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.
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.
Below is a chart that outlines the types of Personal Information we collect, including information collected in the past 12 months:
Third-Party Recipients: Service Providers, Marketing Partners, Data Analysis Firms, Business Allies, Authorized Third Parties
Third-Party Recipients: Service Providers (notably our payment processor, currently Stripe, Inc.)
Third-Party Recipients: Authorized Third Parties
Third-Party Recipients: Marketing Partners, Data Analysis Firms
Third-Party Recipients: Marketing Partners, Data Analysis Firms, Authorized Third Parties
Third-Party Recipients: Service Providers, Data Analysis Firms, Authorized Third Parties
Third-Party Recipients: Service Providers, Marketing Partners, Data Analysis Firms
Third-Party Recipients: Service Providers, Data Analysis Firms, Business Allies, Authorized Third Parties
Third-Party Recipients: Service Providers, Marketing Partners, Data Analysis Firms
We gather Personal Information from the following sources:
When you directly provide us with information:
As you interact with the Services, information is automatically collected:
From governmental entities or other public sources.
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.
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.
These entities assist in delivering our Services or executing business operations on our behalf, including:
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.
These entities support us in marketing our services and presenting you with offers that might interest you, including:
These entities analyze the traffic and usage of our Services, including:
These entities collaborate with us to provide various services, including:
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.
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.
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.
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:
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.
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.
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.
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."
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.
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/.
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.
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:
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.
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.
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:
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.
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.
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.
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.
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.
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.
You have the right to confirm whether we are processing your Personal Data and to access it.
You can correct inaccuracies in your Personal Data, appropriate to the data's nature and our processing purposes.
You are entitled to receive a copy of your Personal Data in a machine-readable format, where technically feasible.
You have the right to have your Personal Data deleted.
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:
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:
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.
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.
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.
For users accessing our Services within the EEA, Switzerland, or the UK (collectively, the "European Region"), the subsequent additional provisions are applicable:
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:
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.
You are entitled to several rights concerning your personal data, including but not limited to:
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.
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.
We may transfer and store your personal data from Russia to the United States, where it will be kept outside your resident country.
For users accessing our Services within Brazil, additional provisions are applicable in alignment with local data protection laws:
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:
Brazilian law requires that individuals under the age of 18 years must not use the services.
For any inquiries directed to our Data Protection Officer, please contact us at contact@tensixty.com.
For users accessing our Services within South Korea, specific additional provisions are applicable.
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).
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.
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: