone. Tangled Tales Website visit information, such as the domain from which you came to our Website or referring links, and details of how you use our Website, including but not limited to what webpages you visit on the Tangled Tales Website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.

Sensitive Information. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

Cookies and Browser “Do Not Track” Notice

Tangled Tales may use cookies on your computer. A cookie is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Third parties that advertise on the Tangled Tales Website do not have access to Tangled Tales cookies, but they may use their own cookies on your computer. Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies. Tangled Tales does not correlate its use of cookies with your Personal Information.

Tangled Tales does not respond to browser Do Not Track (“DNT”) Signals. The Tangled Tales Website may utilize page tags or web beacons to track information related to user visits as a part of Tangled Tales data analytics processes and user experience customization as described below. Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website. Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website. Such technologies enable us to improve and customize user experiences while users visit our website. Tangled Tales does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.

Tangled Tales may employ third party data analytics firms to track and analyze traffic on the Tangled Tales website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking. Tangled Tales’s third party analytics firms, as described in this section, do not receive your Personal Information.

Third parties that may advertise on Tangled Tales Websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Tangled Tales Website. Such information may contain a visitor’s IP address. Third parties may not collect identifying Personal Information from the Tangled Tales Website unless you provide it to such third parties. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Keeping Information Updated

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Security of Personal Information

Tangled Tales takes the security of your Personal Information very seriously. When your Personal Information is stored by Tangled Tales, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction. Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure. While Tangled Tales will use all reasonable means to protect your Personal Information, Tangled Tales cannot guarantee the security of your transmissions of such Personal Information, and you use the Tangled Tales Website at your own risk. If you suspect your Personal Information has been compromised, please notify Tangled Tales Customer Service as specified in Section 16 below.

How we Collect Your Personal Information.

We use different methods to collect data from and about you including through the following methods.

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our Website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Technical Data from the following parties: analytics providers such as Google based outside the EU; advertising networks based inside OR outside the EU; and search information providers based inside OR outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU. Identity and Contact Data from data brokers or aggregators based inside OR outside the EU and from other publicly available sources.

How Tangled Tales Uses and Shares Your Information

General Information and Your Rights. Tangled Tales limits its use of your Personal Information to the stated purposes for which such information is collected. In some cases, Tangled Tales may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. You have the right to the following regarding your Personal Information transferred to Tangled Tales: To know the types of Personal Information Tangled Tales collects; To know the purposes for which it collects and uses your Personal Information; To know type or identity of third parties to which Tangled Tales discloses your Personal Information, and the purposes for which it does so; To access and update your Personal Information; and To know the choices and means Tangled Tales offers you for limiting the use and disclosure of your Personal Information.

Tangled Tales Services to Tangled Tales ID Holders.

When you provide your information to Tangled Tales, we may use information collected from technologies such as cookies, web beacons, and page tags, as described herein, to improve your experience of our website. For example, by saving information concerning the pages you visit and products you purchase, we will be able to provide you with information on other Tangled Tales goods and services that may be of interest to you. Furthermore, by creating an account with Tangled Tales, there is a possibility of receiving content from third parties through Tangled Tales, as discussed under Section 6.5, below.

Tangled Tales has entered into agreements with certain third parties with geographical affinity (“Local Partners”) with Tangled Tales ID holders in order to permit such Local Partners to provide Tangled Tales ID holders with benefits related to their affiliation with Tangled Tales at a local or regional level. Tangled Tales may share personal information with such Local Partners, and those Local Partners may share personal information with Tangled Tales in order to provide local and regional benefits to Tangled Tales ID holders. Furthermore, when such a Local Partner shares personal information with Tangled Tales in this way, a Tangled Tales ID will be created with that information, for use by the user whose information was used for that account. Based on the information we gather, we may use targeted advertising from third party vendors, customized to reflect your interests. For example, if you purchase certain materials from Tangled Tales, Tangled Tales may display advertisements from vendors of similar materials. To accomplish this, we may use cookies and other technologies in order to recognize your computer at the time we display an advertisement to you. Tangled Tales may tailor advertisements based on your use of our website, such as tracking the pages you visit, the searches you make, or the goods or services you purchase. Tangled Tales does not correlate activities described in this section with your Personal Information, and we will not provide advertisers with your Personal Information when you view a targeted advertisement. However, through your interaction with a targeted advertisement, you consent that an advertiser may infer that you meet certain targeting criteria for the display of the advertisement.

In creating a Tangled Tales ID, and as a condition of having a Tangled Tales ID, you expressly consent to Tangled Tales’ use of your Personal Information and non-personally identifiable information as described in this section. Moreover, in using a Tangled Tales ID you expressly acknowledge and agree to our collection and use of such information as described in this section.

