TicTuk Privacy Policy

Last modified: May 15, 2023

TicTuk Technologies Ltd. (“TicTuk” “we,” “our,” or “us”) is committed to protecting your privacy. This TicTuk Privacy Policy (this “Policy”) applies to our website at www.tictuk.com (our “Site”) and online services that link to this Policy, and describes how we collect, use and disclose your personal information when you visit our Site. This Policy also describes our practices regarding personal information that we collect as a processor on our business customers’ behalf (such as when we collect personal information from end users through our business customers’ implementation of our products and services, such as our software solution (the “Services”).

“Personal information” as used in this Policy means information about an individual, from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).

Some data protection laws in certain jurisdictions differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information. A processor does not make decisions about personal information; it only processes personal information on behalf of a controller and based on the controller’s instructions. As appropriate, this Policy will distinguish between our practices as a processor (i.e., when we process data on behalf of our business customers as a service provider in connection with our provision of the Services) and our practices as a controller (i.e., when we process data for our own purposes).

Our Site and Services are designed for businesses and their respective representatives. We do not offer products or services for use by individuals for their personal or household use. Accordingly, we treat all personal information covered by this Policy, including information about any visitors to our Site, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

This Policy does not apply to any services that our business customers provide to their end users. Our business customers have their own privacy policies regarding the collection, use, and disclosure of the personal information of their end users, which we encourage you to read.

This Policy does not apply to the personal information an individual makes available to TicTuk in connection with the recruiting or employment process.

By accessing or using our Site or Services, you signify that you have read and understood our collection, storage, use, and disclosure of your personal information as described in this Policy and our Terms of Use, available on our Site.

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU AS A CONTROLLER?

We collect personal information for which we act as a controller in a variety of ways. For example, you may provide us your personal information in the following situations: when you visit our Site, purchase our Services, buy or sell merchandise, make payments, register for an account, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use other features of our Site or Services.

We may link or combine your activities and information collected from you on our Site with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

The categories of information we collect may include:

Information you provide:

· Contact and profile information. We may collect personal information, such as your name, phone number, address, business information, postal/zip code, and e-mail address, when you purchase or register for our Services, sign up for our mailing list, or otherwise communicate or interact with us. We use this information to create, verify and personalize your account, to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your personal preferences.

· Payment and transaction information. We may collect information such as items purchased, date and time of your transaction, transaction details, and payment information (e.g., credit/debit card details). We use this information to complete your transaction or purchase, detect and prevent fraud, and inform our advertising and marketing activities.

· Comments, chat and opinions. When you contact us directly (e.g., by email, phone, mail or by completing an online form or participating in online chat), or in connection with our Services (e.g. to place an order, to buy or sell merchandise) we may record your comments and opinions, including information about your conversation history through the Chatbot. We use this information to respond to your question or comments, to evaluate and improve our products and Services and to inform our marketing and advertising activities. When you contact us directly to submit a concern, complaint or question, we may record your comments and collect the personal information contained in your communications (e.g., contact information, photos, etc.). We use this information to respond to your questions or concerns, and to evaluate and improve our products and services.

Information we collect when you use our Site and our Services:

· Location information. We may collect information about your general location if you provide your address or postal/zip code, or we may approximate your location based on your IP address. We may use your location information to provide personalized content and advertising, and to improve the effectiveness of our Site and Services. We may also use your location information to provide you with personalized offers regarding products, services, or other opportunities.

Information provided by others:

· Information provided by social networks. When you interact with our Services through various social media networks, such as when you “Like” us on Facebook, or when you follow us or share our content on Facebook, Twitter, Snapchat, LinkedIn, Instagram or other social networks, we may receive some information about you that you permit the social network to share with third parties. We use this information to complete your profile, to better understand the demographics of our customers and to inform our advertising and marketing activities. The data we receive may include your Facebook nicknames and gender (if made public on Facebook) and is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to our Site or Service.

· Information provided by others. From time to time, we may receive information about you from third parties and other users. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available. We may combine this information with the information we collect from you directly.

2. HOW DO WE USE PERSONAL INFORMATION AS A CONTROLLER?

To fulfil your requests and provide our Services to you. We may use your personal information to complete your order or other transactions, deliver orders you place online, or respond to your customer service requests or feedback. We may also use your information to personalize your experience with us.

· For marketing purposes. We may send you communications about new features, updates, products and special offers. We may also use your information to serve you ads about products and special offers about our products or other products or services we think you might find interesting. We may also use individual and aggregate information about you to inform our marketing and advertising campaigns. For more information on your choices about marketing communications, see “Your Choices and Control Over Your Information” below.

· To communicate with you. For example, we may communicate with you about your account activities, such as by providing you transaction confirmations. If you register with us, we may enroll you in our email newsletter or other periodic electronic communications, and we may also send you user surveys and promotional communications. We may communicate with you by email, postal mail, telephone, text message, or other means. For more information on how to adjust your communications preferences, see “Your Choices and Control Over Your Information” below.

