Privacy Policy

Privacy Policy

This Privacy & Cookies Policy (the "Policy") dated Nov 22, 2022, replaces all previous policies. Please take the time to review before you continue to use our services.

This Policy applies to any information you provide to us, including through this website, communications by email and through social media, telephone, and in person. It also covers any information we receive from third parties.

By using our products and services, including browsing our websites, registering, or logging in, you agree we may use your information as outlined in this Policy. If you do not wish to have your information used in line with this Policy, you must not use our products and services and not otherwise provide us with your information.

Information we may collect and process about you

  • Information you provide to us, including by way of example only, your username, email address, and date of birth
  • Your IP address
  • Information about services you've clicked on, or shown an interest
  • Information about your interaction with the Platform including any advertisements
  • Information we collect using cookies stored on your device about your use of the Platform and/or selected third-party websites.

How we may use your information

By accessing the Platform, you agree that we may collect, hold, use or otherwise process your information (including personal information) for the purpose of providing you with those products and services you request or access, managing your payments and orders, and developing our business. By providing us with your email address, you agree to receive emails from us or sent on our behalf providing you with messages regarding your account including, but not limited to, purchase confirmations, renewal confirmations and warnings, alerts you may have requested to receive including alerts regarding other user's streaming broadcasts or content submissions), and newsletters. Should you determine to provide an email address, you may change your email address at any time.

Confidentiality and Security

The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at social@tickle.life.

Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

Payment Processing

Please note that we contract with various third parties to carry out payment processing in connection with any purchases you may make through the Platform. The processing and storage of all information you may provide to any such third-party payment processor, including information they may collect from you, is not governed by this Policy. You will need to review the Privacy and Cookie Policy for such third parties on their website.

Fraud Prevention Services

We use third-party services in connection with preventing fraud and other damage to payments. As such we may provide such information to the third party to handle it carefully. This information will be retained indefinitely for the protection of our Platform and users.

NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS

If you sign up to receive promotional materials from us via email, we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at social@tickle.life, we will remove you from our mailing list. 

WHERE WE STORE YOUR PERSONAL DATA

All data you provide to us through the Products is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on Headspace’s servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and suggest that your change your password frequently.

Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

YOUR DATA RIGHTS

As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are: A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.

This California Consumer Privacy Act (“CCPA”) Addendum for California residents supplements the information contained in the above Privacy Policy and applies solely to all visitors, users and others who reside in the State of California. We adopt this CCPA Addendum to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Addendum.

  1. INFORMATION WE MAY COLLECT FROM YOU

Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, whether collected online or offline (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:

CATEGORY EXAMPLES COLLECTED

Identifiers First and last name       Yes

email address

Internet Protocol address

online identifiers

Personal information First and last name.       Yes

categories listed in the

California Customer Records statute

(Cal. Civ. Code § 1798.80(e)).

The specific types of personal information we collect. Personal information does not include: (1) deidentified or aggregated consumer information; (2) publicly available information from government records; or (3) information excluded from the CCPA’s scope.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms, you complete when registering for the Products. Indirectly from you. For example, from observing your actions on our Products.

YOUR RIGHTS AND CHOICES

Access to Specific Information and Data Portability Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The categories of personal information we share with third parties.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.

We may deny your deletion request if certain CCPA exemptions applies, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. Exercising Access, Data Portability, and Deletion Rights to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
  • Emailing us at help@tickle.life

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Response Timing and Format 

Upon receiving a request for access, portability, refund, or deletion, we will confirm receipt of the request within 10 business days and provide information about our verification process and how we will process the request.