At Tightrope Media Systems, Inc. (“Tightrope”, “we”, and “our”) we are committed to safeguarding the privacy of our customers and of the data collected through the use of our Tightrope and Carousel brand websites, our software products, and all services we provide (collectively, the “Services”).
Tightrope and its licensors own, operate, and maintain the Services. Tightrope is a Minnesota corporation with its principal place of business at 430 N First Ave., Suite 400, Minneapolis, Minnesota, U.S.A. Should you have any privacy questions or concerns you may contact Tightrope by sending an email to email@example.com.
By using the Services, you agree to the information collection and use policies and practices stated herein. If we make material changes to this policy, we will notify you by email, with a notice the next time you log into or access the Services, or by other means. Such revisions and additions shall be eﬀective immediately upon notice. You are responsible for reviewing the Services for any modiﬁcation to this policy. Any access or use of the Services by you after notice of modiﬁcations to this policy shall constitute and be deemed to be your agreement to such modiﬁcations.
(a) Personal Information
Customers and Users of the Services are required to provide personal information to Tightrope to establish and maintain access to the Services. Customers must provide the following personal and business information to Tightrope as part of the Services registration process:
- the administrator’s telephone number
- the Customer business or organization name
- the Customer street address
- the Customer payment information
All Users of the Services must be authorized to use the Services by a Tightrope Customer. We may collect the following personal information from Users for this purpose:
- first and last name
- email address
(b) Information About Your Browser and Devices
We collect information about the web browser (“browser”) and computer or electronic device (“device”) you use to access and use the Services. This information may include unique device identifiers, your browser type and settings, device type and settings, and operating system. We may also collect information about the interaction of your browser and device with our Services, including IP addresses, crash reports, system activity, and the date and time you use the Services. We collect your browser and device information whenever you log into and use the Services from your device.
(c) Information About Your Use of the Services
We may collect information about how you use the Services when you are logged in and using its functionality. This may include information about the types of content that users upload, manage, and display when using the Services. We may also compile certain general usage information concerning the Services. You agree that we are authorized to use, reproduce and generally make such information available to third parties in the aggregate, provided that such information shall not include personal information about you, a User or any data subject.
If your use of the Services is paid for by an organization (e.g. employer), you agree that we may make your usage information available to such organization, including but not limited to, content created and loaded to the Services including the dates and times of your use and actions.
(a) Providing You the Services Functionality
We process your personal information so we can maintain your Customer and User account and provide you with the Services and Services functionality. We also use information about your devices and browser to automatically configure the Services for your use when you log-in. We may also use other information about your device, browser, operating system, and similar information to enhance your use of the Services.
(b) Processing Payments
If we collect payment information from the Customer account administrator, we use this information to process payments of the subscription fees we charge.
(c) Customer Content
Customers and Users save, manage, and display Customer Content when using the Services. We do not generally view or monitor the Customer Content as we operate and provide the Services functionality. We may need to view and monitor the Customer Content to provide support and maintenance services to our Customers and Users.
(d) Communications with Users
We may use personal information like your email address to communicate and interact with you directly. For example, we may let you know about upcoming changes or improvements to the Services. If you contact Tightrope for support or assistance in using the Services, we’ll keep a record of your request and our communications with you so we can better assist you in addressing the issues.
(e) Use of Mobile Phone Number
If you revoke your consent for the use of your mobile number in connection with your use of the Services, you may not have access to all Services functionality.
(f) Disclosures to Third-Party Information Processors
(g) When Disclosures to Other Third Parties May Be Made
(h) Our Use of Your Services Usage Information
We use the information that we collect about your use of the Services to analyze, measure, evaluate, and improve or change the features and functionality of the Services. We may also use this information for product marketing, promotion, and sales purposes in our business discretion. We may share this usage information with third parties for marketing, advertising, or other similar uses. Your usage information will not include any personal information which identifies or can be attributed to a user unless we first notify you and obtain your consent.
Our legitimate business interest for collecting our users’ personal information is to operate the Services for the benefit of our Customers and Users in return for subscription fees. We use the subscription fees to pay our business expenses and operate Tightrope, which is a for-profit business.
Data security is implemented through physical, administrative, and technical safeguards we put in place and operational procedures we follow to protect personal information. We protect your transactions involving personal information over the Internet using Transport Level Security (TLS) technology. We restrict access to your personal information in our database to our authorized employees, our agents, and certain of our authorized contractors. We will promptly notify you if we learn or have reason to believe that any person or entity has breached our safeguards and gained unauthorized access to your personal information.
You can export or copy the content, data, or other files stored in the Services at any time. To delete your personal information from the Services, you can terminate your User account which will delete your personal information from the operating version of the Services.
We may need to retain some of your personal information and content for limited periods for our legitimate business or legal purposes. Contact us for more information about our data retention periods and how long it takes us to delete your information.
The Services is not intended for use by children or persons under the age of 18. We will not knowingly collect any personal information from minors through this Services. If you think that we have collected personal information from a minor, please contact us immediately using the information in Section 12, below.
European and Canadian data protection laws give data subjects certain rights regarding their personal information. Tightrope Customers and Users are required to notify data subjects when the Customer or User has obtained a data subject’s personal information and the specific purposes for which the personal information may be used. It is the obligation of the Customer or User of the Services to obtain consent from the data subject for the use of their personal information.
If you are a User located within the European Union or Canada, you may ask us to take the following actions in relation to your personal information that we hold:
● Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
● Access. Provide you with information about our processing of your personal information and give you access to your personal information.
● Correct. Update or correct inaccuracies in your personal information.
● Delete. Delete your personal information.
● Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
● Restrict. Restrict the processing of your personal information.
● Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.
You can submit these requests by email to firstname.lastname@example.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. European Union residents can find their data protection regulators here.
If we hold your personal information in connection with services that we provide to one of our Users, we will direct your request to the applicable User of our Services.
(a) Correcting Your Information
Send Tightrope an email at email@example.com if you want to access, review, correct or delete the personal information collected from you by Tightrope. To protect your privacy and security, Tightrope requires a Customer or User ID and password to verify your identity before granting you the right to access, review, or make corrections to your personal information. Please be advised that certain personal information may not be corrected or deleted if we must by law retain such information as submitted.
(b) Disclosure of Information
We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or legal process.
It is also possible that Tightrope would sell its business (by merger, acquisition or otherwise) or sell all or substantially all of its assets. In any transaction of this kind, Customer and User information, including your personal information, may be among the assets that are transferred. If we decide to so transfer your personal information, you will be notiﬁed by an email sent to the last know email address in our ﬁles or by notice posted on the Services.
(c) Retention of Personal Information
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
When we no longer require the personal information we have otherwise collected about you, such as when you cease to be a registered Customer or User of the Services, we will dissociate such identifying information from the personal information attached to your content to the extent possible while retaining such information only so long as needed to comply with business, legal or regulatory obligations and requirements. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
For our Customers and Users residing in the European Union, whenever we transfer your personal information to the United States, or other countries not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be made:
● Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules; or
● Pursuant to the consent of the individual to whom the personal information pertains; or
● As otherwise permitted by European law.
For data subjects located in the EU, we have appointed GDPR-Rep.eu as our representative pursuant to Article 27 of GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/11082518 for more information.
Contact information for GDPR-Rep.eu:
Tightrope Media Systems, Inc.
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence: GDPR-REP ID: 11082518.
Tightrope Media Systems, Inc.
430 N First Ave., Suite 400
Minneapolis, MN 55401
Copyright © 2018-2020. Tightrope Media Systems, Inc. All rights reserved.
Last revised: September 2, 2020.