Privacy Policy for Tensixty AI

At Ten Sixty, we prioritize your privacy. Please review this Privacy Policy to understand how we handle your personal information. By engaging with our Services in any capacity, you acknowledge and agree to the practices and policies outlined herein, consenting to our collection, utilization, and sharing of your information as detailed in this Privacy Policy.

Your interaction with Ten Sixty's Services is constantly governed by our Terms of Service, which includes this Privacy Policy. Definitions for any terms not defined in this Policy can be found in the Terms of Service.

As we strive to enhance our Services, changes to this Privacy Policy may occasionally be necessary. We will inform you of any changes by posting a notice on the Ten Sixty website, sending you an email, or through other methods. It's important to note that if you've chosen not to receive legal notice emails from us (or if we do not have your email address), you are still bound by those notices and responsible for understanding them. Continuing to use the Services after changes to the Privacy Policy means you accept all such changes.

Privacy Policy Contents Outline

1. Overview of This Privacy Policy

This document outlines our approach to handling Personal Information collected when you engage with our Services. "Personal Information" refers to any data that identifies or can be associated with a specific individual, also known as "personally identifiable information" or "personal information" in the context of relevant data protection laws, regulations, or rules. This Privacy Policy does not apply to the practices of entities not owned or managed by us or to individuals not employed or managed by us.

2. Personal Information

Details on the Types of Personal Information We Gather

Below is a chart that outlines the types of Personal Information we collect, including information collected in the past 12 months:

3. Types of Personal Information Collected

Profile or Contact Information

  • Name (first and last)
  • Email address
  • Telephone number

Third-Party Recipients: Service Providers, Marketing Partners, Data Analysis Firms, Business Allies, Authorized Third Parties

Financial Information

  • Details of financial accounts
  • Type of payment card
  • Payment card's last 4 digits
  • Billing address, telephone number, and email address

Third-Party Recipients: Service Providers (notably our payment processor, currently Stripe, Inc.)

Transaction Information

  • History of purchases

Third-Party Recipients: Authorized Third Parties

Device and IP Information

  • IP address
  • Device Identifier
  • Device type, operating system, and browser used for accessing the Services
  • Device fingerprint

Third-Party Recipients: Marketing Partners, Data Analysis Firms

Internet Usage Information

  • Interactions with web pages
  • Referring pages/sources through which the Services were accessed
  • Anonymous request identifiers
  • Statistics related to device or browser interaction with the Services
  • Internet or search history

Third-Party Recipients: Marketing Partners, Data Analysis Firms, Authorized Third Parties

Data from Social Networks

  • Email address
  • Social media username
  • Publicly posted social media content and associated statistics
  • Private data access may include social media profile performance analytics

Third-Party Recipients: Service Providers, Data Analysis Firms, Authorized Third Parties

Location Information

  • Location data based on IP address
  • Browser time zone

Third-Party Recipients: Service Providers, Marketing Partners, Data Analysis Firms

Sensory Data

  • Images, videos, or recordings of the surroundings

Third-Party Recipients: Service Providers, Data Analysis Firms, Business Allies, Authorized Third Parties

Data Based on Collected Personal Information

  • Predictions about user characteristics
  • Predictions about user behavior
  • Predictions about user preferences or capabilities

Third-Party Recipients: Service Providers, Marketing Partners, Data Analysis Firms

4. Sources from Which Personal Information is Collected

We gather Personal Information from the following sources:

Directly from You

When you directly provide us with information:

  • By creating an account or utilizing our interactive tools and Services
  • Through voluntary submissions in free-form text fields via the Services, or in response to surveys or questionnaires
  • By emailing us or initiating contact with us in other ways

As you interact with the Services, information is automatically collected:

  • Via Cookies (as outlined in the "Tracking Tools, Advertising and Opt-Out" section)
  • Information about your location and mobile device may be collected if you use our mobile app or a location-enabled browser
  • Information transmitted from your computing device for providing Services, such as login availability for updates or alerts

Public Records

From governmental entities or other public sources.

