LAST UPDATED: 17 November, 2020
Vertical Craft, which includes its products, services, subsidiaries, and affiliates (together, “Tully,” “we”, “us” or “our”) is committed to data protection and data privacy. We would like to inform you, as the users of our mobile applications, websites, products, services, and content, about the way we use data that is collected from you.
If you have any questions about this document, please refer to Section I. 7. for contact details.
- ACCEPTANCE OF THIS POLICY
- Tully is committed to acting responsibility and transparently when handling your personal information. To operate our applications and services, we need to collect information such as your name, email address, and phone number. We do not collect information for any other purpose than to facilitate your use of Tully.
- BY VISITING TULLY, USING ITS SERVICES, ITS PRODUCTS, OR INTERACTING WITH ANY PART OF IT, INCLUDING ITS WEBSITES, YOU FULLY ACCEPT THIS POLICYAND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER, AND PROCESSING OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY.
- COLLECTION OF INFORMATION
- Tully collects information about you in an effort to administer your account, manage your transactions, and protect your assets and identity on the platform.
- Among the reasons we may collect information is the need to analyze usage, allow support through customer care, allow the creation of new features and functions, and to comply with appropriate laws and regulations.
- TYPES OF INFORMATION COLLECTED
- Information We Acquire from You Directly.
- Subscriber Information. Subscriber information may contain Personal Information. We collect your subscriber Information when you provide it to us when you complete a registration form on Tully or otherwise interact with, engage in, or communicate with Tully. The disclosure of your Personal Information is completely voluntary and we will only collect subscriber Information with your consent. However, once you register with us, you are no longer anonymous to us. We may retain your information for a number of reasons including: for as long as you choose to maintain an active account, as long as we provide you services, as long as our legal obligations require us to do so, or as long as needed to resolve disputes or to enforce our agreements. To the extent that we combine any supplementary Information with the information you provide, it will be considered to be part of your subscriber Information.
- User Generated Content. You may use Tully to store files and content that is personal to you including lyric sheets, images, audio and video files. You own and control all content that you generate and store. Tully does not own or control your content and does not have access toit except for the sole purposes of providing products and services to you.
- HOW YOUR INFORMATION IS USED
- As needed, we may use, aggregate, and retain the information that we collect about you.:
- To allow you access to your content and files .
- To provide you with products, services, or information that you request or access, some of which may be accessible for a fee or by subscription.
- To communicate with you generally or to communicate about products and services from Tully or to invite you to join us on social media platforms on which you may participate.
- For any other reasonable and legitimate business purpose that we tell you about when you give us the information.
- By way of example, we analyze information collected from you to:
- Help us recognize your device as a previous visitor, and save and remember any preferences that you may have.
- Help us improve our products and services.
- Identify trends, statistics, and measurements that could contribute to the enhancement of our products and services.
- HOW IS YOUR INFORMATION SHARED
- Service Providers. Tully may provide your Personal Information to certain Service Providers who are working for or with Tully, as described in this Policy, and who require access to such information to facilitate the provision of services, such as the provision of data storage or processing activities. Tully will always attempt to limit the submission of your Personal Information to what is reasonably sufficient and necessary for the Service Providers to carry out their responsibilities relating to the fulfillment of their services.
- Other. We may also share the information that we collect for reasonable and legitimate business interests and for the following purposes:
- Compliance with Applicable Laws. We may disclose the information that we collect to a third party where we are legally required to do so in order to comply with any applicable laws, regulations, legal processes, or government requests, including to meet national security or law enforcement requirements.
- Vital Interests and Legal Rights. We may disclose the information that we collect where we believe that it is necessary in order to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.
- Business Transactions. We may share or transfer the information that we collect in connection with, or during negotiations of, any merger or acquisition of any part of our business, sale of company assets, or financing.
- Your Specifically Consent. We may share the information that we collect in other ways to which you specifically consent.
- DATA RETENTION
- Tully will retain your Personal Information while your subscription is in existence or, as needed, to provide you with products or services.
- We may retain your Personal Information after you have cancelled your subscription if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between subscribers, prevent fraud and abuse, or enforce this Policy and our Terms and Conditions.
- We may also retain Personal Information, for a limited period of time if requested by law enforcement.
- PROTECTING YOUR INFORMATION
- Tully takes the security of the data that it collects very seriously.
- Tully has implemented a myriad of technical, organizational, and administrative measures, which are generally accepted by the industry, to protect the Personal Information in its possession. These measures include, but are not limited to, the implementation of current security technologies and processes to protect your information from loss or misuse and from unauthorized access, disclosure, alteration, or destruction. In particular, our security systems include authenticated access to internal databases, regular audits of processes and procedures, scheduled reviews of overall web security, and restricting access to Personal Information in our possession. Additionally, we use encryption (HTTPS/TLS) to protect data transmitted to and from our websites.
- YOUR PRIVACY RIGHTS
- Unsubscribing from Tully Emails. Following the registration process, you may at any time choose to unsubscribe from our emails, while retaining access to our fee or subscription-based content. Every email sent by or on behalf of Tully includes information as to how you can easily unsubscribe from such future communications. You may also unsubscribe from all or some of Tully emails by updating your account settings with Tully.
- Deletion of Subscription. You may request to have your subscription deactivated and your information erased by emailing us at email@example.com. Although Tully may deactivate your registration or subscription pursuant to your request, it may continue to retain your information for reasonable and legitimate business purposes and as stated in this Policy.
- EUROPEAN UNION GENERAL DATA PROTECTION REGULATION
If you are an EU resident and would like to request that your data be securely removed from our systems, however collected, please send an email with proof of EU residency to firstname.lastname@example.org. We will remove all relevant data, so long as that removal is technically feasible, does not impact our legitimate accounting or business practices, does not impede or restrict the rights of our other users, and does not violate other regulatory or legal standards with which we must comply.
- GENERAL PROVISIONS
- Third Party Websites. Some of the products or services made available through Tully may be hosted on the website of Partners. This means that when you are on a Tully website and click through to access those products or services, you may leave Tully and be redirected to the site of the Partners, at which time you will be subject to the policies of the Partners. Tully is not responsible for the privacy practices or the content of any of the Partners. You must review the privacy statements of each website you visit that collects information. This Policy applies only to information collected on Tully.
- Domestication and International Requests. Any person issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) to Tully shall properly domesticate the process or request and then serve Tully in a jurisdiction where Tully is resident or has a registered agent to accept such service on its behalf. Tully does not accept legal process or requests directly from law enforcement entities outside the U.S. or Canada. Foreign law enforcement agencies should proceed through diplomatic or legal means to obtain data through a court where Tully is located.
- Translations. The English language version shall prevail. Any translations of this Policy are provided for convenience only.
- Children. We do not solicit or knowingly collect any personal information from children under the age of 13 without verifiable parental consent. If you are not 18 or older, you are not authorized to interact with Tully. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If you learn that a child under 13 has provided us with personal information without consent, please contact us. In addition, parents may use the following tips to help safeguard a child’s online experience: Teach children never to give out personal information, unless supervised by a parent or responsible adult, this includes their name, address, phone number, school, etc.; Know the sites your children are visiting and which sites are appropriate; Look for and understand privacy policies that govern websites that your child visits and know how your child’s information is being treated.
- This Policy was drafted with transparency, accuracy, and clarity in mind. However, it does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Requests should be sent to the address below.
Care of: Vertical Craft, Inc.
5688 Windhover Drive, Suite 3
Orlando, Florida 32819