App Privacy Notice

Last update 09.17.2021

Tickle respects your privacy. Our Privacy Notice explains our practices relating to the collection, use, and disclosure of information, including personal information which we may collect from time to time. Tickle is committed to ensuring that your information is stored safely and responsibly. We are committed to complying with privacy laws that apply to us.

BY USING THE SERVICE, YOU PROMISE US THAT YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY Notice, AND YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY NOTICE FOR YOU). 

If you do not agree, or are unable to make this promise, you must not use the Service. In such a case, you must delete your account using the functionality found in "Profile" in the App, or contact us by email reports@trcomplete.com and request deletion of your data and cancel any subscriptions using the functionality provided by Apple and delete the App from your devices.

Short overview of the Privacy Notice:

We are Turing Complete Inc., 8 the green suite #11287, Dover, DE 19901, USA. We collect two types of information: by which you may be personally identified and technical one. We share your data to our employees and specific services which provide technical support and analytical  tools. You have next rights: to be informed, to access and correct your personal information, to delete your data. We store your data during the performance of the contract and 12 months after.

Context:

  1. Who are we?

  2. What this Notice applies for?

  3. What types of data do we process?

  4. Do we share your personal information with third parties?

  5. How do we collect your personal information?

  6. Accessing and correcting information

  7. Privacy Rights (the USA laws)

  8. How do we update Privacy Notice?

  9. Information for the individuals in Switzerland, the UK, and EEA.

    1. Legal basis for processing personal data

    2. How do we protect your personal data?

    3. How long do we store your personal data?

    4. What rights do I have?

1. Who are we?

We are Turing Complete Inc., 8 the green suite #11287, Dover, DE 19901, USA hereinafter, Tickle will be referred to as “we” and “ours”. We are the controller of personal data, which means that we define which, for what purpose, and how your personal data will be processed.

If you have any questions, you can contact us by sending an email to info@trcomplete.com. You can also send us a letter at the address: Turing Complete Inc., 8 the green suite #11287, Dover, DE 19901, USA 

 

2. What this Notice applies for? 

This Notice deals with:

  • the types of information that we may collect from you when you access or use our Mobile App; and

  • our practices for collecting, using, maintaining, protecting, and disclosing that information. This Notice applies only to information we collect through our Mobile App and in the electronic communications sent through or in connection with our Mobile App.

 

3. What types of data do we process? 

We collect two types of information from and about our Users, including information:

  • by which you may be personally identified; and/or

  • about your internet connection, the equipment you use to access our Mobile App, and your usage details.

The information we collect on or through our Mobile App may include:

  • User Account information: Your full name, email address, and other information you may provide with your account  that may be displayed as a part of your User Account;

  • Preferences: Your preferences and settings such as time zone and language;

  • Searches and other activities: The search items you have looked up and results you have selected;

  • Browsing information: How long you used our Mobile App, which features you used, etc.;

  • Technical information: When you visit our site, some data is collected automatically. We need technical data to operate, maintain, and improve our website. This includes data such as IP address, UTM parameters, geolocation, device type

  • Communications: Between you and Tickle with the support staff regarding the Mobile App and your use of the Mobile App.

  • Posts: You also may provide information (likes, ratings, reviews, images, photos, comments, etc.) to be published or displayed on publicly accessible areas of the Mobile App.

  • Information from third parties: We may collect, process, and store your user ID associated with any social media account (such as your Apple, Snapchat and Google account) that you use to sign in to the Mobile App or connect with or use with the Mobile App. This could include, without limitation, any information that you have made public through a given social media account of yours.

4. Do we share your personal information with third parties?

We use other companies, contractors, and/or agents to provide services to you including but not limited to marketing, communications, legal services, customer services, information technology providers. The third parties to whom we disclose personal information may be located within or outside the United States.

In general, the third-party providers used by us will only collect, use, and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers have their own privacy policies. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

So if you elect to proceed with a transaction that involves the services of a third-party service provider (like registration), then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

Hereunder You can find a more detailed list of some third parties - service providers with whom we may share your personal information as described above, along with links to such service providers privacy policies, which we recommend You read:

We use Amazon Web Services (“AWS”), which is a hosting and backend service provided by Amazon, for personal data hosting and enabling our Application to operate and be distributed to its users.

You can learn more about the Amazon Privacy Notice here: AWS Privacy Notice and Data Privacy FAQ.