Through Third Parties

Vendors

  • Analytics providers may be used to understand your interaction and engagement with the Services
  • Third parties may assist in providing customer support
  • Vendors may supply information for lead generation and user profile creation

Advertising Partners

  • We obtain information about you from vendors who assist with our marketing or promotional services
  • Focusing on your interactions with our websites, apps, products, Services, ads, or communications

Social Networks

  • Content and/or information from your social network accounts may be transmitted to your account with us
  • If you link your social network credentials to our Services or log in through a third-party service

5. Purposes for Collecting or Disclosing Information

To Provide, Customize, and Enhance the Services

  • Account creation and user profile management
  • Processing transactions, billing
  • Delivering requested products, services, or information
  • Fulfilling the purpose for which information was provided
  • Offering support and assistance for the Services
  • Enhancing the Services through testing, research, internal analytics, and product development
  • Personalizing Services, content, and communications based on preferences
  • Conducting fraud protection, security measures, and debugging
  • Executing other business activities as mentioned during the collection of your Personal Information

For Marketing Purposes

  • Marketing and selling the Services
  • Displaying advertisements, including targeted or behavioral advertising

To Communicate with You

  • Addressing correspondence received from you, contacting you when necessary or requested
  • Sending information about Ten Sixty or the Services
  • Distributing emails and other communications based on your preferences or that we believe will interest you

To Meet Legal Obligations and Enforce Legal Terms

  • Complying with legal requirements under laws, regulations, court orders, or other legal processes
  • Security incident prevention, detection, and investigation
  • Protecting the rights, property, or safety of parties involved
  • Enforcing agreements with you
  • Addressing third-party claims regarding content violations
  • Managing disputes

We do not collect additional categories of Personal Information or use the Personal Information we've gathered for significantly different, unrelated, or incompatible purposes without notifying you. For California residents, note that your sensitive personal information is used or disclosed solely for purposes outlined in CPRA section 7027(m), and we do not gather or process sensitive personal information to infer characteristics about California residents.

6. Disclosure of Your Personal Information

We share your Personal Information with various categories of service providers and other entities as detailed in this section. Depending on the state laws applicable to you, certain disclosures of your Personal Information might be considered a "sale." For additional details, please see the sections specific to your state below.

Service Providers

These entities assist in delivering our Services or executing business operations on our behalf, including:

  • Providers of hosting, technology, and communication services
  • Analytics services providers
  • Customer support and service vendors
  • Payment processing services

Stripe, Inc. ("Stripe"), our payment processing partner, gathers the payment card information you provide voluntarily to facilitate your payment.

For information on how Stripe uses and stores your Personal Information, please review Stripe`'s terms of service and privacy policy.

Advertising Partners

These entities support us in marketing our services and presenting you with offers that might interest you, including:

  • Advertising networks
  • Marketing service providers

Analytics Partners

These entities analyze the traffic and usage of our Services, including:

  • Companies analyzing how users are directed to or referred to the Services
  • Companies examining user interactions with the Services

Business Partners

These entities collaborate with us to provide various services, including:

  • Businesses you have relationships with
  • Companies offering marketing (e.g., social media scheduling) and creator tools that integrate with our products
  • Companies with whom we conduct joint promotional activities

Entities Authorized by You

  • Third-party services accessed via our services
  • Social media platforms

Legal Obligations

We reserve the right to disclose any collected Personal Information to third parties as necessary for any legal obligations outlined in the "Meeting Legal Requirements and Enforcing Legal Terms" section.

Business Transitions

In the event of a merger, acquisition, bankruptcy, or any other scenario where a third party takes control of our business, wholly or partially, we may transfer all collected Personal Information to this third party. We will endeavour to notify you in advance if your data becomes subject to a different set of privacy and security policies and practices.