You can opt-out of the use of your Personal Information as described in this section by deleting your Tangled Tales ID. To delete your Tangled Tales ID, please contact Tangled Tales Customer Service as specified in Section 16 below.

Other Tangled Tales Services.

Tangled Tales Internal Data Sharing

Tangled Tales may also share your Personal Information with other Tangled Tales offices or Tangled Tales subsidiaries in the country in which you reside and in other countries.

Information Sharing with Third Parties This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Tangled Tales may utilize third-party service providers that process your Personal Information solely on Tangled Tales’ behalf (“Agents”). When Tangled Tales transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes. Tangled Tales will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations under the principles. Tangled Tales remains responsible and liable if the Agents that Tangled Tales engages to process your Personal Information on Tangled Tales’s behalf do so in a manner inconsistent with this Online Privacy Policy and the Privacy Shield Principles, unless Tangled Tales proves that it is not responsible for the event giving rise to the damage.

Tangled Tales may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person. Tangled Tales uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services. All parties with which Tangled Tales shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.

Tangled Tales may partner with third parties to provide other specific services, including, but not limited to registration for Tangled Tales conferences and other Tangled Tales program and educational materials. When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services. Tangled Tales may auto-populate forms utilized by these third parties with data contained in Tangled Tales managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services. All parties with which Tangled Tales shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.

Tangled Tales shall not share your opt-in text message authorization with any other non-Tangled Tales entity.

Other Possible Disclosures.

In addition to the other disclosures stated herein, Tangled Tales may share your information in the following ways:

To comply with applicable laws, regulations, legal processes, or government enforced orders, To enforce applicable terms of service, protect our legal rights or defend against legal claims, To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud, To comply with Tangled Tales’s obligations to address complaints arising under EU Data Protection Authorities, or other necessary entities. To guard against harm (whether actual or potential) to the legal rights, property or safety of Tangled Tales, our visitors or the general public as required or permitted by law. 

International Transfers

We share your personal data within Tangled Tales. This will involve transferring your data outside the European Economic Area (EEA). Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Tangled Tales Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer or member. (a) Identity (b) Contact Performance of a contract with you To register you for Tangled Tales events, conferences and programs. (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transactional a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Managing Tangled Tales member services. (d) Administering, maintaining monitoring, and managing Tangled Tales certifications, and related examinations and programs. (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transactional (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To enable you to partake in a prize draw, competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business)

Data retention

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements.

Tangled Tales Email Uses

Tangled Tales never rents or sells email addresses to outside parties without your consent. Occasionally, you may wish to receive information or communication from a Tangled Tales client. In that instance, you will be asked for permission to share your email address.

When you submit Personal Information to Tangled Tales, including signing up for our email list or submitting any form, you will receive information about Tangled Tales products, services, and educational offerings that relate to your areas of interest unless you choose to opt-out. If you have questions or concerns about Tangled Tales’ Online Privacy Policy or wish to no longer receive such offers (opt-out), please contact Tangled Tales Customer Service as specified in Section 16 below.

How to Access or Change Your Personal Information

To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may request such changes by contacting Tangled Tales Customer Service as specified in Section 16 below.

In your request, clearly state what information you would like to have changed or updated. Tangled Tales will try to comply with your request as soon as possible.

The deletion of Personal Information and other changes to the data retained by Tangled Tales as described above may result in the deletion or limitation of other services Tangled Tales provides, including, but not limited to, maintaining and making accessible Tangled Tales certification records. Tangled Tales may retain certain Personal Information to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce agreements.

Your Legal Rights. You have the right to: Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you choose to exercise any of your legal rights outlined herein, you have the right not to receive discriminatory treatment by Tangled Tales.

Verification

Tangled Tales will regularly self-assess its compliance with all applicable laws and the Privacy Shield Principles regarding Personal Information that is received from the EU.

Recourse Mechanisms

Tangled Tales makes readily available independent recourse mechanisms by which your complaints and disputes are investigated and expeditiously resolved at no cost to you. Please direct any inquiries or complaints regarding our compliance to the point of contact listed in Section 16 below. If we do not resolve your complaint within 45 days, you may submit your complaint free of charge to JAMS using this link: https://www.jamsadr.com/eu-us-privacy-shield. Tangled Tales has designated JAMS, an alternative dispute resolution provider in the United States, as its alternative dispute resolution process. The JAMS dispute resolution process shall be conducted in English. A binding arbitration option will also be made available to you at your request if you qualify for such option in order to address your complaints not resolved by any other means.

Notices of Changes to Privacy Policy

In the event of any change to the Tangled Tales Online Privacy Policy, notice of such changes will be posted on the Tangled Tales website. Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Tangled Tales website. Your use of the Tangled Tales website following these changes means that you accept the revised Online Privacy Policy.

Contact Tangled Tales

For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact: info@tangledtalesllc.com.