We use Snapchat for these purposes: to register or enter the mobile application by you. You can learn more about the Snapchat Privacy Notice here: Privacy Center.

We use Google for these purposes: to register or enter the mobile application by you. You can learn more about the Google Privacy Notice here: Privacy Notice.

5. How do we collect and use personal data:

How we collect and store information depends on the pages you are visiting, the activities in which you elect to participate. For example, you may be asked to provide information when you register for access to certain portions of our Mobile App, create a User account, request certain features, or when you communicate with us. Like most Mobile Apps, Tickle also collects information automatically and through the use of electronic tools that may be transparent to our visitors and Users. For example, we may log the name of your Internet Service Provider or use “cookies” technology to recognize you and hold information from your visit. As we use additional technologies, we may also gather information through other means.

Where you provide us information about a third party, you must have the consent of that third party before providing us with that information. By providing us with information regarding a third party you warrant that you have their permission to provide that information to us.

6. Accessing and correcting information

You can make a request to receive the Personal Information related to you through the 'Profile' menu of this Application. Also, you can  make a request by writing to our email address:  info@trcomplete.com

We take reasonable steps to accurately record the personal information that you provide to us, as well as any subsequent updates. We encourage you to review, update, and correct the personal information that we maintain about you. 

You may request that we delete personal data about you that is inaccurate, incomplete, irrelevant for legitimate purposes, or is being processed in a way which infringes any Mobile Applicable legal requirements.

If you would like to review, change or delete personal data we have collected from you or you had submitted or permanently delete your account, please contact us through the App or by email: info@trcomplete.com.

7. Privacy Right (the USA laws)

You, as subjects of personal data, have some specific privacy rights. To exercise them, write us an email at privacy@avitar.legal.

Your rights vary depending on the laws that apply to you, but may include:

  • The right to be informed about the personal data we collect and/or process about you;

  • The right to learn the source of personal data about you we process;

  • The right to access, modify, and correct personal data about you;

  • The right to know with whom we have shared your personal data with, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);

  • The right to withdraw your consent, where processing of personal data is based on your consent; and

  • The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

Please see more detailed information about your State law in a separate section at the end of this document.

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Virginia’s Consumer Data Protection Act

Right to Know whether the controller is processing a customer’s personal data.
Right to Access personal data processed by the controller.
Right to Correct.
Right to Delete.
Right to Data Portability.
Right to Opt Out of targeted advertising, the sale of personal data or profiling.
_
Consumer Privacy Act (CCPA) and  California Privacy Rights Act

Right to Know what personal information is collected and Right to Access personal information.
Right to Know if Personal Information is Sold.
Right to Delete. subject to certain exceptions.
Right to Data Portability.
Right to Correct.
Right to Opt Out of Sale.
Right to Limit Use and Disclosure of Sensitive Personal Information.
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Colorado Privacy Act

Right of Access.
A customer has the right to confirm whether the controller is processing Personal data concerning the customer and to access such data.
Right to Correction.
Right to Deletion.
Right to Data Portability.
Right to Opt out of targeted advertising, the sale of personal data, or profiling via a universal opt-out mechanism.
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Nevada Privacy Law

Right to Know whether the controller is processing the customer’s personal data.
Right to Opt Out of Sale.
Right to Correct.
_
Delaware Online Privacy and Protection Act

Right of Access.
Right to withdraw a consent.
Right to Correction.
Right for “do not track” request.
Right to Opt Out of Sale.

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8. How do we update Privacy Notice?

This privacy notice and the relationships falling under its effect are regulated by the laws of the state of Delaware. Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy notice on our website. If significant material changes are made that affect your privacy and confidentiality, we will notify you by email or display information in the Mobile App and ask for your consent.

8. Information for the individuals in Switzerland, the UK, and EEA

If you are visiting and using the Services from the European Economic Area ('EEA'), please be aware that you are sending information (including personal data) to the United States where our partner platform’s servers are located. Our partners and/or staff operating outside the EEA may process this information. The information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how we store it. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal data will at all times continue to be governed by this Privacy Notice. Mobile App and this Privacy Notice were developed with accordance with GDPR standards.

8.1 Legal basis for processing your personal data

8.1.1

Description of why we process your personal data:
To provide you access to App.

Legal basis:
Performance of a Contract..