Non-Personal Data

We may generate aggregated, unidentifiable, or anonymized data from the Personal Information we collect, by eliminating identifiers that link the data to you specifically. This processed data may be used and shared with third parties for legitimate business interests, such as analyzing, developing, and improving the Services and our business promotion, with the assurance that it will not be shared in a way that can re-identify you.

7. Use of Tracking Technologies and Ad Preferences

Our Services employ cookies and similar tracking technologies like pixel tags, web beacons, clear GIFs, and JavaScript, collectively referred to as "Cookies," to recognize your browser, understand how and when you visit and use our Services, track trends, and gather data to enhance our Services. Cookies are small data files placed on your device when you visit our Services. In addition to the data we collect, we may also receive data collected by third parties through their own cookies placed on your devices. It's important to note that our Services do not accommodate "Do Not Track" signals from web browsers at this time due to our use of Cookies.

We utilize various types of Cookies:

Essential Cookies

These are necessary to provide you with services and features you have requested. For instance, they enable secure access to our Services. Turning off these Cookies may result in the unavailability of certain functionalities and services.

Functional Cookies

These are used to remember your settings and preferences on our Services, like your language or region, to enhance your experience and provide personalized content.

Performance/Analytical Cookies

These Cookies help us understand the behaviour of our visitors, such as which pages are visited most often and how long visitors spend on those pages. This information assists in improving our Services and advertising campaigns. For instance, Google uses Cookies for its Google Analytics services, subject to Google's own privacy policies and terms. You have the option to opt out of Google's use of Cookies by visiting Google's ad settings or the Google Analytics opt-out add-on.

Retargeting/Advertising Cookies

These Cookies track your online activities to deliver ads that are more relevant to your interests. Further details are provided in the section titled "Information about Interest-Based Advertisements."

Cookie Management

You have control over the acceptance of Cookies through your web browser's settings, where you can refuse the use of Cookies, accept or reject new Cookies, and remove existing Cookies. Adjusting these settings may require you to manually adjust preferences each visit, and some services and functionalities might not work if Cookies are disabled.

To manage or learn more about Cookies, access your browser's Cookie management settings or visit general information sites like http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ for users in the European Union.

Interest-Based Advertising

Our Services may display advertisements directly and also permit advertisements from third-party networks, servers, agencies, technology vendors, and research firms. These ads can be tailored to users based on specific profiles, preferences, or behaviours, known as "Interest-Based Ads."

We adhere to the Self-Regulatory Principles for Online Behavioural Advertising set forth by the Digital Advertising Alliance (DAA). For information on how to manage your preferences for Interest-Based Ads from involved third parties, or to opt-out from receiving targeted ads from those participating entities, you are encouraged to visit the opt-out pages of the DAA or NAI at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. For users within the European Union, additional information and opt-out options are available at the European Interactive Digital Advertising Alliance's website, http://www.youronlinechoices.eu/.

8. Protecting Your Data

Our aim is to safeguard your Personal Data from unauthorized access, usage, and disclosure by employing suitable physical, technological, organizational, and administrative security measures, tailored to the nature of the Personal Data and our processing activities. We also encourage you to play a role in protecting your information by choosing a secure password and/or other sign-on methods, restricting access to your computer or device and browser, and logging out after accessing your account. Despite our efforts to secure your data, we acknowledge that no method of data transmission over the internet or data storage is entirely secure.

9. Storing Your Data

We keep your Personal Data for as long as it is necessary to offer our Services or for our operational or commercial reasons in collecting it. The duration for which we store specific data categories is determined by considering the source of the data, our need for the Personal Data, the purposes for which we collected the data, and the data's sensitivity. In certain instances, we may keep Personal Data longer if required to fulfill legal obligations, resolve disputes, collect fees due, or as allowed or mandated by law, regulation, or rule. We might also retain information in an anonymized or aggregated form where it cannot personally identify you.