· To monitor, improve and develop our products and Services. We may use your information to understand our visitors, business customers and end users of our business customers, and tailor our product offerings accordingly. From time to time, we analyze statistics and trends to improve our Site and Services and to develop new services or features.

· To protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law. We may use information to protect our company, our business customers, and our websites. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Policy, or agreements with third parties, to detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law.

3. WHAT INFORMATION MAY BE COLLECTED AUTOMATICALLY AS A CONTROLLER?

When you visit our Site or use our Services, read our emails, or otherwise engage with us through a computer or mobile device, we and our third party partners may automatically collect information about how you access and use the Site and Services and information about the device you use to access the Site and Services. This information allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Site and Services, and for other internal purposes. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). Information we collect automatically about you may be combined with other personal information we collect directly.

Specifically, we and our third party partners may use tracking technologies to automatically collect usage and device information, such as:

· Information about how you access the Site and Services, such as the site from which you came and the site to which you are going when you leave our Site, how frequently you access the Site or Services, when and whether you open emails or click the links contained in emails, whether you access the Site or Services from multiple devices, and other actions you take on the Site or Services.

· Information about how you use the Site and Services, such as the pages you visit and website navigation paths, the links you click, visit length, the ads you view and click on, purchase information and your checkout process, your general location when you access or interact with our Site or Services, and other similar actions.

· Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, e.g., a persistent device identifier or an Ad ID), and other such information.

· Analytics information. We may collect analytics data, or use third party analytics tools, to help us measure traffic and usage trends for the Site and Services and to understand more about the demographics and behaviors of our users.

We, or our third party partners, may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of our Site and Services; (e) perform analytics and detect usage patterns on our Site and Services; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, and (h) otherwise to plan for and enhance our Site and Services.

Your choices to control tracking technologies. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. For more information on how to block, delete and/or disable tracking technologies, see “Choice and Control Over Your Information” below.

Do Not Track. Although we do our best to honor the privacy preferences of our Site and Services visitors, we are not able to respond to “Do Not Track” signals from your browser at this time.

We and our third party partners may collect information through tracking technologies for personalized advertising purposes. See our Cookie and Ads Policy available on our Site to learn more.

4. HOW WE SHARE YOUR INFORMATION AS A CONTROLLER

We may share, sell or disclose your information in the instances described below. For further information on your choices regarding your information, see “Your Choices and Control Over Your Information” below.

· Other group companies: We may share personal information with our group companies and our affiliates, who may use your personal information for the purposes described in this Policy.

· Select marketing and strategic business partners: We may share limited data with our preferred marketing and strategic business partners so that they can provide you with information and marketing messages about products or services that may interest you. These parties may use your information in accordance with their own privacy policies.

· With your consent or at your direction: In addition to the sharing described in this Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

Other instances in which we may share your personal information:

· Service providers and advisors: Personal information may be shared with third party vendors and other service providers who perform services for us or on our behalf. These third parties include, but are not limited to: Amazon Web Services, Stripe, Facebook, TaxJar, Wix, Nexmo, etc. This may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, product fulfillment, delivery services, payments processing, data enhancement services, fraud prevention, web hosting, or analytic services.

· Purchasers and third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.

· Law enforcement, regulators and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Site or Services; and/or (c) to exercise or protect the rights, property, or personal safety of our organization, our visitors, or others.

In connection with any of the above, we may share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you.

5. YOUR CHOICES AND CONTROL OVER YOUR INFORMATION WE COLLECT AS A CONTROLLER

Profile and settings: You may update your account information and adjust your account settings by logging into your account at any time. Please note that changes to your settings may not update automatically and thus, require some time to take effect.

How to control your email preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all request to unsubscribe. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service,s technical and security notices). You may also be able to adjust certain communications preferences by logging into your account.

Geolocation and device Information: You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your address book, location, photo stream, and camera. You may also control precise location tracking by adjusting your location services’ settings on your mobile device. We may continue to approximate your location based on your IP address or through other means when you access the Services through a computer or device.

Online advertising and tracking. We may work with third party partners to collect data through tracking technologies for various purposes, including analytics and advertising, and to understand your choices.

6. HOW WE STORE AND PROTECT YOUR INFORMATION WE COLLECT AS A CONTROLLER

Data storage and transfer: Your information collected through our Services may be stored and processed in the United States or any other country in which TicTuk, Yum! Brands, its affiliates or service providers maintain facilities. If you are located in regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that have data protection laws that may be more or less restrictive than those required under U.S. law.

Data retention: We will retain your personal information as long as reasonably necessary to fulfil the purposes for which we collected it, to meet legal, reporting and accounting obligations, and for the other purposes described in this Policy, to establish or defend legal claims, for fraud prevention purposes or as otherwise required or permitted by law. In general, information obtained in the course of providing our Services will be blocked from general access within a few days and deleted within 18 months after the end of us providing you Services, unless an earlier deletion is requested or has been agreed upon, or statutory retention requirements require a longer retention or we need to retain such data for our legitimate interests, for example, the defense against IT security threats. We may anonymize and/or aggregate personal information and store it in order to analyze aggregate metrics and trends.

