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Privacy Policy

Welcome to Tangle that App, Inc.’s (Tangle) Privacy Policy. This policy explains how we collect, store, protect, and share your information, and who we share it with.

EFFECTIVE DATE: August 1, 2020

 

1. Where this Privacy Policy Applies

 

This Privacy Policy applies to our websites, apps and other services operated by Tangle. For simplicity, we refer to all of these as our “services” in this Privacy Policy.

 

2. Information Collected

 

To use our services, we must collect some information about you, such as basic profile details and the types of people you would like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account, as summarized below.

 

Information you give us:

You choose to give us certain information when using our services, such as:

 

  • Name

  • Username

  • Email address

  • Mobile phone number

  • Gender identity

  • Date of birth

  • Sexual preference

  • Photographs

  • Location

  • Login information and friend lists for social media accounts that you connect to your Tangle Account

  • Information related to your activities, preferences, tastes, interests and similar

 

Additional information you provide to us may include:

  • If you contact us, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
     

  • If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
     

  • We also process and store your chats with other users as well as the content you publish, as part of the operation of the services.

 

Information we receive from others:

In addition to the information you provide us directly, we receive information about you from others, including:

 

  • Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

 

  • Social Media: You may be able to use your social media login (such as Facebook Login) to create and log into your Tangle account. This saves you from having to remember yet another username and password and allows you to share some information from your social media account with us.

 

  • Other Partners: We may receive info about you from our partners, for instance where Tangle ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).

 

Information collected when you use our services:​

When you use our services, we collect information about which features you have used, how you’ve used them and the devices you use to access our services. See below for more details:

 

  • Usage Information: We may collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

 

  • Device information: We may collect information from and about the device(s) you use to access our services, which may include hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

 

  • Other information with your consent: If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

 

3. Cookies and Similar Technologies

 

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s) (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools, as summarized below.

 

  • Cookies are small data files that are transferred to your computer's hard disk that stores information about website visits, recognizes you and your preferences each time you visit Tangle, and ensures site functionality and enables us to provide the services our members request.

 

  • The cookies we collect enable us to learn how people interact with Tangle. Cookies store information about your website visits and can recognize you and your preferences each time you visit the Tangle site.

 

  • Tangle’s use of cookies and local storage devices is related to the performance of Tangle’s site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our members and visitors.

 

  • If you decide that you do not want all of your Tangle activities to be stored, you may set your browser and mobile settings to block cookies and local storage devices.

 

  • We may collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the Service, where visitors have come from and the pages they visited.

 

  • We may use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests.

 

4. How Information is Used

 

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we may use your information.

 

  • To administer your account and provide our services to you

    • Create and manage your account

    • Provide you with customer support and respond to your requests

    • Complete your transactions

    • Communicate with by email, phone, social media or mobile device about our services, including order management and billing

 

  • To help you connect with other users

    • Analyze your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others

    • Show users’ profiles to one another

 

  • To ensure a consistent experience across your devices

    • Link the various devices you use so that you can enjoy a consistent experience of our services on all of them.

 

  • To provide new Tangle services to you

    • Register you and display your profile on new Tangle features and apps

    • Administer your account on these new features and apps

 

  • To serve you relevant offers and ads

    • Administer sweepstakes, contests, discounts or other offers

    • Develop, display and track content and advertising tailored to your interests on our services and other sites

    • Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you

 

  • To improve our services and develop new ones

    • Administer focus groups and surveys

    • Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)

    • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

 

  • To prevent, detect and fight fraud or other illegal or unauthorized activities

    • Address ongoing or alleged misbehavior on and off-platform

    • Perform data analysis to better understand and design countermeasures against these activities

    • Retain data related to fraudulent activities to prevent against recurrences

 

  • To ensure legal compliance

    • Comply with legal requirements

    • Assist law enforcement

    • Enforce or exercise our rights, for example our Terms

 

To process your information as described above, we rely on the following legal bases:

 

  • Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

 

  • Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

 

  • Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

5. How Information is Shared

 

Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other Match Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

 

  • With other users

 

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.

 

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.

 

  • With our service providers and partners

 

We may use third parties to help us operate and improve our services. These third parties may assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

 

We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

 

  • For corporate transactions

 

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

 

  • When required by law

 

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

 

  • To enforce legal rights

 

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

 

  • With your consent or at your request

 

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

 

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
 

6. Your Rights

 

We want you to be in control of your information, so we have provided you with the following tools:

 

  • Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please email us at privacy@tangletheapp.com for help.

 

  • Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

 

We want you to be aware of your privacy rights. Here are a few key points to remember:

 

  • Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can also request a notice disclosing the categories of personal information about you that we may have shared with third parties for their direct marketing purposes during the preceding calendar year, if applicable. To request your personal information stored, or the categories of personal information shared with third parties, please submit your request to privacy@tangletheapp.com. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

 

  • Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at privacy@tangletheapp.com.

 

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

 

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the information is released.

 

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

 

  • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device and/or email address will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

 

7. How We Protect Your Information

 

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

 

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at privacy@tangletheapp.com.

 

8. How Long We Retain Information

 

We keep your personal information only so long as we need it for legitimate business purposes (as set forth in Section 4) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

 

Note that deleting our app from your mobile device will not delete your account. To delete your account, please email deleteyouraccount@tangletheapp.com from the email address associated with your account requesting deletion.

 

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:

 

a. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

b. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

c. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

d. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent any user who was banned for unsafe behavior or security incidents from opening a new account.

 

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

 

9. Children’s Privacy

 

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

 

Privacy Policy Changes

 

Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

 

Contact Us

 

If you have questions about this Privacy Policy, here’s how you can reach us:

 

Online: privacy@tangletheapp.com
 

By mail:

 

Tangle the App, Inc.

32 Derne Street

Boston, Massachusetts 02114

Attn: Privacy Officer

 

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