For instance:

  • We will hold onto your profile information and credentials as long as your account is active.
  • We keep your payment information for the duration needed to process transactions or subscriptions.
  • We store data related to your device/IP as needed to maintain the effective, efficient operation of our systems.

10. Data on Minors

Consistent with our Terms of Service, we do not intentionally gather or seek out Personal Data from children under 18 years of age. If you are under 18, please refrain from registering for the Services, using them, or sending us any Personal Data. Upon discovering that we have inadvertently collected Personal Data from a child under 18, we will eliminate that information promptly. If you suspect that a child under 18 has provided us with Personal Data, please reach out to us at contact@tensixty.com.

11. Rights of California Residents

As a resident of California, you possess specific rights detailed in this segment. For instructions on exercising these rights, please refer to the "Exercising Your Rights" section below. It's important to note that we might process the Personal Data of our customers' end users or employees as part of delivering services to our customers. If your Personal Data is being processed by us as a service provider, you should initially contact the entity that collected your Personal Data to address your rights regarding such data. In instances of conflict between this segment and other sections of this Privacy Policy for California residents, the provisions offering greater protection to Personal Data will prevail. For any inquiries about this segment or to find out if the following rights apply to you, please reach out to us at contact@tensixty.com.

Access

You're entitled to request specific information about our collection and utilization of your Personal Data over the last 12 months.

We will provide you with:

  • The types of Personal Data we've gathered about you.
  • The sources from which the Personal Data was collected.
  • The business or commercial reasons for collecting or selling your Personal Data.
  • The categories of third parties with whom we've shared your Personal Data.
  • The particular pieces of Personal Data we've collected about you.

Should we have disclosed your Personal Data to third parties for business purposes in the last 12 months, we will identify the types of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data in the last 12 months, we will specify the types of Personal Data sold to each category of third-party recipient.

Deletion

You have the right to request the deletion of the Personal Data we've collected about you, subject to certain exceptions under the CPRA, such as the necessity to retain your Personal Data to provide Services you've requested or when deletion requires disproportionate effort. Your request for deletion may be denied if it falls under these exceptions.

Correction

You can request correction of inaccurate Personal Data we have about you. Under the CPRA, this right has exceptions, for instance, if we determine that the Personal Data is accurate based on the circumstances. Your request for correction may be denied if it falls under these exceptions.

Personal Data Sales Opt-Out and Opt-In

We do not sell your Personal Data and have not in the last 12 months. To our knowledge, we do not sell Personal Data of minors under 16 years of age.

Non-Discrimination for Exercising CPRA Rights

Exercising your CPRA rights will not result in discrimination against you. We won't deny goods or services, charge different prices or rates, or provide a different quality of goods or services. However, we may offer different tiers of Services as permitted by data privacy laws, including the CPRA, with variations in prices, rates, or quality based on the value of Personal Data we receive from you.

12. Rights of Virginia Residents

As a Virginia resident, you are granted rights under the Virginia Consumer Data Protection Act (VCDPA). For instructions on how to exercise these rights, see the "Exercising Your Rights" section below. We may process Personal Data of our customers' end users or employees in delivering services to our customers. If your Personal Data is processed by us as a service provider, contact the entity that collected your Personal Data first to address your rights regarding that data. This section's provisions that offer more protection to Personal Data will take precedence over any conflicting parts of this Privacy Policy for Virginia residents. For questions about this section or to determine if these rights apply to you, contact us at contact@tensixty.com.

Access

You have the right to confirm whether we are processing your Personal Data and to access it.

Correction

You can correct inaccuracies in your Personal Data, appropriate to the data's nature and our processing purposes.

Portability

You are entitled to receive a copy of your Personal Data in a machine-readable format, where technically feasible.

Deletion

You have the right to have your Personal Data deleted.