Categories of personal data:
User Account information;
Preferences;
Searches and other activities;
Browsing information;
Communications;
Posts;
Technical information.

 

8.1.2
Description of why we process your personal data:
Safety and security.

Legal basis:
Legitimate interest.

Categories of personal data:
Technical information;
User Account information;
Communications.


8.1.3
Description of why we process your personal data:

Customer Support.

Legal basis:
Performance of a Contract.

Categories of personal data:
User Account information;
Communications.


8.1.4
Description of why we process your personal data:

Compliance with legal obligations.

Legal basis:
Compliance with legal obligations.

Categories of personal data:
Communications;
User Account information;
Searches and other activities.


8.1.5
Description of why we process your personal data:

Research and development.

Legal basis:
Legitimate interest.

Categories of personal data:
Preferences;
Searches and other activities;
Browsing information;
Posts;
Technical information.


8.1.6
Description of why we process your personal data:

Marketing.

Legal basis:
Consent.

Categories of personal data:
User Account information.


8.2 How do we protect your personal data?

We have implemented Mobile Appropriate measures in the form of various technical, physical, and other means, including, but not limited to measures regarding the security of our electronic systems and databases, locks, and other devices and access controlling systems, including limited access and strong password policy. These means aim at improving the integrity and security of the personal information that we collect and maintain. However, please be advised that even the best security measures cannot guarantee the full elimination of all risks. 

If we learn of any violation, breach or danger to our security systems breach, then we will attempt to notify you electronically so that timely and Mobile Appropriate protective steps can be taken. Apart from informing you via email, we may post a notice through the Mobile App via pop-up if a security breach occurs.

 

8.3 How long do we store your personal data?

We store your data during the performance of the contract and for 12 months after. However, you can exercise your right to delete your data. In this case, your data will be deleted from our servers within 30 days after your request.

8.4 What rights do I have?

You, as subjects of personal data, have the following rights:

  • The right to access information. You can request an explanation of the processing of your personal data.

  • The right to portability. You can request all the data that you provided to us, as well as request to transfer data to another controller.

  • The right to restrict processing. You may partially or completely prohibit us from processing your personal data.

  • The right to file complaints. If your request was not satisfied, you can file a complaint to the regulatory body, the Office for Personal Data Protection.

  • Right to be forgotten. You can send us a request to delete your personal data from our systems.

To exercise your rights, write us an email at reports@trcomplete.com

Also you can contact our EU representative Avitar s.r.o., with registration number 48012386, having its registered address at: Šancová 4007/48, Bratislava, SLOVAKIA. Also you can contact them via email privacy@avitar.legal.

If your request was not satisfied, you can file a complaint to the regulatory body, the Office for Personal Data Protection of the Slovak Republic, adress: Hraničná 12, 820 07 Bratislava 27, Slovak Republic.

Region-specific legislation

California legislation

We put here information for residents of California to provide you with more information about legislation and your privacy rights granted by the California Customer Privacy Act (CCPA) and  California Privacy Rights Act.

Opt-out of disclosure for direct marketing purposes. The California laws allow its residents to learn the identities of entities that received their personal data for marketing purposes and the categories of information disclosed. You may request such information by contacting us by e-mail privacy@avitar.legal. Please be aware that this opt-out does not prohibit our disclosure of personal data for any purpose other than direct marketing. The data we process and share may include your name, address, email address, and telephone number.

Automatic gathering of information. We collect data that you provide to us online, and through websites of unaffiliated third parties.

Automatic gathering of information by third parties. When you visit our websites, third parties can collect personal data about your online activities over time and across different websites pertaining to your visit to or use of our and other websites.

Minors. A business shall not sell the personal information of customers if the business has actual knowledge the customer is less than 16, unless the customer, in the case of customers at least 13 and less than 16, or the customer’s parent or guardian, in the case of customers who are less than 13, has affirmatively authorized the sale of the customer’s personal information. A business that willfully disregards the customer’s age shall be deemed to have had actual knowledge of the customer’s age. This right may be referred to as the “right to opt-in.” A business that has not received consent to sell the minor customer’s personal information shall be prohibited from selling the personal information unless the customer subsequently provides express authorization.

Do-not-track requests. California residents visiting our websites may request that we do not automatically gather and track information pertaining to their online browsing movements across the Internet. Such requests are typically made through web browser settings that control signals or other mechanisms that provide customers the ability to exercise choice regarding the collection of personal data about an individual customer's online activities over time and across third-party websites or online services. We currently do not have the ability to honor these requests. We may modify this Notice as our abilities change.