Keeping your information safe: Security of your information is very important to us, and we have put in place safeguards to preserve the integrity and security of information we collect and share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems at all times. In the event that any information under our control is compromised as a result of a breach of data security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take additional steps, in accordance with any applicable laws and regulations

7. JURISDICTIONAL DISCLOSURES FOR INFORMATION WE COLLECT AS A CONTROLLER

We may choose or be required by law to provide different or additional disclosures about our data privacy practices depending on your state or country of residence. Please review this section or applicable regional addenda to understand how our practices or policies may differ in your jurisdiction:

EUROPE

· Where we have an establishment in the European Economic Area (“EEA”), the United Kingdom or Switzerland or we are processing personal information relating to individuals located in the EEA, the UK, or Switzerland, please see the specific section at the bottom of this page for additional information about our data privacy practices.

8. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU AS A PROCESSOR?

When you use our business customers’ implementation of our Services, we may collect certain personal information about you, for which we act as a processor on behalf of our business customers (who act as the controllers of such data). This section describes the types of personal information we may collect about you as a processor, and the ways in which we collect such information. Please note our use and processing of this personal information as a processor is governed by our agreements with our business customers. Our business customers may have their own privacy policies that govern the personal information collected in connection with their use of our Services, and you should consult the policies of and/or contact the applicable business customer to see how they process and share your personal information relating to the Services, including with respect to any rights you may have to such personal information. If we receive any requests to exercise such rights with respect to personal information for which we act as a processor, we are not able to directly accommodate such requests but will forward such requests to the applicable business customer (or otherwise follow the procedure we have agreed upon with the applicable business customer).

The categories of information we collect may include:

Information you provide:

· Contact and profile information. We may collect personal information, such as your name, phone number, address, business information, postal/zip code, and e-mail address, when you register for our Services, place an order for delivery, sign up for our mailing list, or otherwise communicate or interact with us. We use this information to create, verify and personalize your account, to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.

· Comments, chat and opinions. When you send messages through our business customers’ implementation of our Services.

9. HOW DO WE USE PERSONAL INFORMATION AS A PROCESSOR?

For the personal information we collect about you as a processor on our business customers’ behalf, we may use such personal information for the following purposes, or as otherwise described at the time of collection:

· To provide our Services. We may use your personal information to provide and operate the Services, establish and maintain your user profile, and provide support for the Services, and respond to your customer service requests or feedback.

· For our business customers to communicate with you. Our business customers may send you emails or text messages using our Services. If you would like to opt-out of receiving such further communications, you need to exercise your rights with those companies by, for example, unsubscribing to their emails.

10. HOW WE SHARE YOUR INFORMATION AS A PROCESSOR

For the personal information we collect about you as a processor on our business customers’ behalf, we may share such personal information with the following parties and as otherwise described in this Policy or at the time of collection:

· Business customers. We will share your personal information with our business customers that are using the Services, and our business customers may have their own privacy policies that govern the personal information collected in connection with their use of the Services.

· Third parties designated by our business customers. We may share your personal information with third parties where our business customers have instructed us to do so.

Other instances in which we may share your personal information:

· Service providers and advisors: Personal information may be shared with third party vendors and other service providers who perform services for us or on our behalf or help us operate the Services.

· Law enforcement, regulators and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our business partners’ terms of use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of our business partners, our organization, our visitors, or others.

11. YOUR CHOICES AND CONTROL OVER YOUR INFORMATION WE COLLECT AS A PROCESSOR

As mentioned above, you should consult the policies of and/or contact the applicable business customer to see how they process and share your personal information relating to the Services, including with respect to any rights you may have to such personal information. If we receive any requests to exercise such rights with respect to personal information for which we act as a processor, we are not able to directly accommodate such requests but will forward such requests to the applicable business customer (or otherwise follow the procedure we have agreed upon with the applicable business customer).

12. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from individuals under the age of majority in their state, province, or country of residence. In the event we learn that we have inadvertently collected personal information from an individual under the age of majority, we will delete that information as quickly as possible. If you believe that we may have collected information from an individual under the age of majority, please contact us using the contact information below.

13. LINKS TO OTHER WEB SITES AND SERVICES

The Site and Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability resulting from you following a link to these websites. Additionally, other privacy policies may apply when you engage with us through a co-branded or co-sponsored promotional or marketing activity. We strongly recommend that you read the privacy policies and terms and conditions of use of any third-party website or service to understand how your information will be collected, used and shared. We are not responsible for the privacy practices or the content on the websites of third-party sites.

14. HOW TO CONTACT US

If you have any questions about this Policy, the Site or the Services, please contact us at toinfo@tictuk.com.

If you are located outside of the United States, please refer to the local contact information provided in the Jurisdictional Disclosures section, above.

15. CHANGES TO OUR PRIVACY POLICY

We may modify or update this Policy from time to time to reflect the changes in our business and practices, so you should review this Policy periodically. When we change this Policy in a material manner, we will so indicate by updating the “last modified” date in the heading of this Policy. If you object to any changes in this Policy, you may close your account associated with the Services.