Opt-Out Rights

  • You can opt-out of the processing of your Personal Data for targeted advertising.
  • You can opt-out of the sale of your Personal Data, as defined under the VCDPA.
  • You can opt-out of processing your Personal Data for profiling in decisions that significantly affect you, if applicable.

Challenging a Denial

Should we not act upon a request in a timeframe deemed reasonable following your submission in line with this section, you have the opportunity to appeal. For your appeal to be considered, you are required to:

  • (1) Submit adequate information to enable us to confirm your identity as the individual concerned by the original request and to recognize the initial request itself, and
  • (2) Offer an explanation for the grounds of your appeal. It's important to understand that your appeal is governed by the rights and responsibilities allocated to you under the VCDPA.

We commit to addressing your appeal within 60 days from the date we receive it. In the event of an appeal denial, you are entitled to reach out to the Virginia Attorney General through the methods outlined at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint. To lodge an appeal with us, you may utilize the following channels:

  • contact@tensixty.com (ensure "VCDPA Appeal" is included in the subject line)

13. Initiating Your Rights Under CPRA and VCDPA

To initiate the rights outlined in this Privacy Policy, you, or an Authorized Agent if you are a resident of California (referred to here as "Authorized Agent"), need to send us a request that both (1) provides adequate information for us to confirm your identity as the individual whose Personal Data we have collected, and (2) details your request with enough clarity for us to comprehend, assess, and address it effectively. We label each request that satisfies these two criteria as a "Valid Request." Requests failing to meet these standards may not receive a response. Information supplied in a Valid Request will be used solely for verifying your identity and fulfilling your request. No account is necessary to make a Valid Request.

We commit to responding to your Valid Request within the timeframe mandated by relevant law. We will not impose a fee for processing a Valid Request unless it is deemed excessive, redundant, or clearly unfounded. If we conclude that your Valid Request necessitates a fee, we will inform you about the fee and provide an explanation before proceeding with your request.

Valid Requests can be submitted through the following channels:

contact@tensixty.com

For California residents, you have the option to designate an Authorized Agent to act on your behalf regarding your rights. You must grant your Authorized Agent written consent to represent you, and we may request to see this authorization when they submit a request in your name.

14. Other State-Specific Privacy Rights

Rights for Residents of California

California's Civil Code Sections 1798.83-1798.84 grant residents of California the right to request that their Personal Data not be shared with third parties for the direct marketing purposes of those third parties. To make such a request, please reach out to us at contact@tensixty.com.

Your web browser might provide a "Do Not Track" feature, enabling you to communicate to website and web application operators your preference against having some of your online behaviors tracked across various sites over time. Currently, our Services do not recognize "Do Not Track" signals. For additional information regarding "Do Not Track," please visit www.allaboutdnt.com.

Rights of Nevada Residents

As a Nevada resident, you possess the right to opt out from the sale of specific Personal Data to third parties that plan to license or sell that Personal Data. To utilize this right, please reach out to us at contact@tensixty.com using the subject line "Nevada Do Not Sell Request," and include your name along with the email address linked to your account.

15. Additional Terms for Users Outside the U.S.

EEA, Switzerland, and UK

For users accessing our Services within the EEA, Switzerland, or the UK (collectively, the "European Region"), the subsequent additional provisions are applicable:

Basis for Data Processing

We process your personal information strictly in accordance with legal requirements. The foundation for processing your personal data, as detailed in this Privacy Policy, includes:

  • Administering, operating, and providing Ten Sixty, including account creation and transaction processing, is grounded in the necessity to fulfill our contractual obligations to you or to take preparatory steps at your request before entering into such a contract.
  • Enhancing user experience on Ten Sixty, informed by user feedback and aimed at service improvement and development, is driven by our legitimate interests in resolving service issues and upgrading service quality.
  • Delivering personalized advertising is based on obtaining your explicit consent to process personal data for tailored advertising experiences.
  • Adhering to legal obligations, including supporting law enforcement and regulatory investigations, necessitates compliance with our legal duties.
  • Communicating with you about service updates, support, and other service-related notices necessitates processing for contract execution.
  • Sending marketing communications is motivated by our legitimate interest in promoting service updates and innovations, subject to obtaining your consent where legally required.
  • Enforcing our terms, conditions, and policies, as well as verifying user age for service access, is essential for the performance of our contract with you.
  • Detecting and preventing abuse, fraud, and illegal activity on Ten Sixty align with our legitimate interest in safeguarding the service's security and integrity.