California residents’ data protection rights. The California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act provides our users who are California residents the following additional rights:

  1. Right to Know: You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:

    • The categories of personal data collected about you;

    • The categories of sources from which we collected your personal data;

    • The categories of personal data that we have sold or disclosed about you for a business purpose;

    • The categories of third parties to whom your personal data was sold or disclosed for a business purpose;

    • Our business or commercial purpose for collecting or selling your personal data; and

    • The specific pieces of personal data we have collected about you.

  2. Data Portability: You have the right to request a copy of personal data we have collected and maintained about you in the past 12 months.

  3. Right to Deletion: You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal data, we may deny your request or may retain certain elements of your personal data if it is necessary for us or our service providers to:

    • Complete the transaction for which the personal data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.

    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

    • Debug to identify and repair errors that impair existing intended functionality.

    • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

    • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

    • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

    • Comply with a legal obligation.

    • Otherwise use the personal data, internally, in a lawful manner that is compatible with the context in which you provided the information.

  4. Right to Opt-Out/In: You have the right to opt-out of the sale of your personal data. You also have the right to opt-in to the sale of personal data. However, we do not sell your personal data.

  5. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services.

    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

    • Provide you a different level or quality of goods or services.

    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

You can exercise these rights any time by contacting us via email at privacy@avitar.legal 

Notice, the CCPA envisages some specific requirements related to the exercising of these data protection rights. Considering them we may:

  • respond to your request within forty-five (45) days of receiving the request;

  • provide you with personal data we collected about you no more than twice in a 12-months period (categories and specific pieces of collected personal data, business purpose and sources of collection, categories of third parties personal data is shared with);

  • NOT provide you with personal data if we cannot verify your identity. You shall provide us with sufficient information allowing us to verify you as the person about whom we collected personal data. However, we do consider requests made through your Account sufficiently verified.

  • NOT transmit your personal data to another entity.

Also, please be aware that we are allowed to maintain personal data after deletion requests are received as permitted by the CCPA (for instance, for the purposes of detection of security incidents, repair errors, compliance with legal obligations, transaction completion).

We want to draw your special attention that Tickle does not sell, rent, or trade your personal data to anyone.We will not discriminate against you if you choose to exercise your rights under the CCPA.

We are accessible to customers with disabilities. Customers with disabilities may also contact us by emailing to request an alternative format of this Privacy Notice.

Virginia Legislation

We put here information for residents of Virginia to provide you with more information about legislation and your privacy rights granted by the Virginia’s Customer Data Protection Act.

The VCDPA obliges some businesses to give consumers the ability to access and control personal data that the business collects about them. 

Minors. Controllers and processors that comply with the verifiable parental consent requirements of COPPA shall be deemed compliant with any obligation to obtain parental consent under the CDPA.

A known child’s parent or legal guardian may invoke customer rights on behalf of the child regarding processing personal data belonging to the known child.

No Discrimination. A controller cannot process personal data in violation of state and federal customer anti-discrimination laws or discriminate against a customer for exercising rights under the CDPA.

Access Requests.  Controllers are required to establish and describe in a privacy notice one or more secure and reliable means for customers to submit a request to exercise their rights. The method used needs to consider how customers normally interact with the controller, the need for secure and reliable communication of such requests, and the ability of the controller to authen- ticate the requests.

Controllers are prohibited from requiring a customer to create a new account in order to exercise their customer rights but may require a customer to use an existing account.

Response time. Controllers are required to respond to customer requests within 45 days. This time period may be extended once by 45 additional days if certain requirements are met.

No charge for information. Controllers are required to provide information in response to a customer request free of charge, up to twice annually per customer. The controller may charge the customer a reasonable fee or decline to act on the request if requests are manifestly unfounded, excessive or repetitive, but the burden of demonstrating the manifestly unfounded, excessive or repetitive nature of the request is on the controller.

Right to opt out. Virginia residents visiting our websites may request  to Opt Out of targeted advertising, the sale of personal data or profiling. Virginia laws allow its residents to learn the identities of entities that received their personal data for marketing purposes and the categories of information disclosed. You may request such information by contacting us by e-mail privacy@avitar.legal 

Colorado Legislation

We put here information for residents of Colorado to provide you with more information about legislation and your privacy rights granted by Colorado Privacy Act.

