Privacy Policy

ABOUT TUPALO

Tupalo is an interactive Internet Service providing a tool for users to find, review and share local entertainment, business and shopping resources in locations around the world which are of interest to the user. Users provide most content contained within Tupalo by creating and sharing their personal experiences and opinions of establishments contained within the Tupalo database. Aditionally we work with data partners that provide us with location data of businesses around the world. For the purpose of this privacy policy, a “user” is defined as any member of the public who takes advantage of the Services provided by Tupalo. A “friend” is defined as any registered member of Tupalo who has been actively invited or given permission to connect and share reviews, favorites and private messages with another user via Services provided by Tupalo. A “spot” is defined as any company, person or establishment operating a business or organization that users interact with via Services provided by Tupalo.

TUPALO’S PRIVACY POLICY

Tupalo is adamant about protecting the personal information of it’s users. In this privacy policy we’ll explain how, when and why personal information is collected, used, and disclosed via Tupalo (also described as “we” and the “Site”).

By registering with and taking advantage of the Services that Tupalo offers, you consent to the privacy practices described in this policy below. These policies will be modified from time to time by Tupalo, so please check back periodically to see if changes have been made.

INFORMATION WE COLLECT

We only collect information about you if we have a reason to do so – for example, to provide our Services to you and other users, to communicate with you, or to improve our Services to you.

We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

  • Basic Account Information:  We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Tupalo account to provide a username and email address–and that’s it. You may provide us with more information–like your name–but we don’t require that information to create a Tupalo account. Never will Tupalo display your email address to another user visiting your profile, even when a mutually agreed friendship is present.
  • Profile Information:  If you have an account with us, we collect the information that you provide for your profile. For example, if you have a Tupalo account, your username is part of that profile, along with any other information you add to your profile, such as a photo, your home town/country, a Biography description or social media links. Your default location, entered as City and Country, is shared publicly via your personal profile by default, but can be disabled by editing your profile.
  • Transaction and Billing Information: If you, as a representative of an establishment/business/spot, buy a subscription to a Tupalo plan from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
  • Content Information: Tupalo collects user-submitted photos, ratings & reviews, bookmarks and favorites of users for businesses and Service providers. This user-submitted information is public by default and accessible to all users of Tupalo. Tupalo collects user-submitted checkins of users for businesses and Service providers. This user-submitted information is partially public when a user has the most checkins to a spot ("Kaiser")
  • Credentials:  Depending on the Services you use, you may provide us with credentials for other web services you use.
  • Communications With Us (Hi There!): You may also provide us with information when you respond to surveys, communicate with us about a support question, content issue and feedback.

Information We Collect Automatically

We also collect some information automatically:

  • Log Information:  Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
  • Usage Information:  We collect information about your usage of our Services. For example, we collect information about the actions users perform on Tupalo – in other words, who did what, when and where on Tupalo (e.g., [username] reviewed/rated/liked/saved or edited [spot] on Tupalo at [time/date]) We also collect information about what happens when you use our Services (e.g., page views, searches) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
  • Location Information:  We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions and to allow us to detect and warn you about suspicious account activity . We may also collect information about your precise location via our mobile apps (when, for example, you post a review for a spot or check-in to a spot) if you allow us to do so through your mobile device operating system’s permissions.
  • Stored Information:  We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access selected photos stored on your device when you upload a really amazing photograph of your latest lunch to a Tupalo spot.
  • Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Tupalo uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness, to deliver targeted ads and provide performance tracking to some of our data partners. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.

Information We Collect from Other Sources

We may get information about users from other sources. For example, if you log into Tupalo account through another service (Facebook, Twitter, Google), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.

Tupalo collects information about spots, such as name, address, phone-number, website and socialmedia links either via user submissions or from data partners. In some cases this information refers to a one-person business and thus might be considered personal information in some juristictions.