International Data Transfers

Personal data collected from individuals in the European Region may be transferred to and stored at a location outside of this region, such as with our service providers and partners, under safeguards like the standard contractual clauses approved by the European Commission. For more details on these safeguards, please contact us at contact@tensixty.com.

Your Rights

You are entitled to several rights concerning your personal data, including but not limited to:

  • Requesting confirmation and access to your personal data we hold, at no charge.
  • Correcting, deleting, or limiting the processing of your personal data.
  • Obtaining your personal data in a structured, commonly used format, or having it transferred to another company, under certain conditions (data portability).
  • Withdrawing consent for data processing, without affecting the legality of prior processing.
  • Objecting to decisions based solely on automated processing, including profiling, unless it's necessary for entering into, or performance of, a contract, is authorized by law, or based on explicit consent.
  • Objecting to processing based on our legitimate interests, requiring us to demonstrate compelling grounds for continuation that outweigh your rights and freedoms.
  • Objecting to direct marketing.
  • Lodging complaints with appropriate data protection authorities.

To exercise these rights, verification of your identity or account details may be required. For action on any of your rights, please reach out to us at contact@tensixty.com.

Russia

Legal basis for Processing Personal Data:

Our processing of your personal data is based on various legal grounds, including your consent, the necessity to perform a contract, our legitimate interests, and legal obligations that require us to process personal data.

By registering for and utilizing Ten Sixty, you are giving your consent for us to process your personal data as outlined in this Privacy Policy.

Storage and Transfer of Personal Data

We may transfer and store your personal data from Russia to the United States, where it will be kept outside your resident country.

Brazil

For users accessing our Services within Brazil, additional provisions are applicable in alignment with local data protection laws:

Rights Under Brazilian Law:

Brazilian legislation grants individuals specific rights concerning their personal data. Our aim is to maintain transparency and enable effective access controls, ensuring users can exercise their rights provided by the Brazilian General Data Protection Law (LGPD), including:

  • Verification of personal data processing;
  • Access to personal data;
  • Correction of any incomplete, inaccurate, or outdated data;
  • Anonymization, blocking, or deletion of unnecessary or excessive data;
  • Portability of personal data to another service provider;
  • Objection to the processing of personal data;
  • Information about public and private entities with which we have shared data;
  • The option to not provide personal data and understand the consequences thereof;
  • Withdrawal of consent.

Consent from Minors:

Brazilian law requires that individuals under the age of 18 years must not use the services.

Data Protection Officer (DPO):

For any inquiries directed to our Data Protection Officer, please contact us at contact@tensixty.com.

Additional Country-Specific Provisions

South Korea

For users accessing our Services within South Korea, specific additional provisions are applicable.

Indonesia

By using our Services, you affirm that you are at least 21 years old, married, or not under guardianship. Users under 21 years old, unmarried, or under guardianship must obtain approval from their parent(s) or legal guardian(s).

Other Jurisdictions

Additional specific provisions may apply for users in other jurisdictions including but not limited to: United Arab Emirates, Vietnam, South Africa, Philippines, Egypt, and Mexico. These provisions take precedence over conflicting terms in the main policy text for users in those respective jurisdictions.

16. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

  • Website: www.tensixty.ai
  • Email: contact@tensixty.com
  • Address: Suite 1300, 388 Market Street, San Francisco, CA 94111