Minors.  A controller shall not process the personal data of a known child without first obtaining consent from the child’s parent or lawful guardian.

Access Requests. Customers may exercise their rights by submitting a request using a method specified by the controller in the required privacy notice. The method must take into account: 

  1. the ways in which customers normally interact with the controller; 

  2. the need for secure and reliable communi- cation relating to the request; and 

  3. the ability of the controller to authen- ticate the identity of the customer making the request.

Controllers shall not require a customer to create a new account in order to exercise customer rights. However, a controller may require a customer to use an existing account.

Response time. In short: 45 days to respond. Controller shall inform a customer of any action taken on a request within 45 days. In certain circumstances, this 45-day window to respond may be extended by an additional 45 days.

No charge for information. Controllers are required to provide the information requested free of charge once per year. For additional requests within a 12-month period, the controller may charge an additional amount.

Justification for failure to act. If a controller does not take action as requested by a customer, the controller shall inform the customer within 45 days after receipt of request of the reasons for not taking action and instructions for how to appeal the decision.

Denial of requests. Controller is not required to comply with a request to exercise any of the customer’s rights if the controller is unable to authenticate the request using commercially reasonable efforts and may request the provision of additional information reasonably necessary to authenticate the request.

Right to appeal. Controller shall establish an internal process whereby customers may appeal a refusal to take action on a customer request. Where a customer wishes to appeal, they must do so within a reasonable time period after the controller notifies them that the controller is denying the request. The appeal process must be conspicuously available and easy to use.

Responding to an appeal. Controller shall inform the customer of the result of the appeal as well as provide written explanation of the reasons in support of the outcome within 45 days of receipt of the appeal. This 45-day period may be extended by an additional 60 in certain circumstances.

 

 

Delaware legislation

We put here information for residents of Delaware to provide you with more information about legislation and your privacy rights granted by the Delaware Online Privacy and  Protection Act.

Advertising to children. DOPPA regulates operators only as far as they provide services or platforms that are 'targeted or intended to reach an audience that is composed predominantly of children. However, this does not include services or platforms that merely refer or link to another service or platform that is directed at children. 

Operators can also be liable under DOPPA if, despite not directing their services or platforms to children, they have actual knowledge that children are accessing the services or platforms. In such an event, an operator cannot knowingly use, disclose, or compile the personal information of that child, nor can an operator allow another to do the same. An operator that provides a covered service or platform cannot advertise or market content that is inappropriate for children. In this regard, DOPPA provides an enumerated list of prohibited content, including alcohol, tobacco, firearms, fireworks, tanning equipment and facilities, lotteries and gambling, tattoos, drug paraphernalia, and pornography. It should be noted that an operator need not monitor the foregoing if it is using an advertising service and it ensures that such service is complying with DOPPA.

Do-not-track requests. Delaware residents visiting our websites may request that we do not automatically gather and track information pertaining to their online browsing movements across the Internet. Such requests are typically made through web browser settings that control signals or other mechanisms that provide customers the ability to exercise choice regarding the collection of personal data about an individual customer's online activities over time and across third-party websites or online services. We currently do not have the ability to honor these requests. We may modify this Notice as our abilities change.

Nevada Legislation

 

We put here information for residents of Nevada to provide you with more information about legislation and your privacy rights granted by Nevada privacy law ​​Senate Bill 220.

Opt-out of the sale. Nevada allows consumers to opt-out of the sale of “covered information” collected through a website or online service. Under the law, “covered information” includes:

  • A first and last name. 

  • A home or other physical address, which includes the name of a street and the name of a city or town. 

  • An electronic mail (email) address. 

  • A telephone number. 

  • A social security number. 

  • An identifier that allows a specific person to be contacted either physically or online. 

  • Any other information concerning a person collected from the person through the operator’s Internet website or online service and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable. 

 

Do-not-sell request. Nevada does not require entities to include a “Do Not Sell My Personal Information” button or link on their websites. Instead, it mandates that entities provide consumers with an email address, a toll-free telephone number, or an Internet website to submit verified opt-out requests.

Response time. Upon receiving a “verified consumer request,” a business has 45-days, with a possible 90-day extension when “reasonably necessary” and by providing notice to the consumer, for a total of 135 days.