HOW AND WHY WE USE INFORMATION

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

  • To provide our Services – for example, to set up and maintain your Tupalo user account or Tupalo business account, charge you for any of our paid plans, display your public profile and the content you contributed on our Service, or allow you to contact other users on the service via friend requests or messages; Some spot pages (listing pages, business pages) might refer to one-person businesses and allow our users to find information about said business as well write reviews and ratings and upload photos regarding the one-person business. We use this information based on the legitimate interest of running a ratings and review platform for local businesses.
  • To further develop and improve our Services – for example by adding new features that we think our users will enjoy or will help our users and business owners with the Service.
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition – for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
  • To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Tupalo and others, which may result in us declining a transaction or the use of our Services;
  • To communicate with you, for example through an email, about offers and promotions offered by Tupalo and others we think will be of interest to you, solicit your feedback, or keep you up to date on Tupalo and our products; and
  • To personalize your experience using our Services, target our marketing messages to groups of our users (for example, those who have a particular business plan with us or have been our user for a certain length of time), and serve relevant advertisements.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws (GDPR), which is that our use of your information is based on the grounds that:

  • (1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account – for example, in order to enable access to our website on your device or charge you for a paid plan; or
  • (2) The use is necessary for compliance with a legal obligation; or
  • (3) The use is necessary in order to protect your vital interests or those of another person; or
  • (4) We have a legitimate interest in using your information – for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
  • (5) You have given us your consent – for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy.

DISCLOSING INFORMATION

How We Disclose Information

We do not sell our users’ private personal information.

We disclose information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

  • Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we disclose to them.
  • Third Party Vendors: We may disclose information about you with third party vendors who need to know information about you in order to provide their services to us. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you), those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to disclose information with them. Other vendors are listed in our more specific policies (e.g. our Cookie Policy).
  • Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.
  • To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Tupalo, third parties, or the public at large.
  • Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Tupalo goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
  • Aggregated or De-Identified Information: We may disclose information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may disclose a hashed version of your email address to facilitate customized ad campaigns on other platforms.
  • Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

Information you share publicly

Through Tupalo, you are able to publish reviews, comments, forum discussions and other Content which becomes publicly available. Anonymous and Unregistered Users are able to search within and access Content created and published via this Service. Please do not post any personal information on this website which you wish to keep private.

You further acknowledge that when you voluntarily disclose information about yourself within Submitted Content to this Site, such information can be collected, compiled and published by third parties (e.g. search engines) unknowingly to Tupalo and it’s administrators. This may result in unsolicited messages from other people or companies not affiliated with Tupalo or it’s administrators. Please do not post any personal information on this website which you wish to keep private.

Per our terms of use, we have the right to republish your Submitted Content to third parties who in turn may display or publish such information in connection with their own websites, search engines, products, mobile platforms, and other media, whether electronic in nature or otherwise. Please do not post any personal information on this website which you wish to keep private.

HOW LONG WE KEEP INFORMATION

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it — which are described in the section above on How and Why We Use Information — and we are not legally required to continue to keep it.

SECURITY

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks and when possible storing your data encrypted at rest. All registered Tupalo accounts are password-protected, which are hashed within our databases. This means that only you, the user, are in possession of your password. While employees of Tupalo have access to portions of our database, all passwords are stored in a form which is unreadable.

You must be aware that when you voluntarily disclose your personally identifiable information (user name, email address, name, etc) via reviews, messages, forums, lists, personal messages, friend requests or any features involving two-way communication between users on Tupalo, this information may possibly be collected and used by third parties in ways considered abusive. Activities such as this are beyond the scope of Tupalo’s responsibility. For the sake of your personal security, we ask that you not post any personally identifiable information you wish to keep private via the Tupalo Site or Services.

Your personal information can always be modified by logging into your personal profile and editing the minimal personal information we collect. Registered users who wish to have their account removed are able to do this via their profile. Upon request, all personal identifiable information will be removed, as well as as much information related to content you provided as commercially possible without affecting the quality of Service and functionality of the Tupalo Service. Some residual non personal identifiable information may not be able to be removed.

If permissable by law, by registering with Tupalo you are acknowledging that Tupalo is not responsible for any intercepted information sent via the internet and you further release Tupalo from any and all claims which may arise of or related to the unauthorized use of intercepted information.

EXTERNAL LINKS

Tupalo contains many links which point to third party websites and service which we have no direct affiliation with. By your visiting such third party links via Tupalo, you acknowledge that Tupalo or it’s administrators are not responsible for the privacy policies or terms of use of third party sites which are linked to via Tupalo. We do not share personal information with third party sites and services by your visiting such sites and services via links found on Tupalo.

COOKIES AND OUR USAGE OF COOKIES

Tupalo uses “cookies”. A cookie is a small file that can be stored on your computer when you visit a website. Basically, cookies are used to provide users with additional functions on a website. For example, they may be used to help you navigate a web page, to allow you to continue to use a web page where you left it, or to save your preferences and settings when you revisit that website. Cookies cannot access, read or modify any other data on your computer. Most cookies on this website are so-called session cookies. They will be automatically deleted when you leave our website. Permanent cookies, however, remain on your computer until you manually delete them in your browser. We use such permanent cookies to recognize you when you next visit our website. If you want to control cookies on your computer, you can choose your browser settings to get a notification when a webpage wants to save cookies. You can also block or delete cookies if they have already been saved on your computer. If you want to know more about how to set these steps, please use the “Help” function in your browser. Please note that blocking or deleting cookies could interfere with your online experience and prevent you from fully using this website.

CHOICES

You have several choices available when it comes to information about you:

  • Limit the Information that You Provide:  If you have an account with us, you can choose not to provide the optional account information and profile information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
  • Limit Access to Information On Your Mobile Device:  Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like checking in to a spot, for example).
  • Opt-Out of Electronic Communications:  You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
  • Set Your Browser to Reject Cookies:  At this time, Tupalo does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Tupalo's websites, with the drawback that certain features of Tupalo's websites may not function properly without the aid of cookies.
  • Close Your Account:  While we’d be very sad to see you go, if you no longer want to use our Services you can close your Tupalo user account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above – for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
  • Request that we remove your spot page (listing page, business page): Deleting a spot requires us to verify that you are the owner of the business. Please get in touch with us by sending an email to feedback@tupalo.com. To avoid ambiguities, please inlcude the URL (Website address) of the listing. We will then remove your business listing from our database entirely. See our FAQ for more information.

YOUR RIGHTS

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to "Contacting Tupalo" to find out how to reach us.

EU individuals also have the right to make a complaint to a government supervisory authority.

CONTACTING TUPALO

If you have any questions or concerns regarding this privacy policy you are welcome to contact us at legal@tupalo.com

Tupalo Data Controller: Mr. Clemens Beer datacontroller@tupalo.com

Tupalo Data Protection Officer: Mr. Clemens Beer dpo@tupalo.com

TRANSFERRING INFORMATION

Because Tupalo Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us or third party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

  • In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the  EU-US Privacy Shield; or
  • In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

ADS AND ANALYTICS SERVICES PROVIDED BY OTHERS

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Tupalo and does not cover the collection of information by any third party advertisers or analytics providers.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA ("Google"). Google Analytics uses “cookies” which are text files placed on your computer to help the website analyze how users use the site. We process your data on the basis of our prevailing legitimate interest to cost efficiently generate easy-to-use website statistics.

The information generated by cookies about your use of our website (including your truncated/anonymized IP address and the ULRs of the pages accessed on our website) might be transmitted to and stored by Google on servers in the United States. We do not store any of your personal data collected in connection with Google Analytics.

Our website uses an IP anonymization feature provided by Google Analytics. Your IP address will therefore be truncated/anonymized by Google as soon as it receives it. On our behalf, Google will use this information for the purpose of evaluating your use of our website, compiling synthesis reports on website activity for website operators and providing us with services relating to website activity and internet usage. Google will not associate your IP address transmitted by your browser with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. You can also prevent Google’s collection of your data by downloading and installing the browser plug-in available here

More information on Google’s terms of use and data privacy statement is available under http://www.google.com/analytics/terms/ and https://policies.google.com/

THIRD PARTY DATA PROCESSORES

Tupalo uses the following third party data processors:

USAGE AND TERMS OF THIS PRIVACY POLICY

By using Tupalo, you signify your agreement to the terms of this privacy policy and our terms of use as presented to you. If you do not agree to these terms please cease usage of this Site immediately. We reserve the right to modify this privacy policy at any time. You and you alone are responsible for reviewing the terms of this privacy policy as well as our Terms of Service.

CREATIVE COMMONS SHAREALIKE LICENSE

This privacy policy is partly based on  Automattic'sFactbranch's and Zentr's privacy policy who have decided to make this privacy policy available under a Creative Commons Sharealike license. If you want to re-use parts of this policy, feel free to do so at your own responsibility.


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