(i) Navigation on the site www.tenni.app
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Early signup form
Name, E-mail
Legitimate Interests
10 years from the last access
PW9
(ii) Usage of the mobile app “TENNI”
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Creating account, login and management of your profile and role
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA1, PA11
Making a user member of a private club
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA2
Making a reservation
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA3
Organizing public matches (name, surname and statistics will be visible to other users)
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA4
Providing a group chat related to the match
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA5
Organizing classes
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA6
Organizing tournaments
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA7
Accessing your mobile agenda to (i) invite your contacts to join activities (tournaments and matches) (ii) find friends already registered in Tenni with the purpose to add them to activities and to your community. The data will not be stored in our system; by giving the consent, you also confirm to have the authorization of your friends to share their data with Tenni.
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Consent
Up to the withdrawal of the consent
PA7.1
Providing a private chat service between users
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA8
Calculating and publishing the ranking of the user
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Consent
Up to the withdrawal of the consent
PA9, PA10
Allow club managers to access the chat related to the matches for organizational reasons
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Consent
Up to the withdrawal of the consent
PM3, PM4
Purchase of a premium profile by the user (the person will be identifiable as a premium user by means of a specific indicator)
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA12
In public activities, the phone number of the organizer will be shared with people enrolled in the specific activity.
Name, Surname, Image, Gender, E-mail, Phone number, Level (PA1), Fitness evaluation (PA2), Credit Card information (PA2 – PA3 – PA4), Agenda (PA7.1), Level / Ranking (PA8 – PA9 – PA10)
Execution of a contract
10 years from the last access
PA13
(iii) Marketing purposes
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Marketing communications
Name, E-mail, User behavior data (M2)
Consent
Up to the withdrawal of the consent
M1
Analysis of users behavior
Name, E-mail, User behavior data (M2)
Consent
Up to the withdrawal of the consent
M2
Sending random questionnaires
Name, E-mail, User behavior data (M2)
Consent
Up to the withdrawal of the consent
M3
Data transfer to social networks (e.g. Facebook, Instagram, X(Twitter) etc) for sending, on behalf of Tenni, commercial or advertising communications to the customers.
Name, E-mail, User behavior data (M2)
Consent
Up to the withdrawal of the consent
M4
Social Media Marketing (Interaction with the customers on the Facebook and Instagram fan page of Tenni). Please consider that, with reference to the function “Insight” of Facebook, related to your visit statistics, we are joint controller with Facebook Ireland Limited (“Facebook Ireland”).
Name, E-mail, User behavior data (M2)
Consent
Up to the withdrawal of the consent
M5
(iv) Notifications
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Social Media Marketing (Interaction with the customers on the Facebook and Instagram fan page of Tenni). Please consider that, with reference to the function “Insight” of Facebook, related to your visit statistics, we are joint controller with Facebook Ireland Limited (“Facebook Ireland”).
Name, Surname, E-mail, Phone number
Consent
Up to withdrawal of the consent
NE
Under consent, Tenni will send to your device push communications related to your Tenni experience. The notifications will be delivered in the case an event occurred in relation to (i) Booking (ii) Chat (iii) Matches (iv) Community interactions
Name, Surname, E-mail, Phone number
Consent
Up to withdrawal of the consent
NP
Under consent, Tenni will send to your phone number SMS communications related to your Tenni experience. The notifications will be delivered in the case an event occurred in relation to (i) Application process (ii) Booking
Name, Surname, E-mail, Phone number
Consent
Up to withdrawal of the consent
NS
(v) Customer success
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Customer support via chat
Name, E-mail, Phone number
Execution of a contract
10 years from the last access
CS1
Customer experience (through random questionnaires)
Name, E-mail, Phone number
Consent
Up to withdrawal of the consent
CS2
Whatsapp and Telegram Communications
Name, E-mail, Phone number
Consent
Up to withdrawal of the consent
CS3
(vi) Community
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Supply of a social platform for autonomous interaction between users
Name, City, Social interactions (Comments, likes, tags)
Execution of a contract
Until the user asks for the removal of the account
COM1
Automatic sharing of contents
Name, City, Social interactions (Comments, likes, tags)
Consent
Up to withdrawal of the consent
COM2
(vii) Other processings generally applicable
PURPOSE
CATEGORIES OF PERSONAL DATA
PRINCIPLE OF LAWFULNESS
PERIOD OF STORAGE
REFERENCE ON RECORDS OF PROCESSING ACTIVITY
Research and Development of new products / features
Name, Surname, E-mail, Phone number
Legitimate interest
Until the conclusion of the intervention
RD1
Maintenance, operation and security of IT services
All your personal data
Legitimate interest Legal obligation
Until the conclusion of the intervention
CT1
Identification, analysis and management of company data for a proper performance of the business
Name, Surname, E-mail
Legitimate interest
Until the conclusion of the intervention
B1
Furthermore, please take in due consideration the following information:
DATA PROVISION
In all those cases in which we ask for consent to the processing of your personal data, their provision is purely optional. Consequently, failure to provide your personal data will have no consequences, other than in terms of the impossibility of processing the data for such specific purposes. In all other cases where we do not ask for consent to the processing of your personal data, their provision is mandatory and necessary to comply with contractual or legal provisions and for the purpose of the proper conduct of business. Consequently, failure to provide such information would not make it possible to comply with these requirements and to carry out business activities properly.
CATEGORIES OF RECIPIENTS
In addition to the Data Processors above mentioned, your personal data will be shared with: (i) the club managers related to your booking; (ii) subsidiaries and affiliates companies.
AUTOMATED DECISION- MAKING PROCESS
There are no automated decision-making procedures.
TRANSFERS EXTRA EU OR TO INTERNATIONAL ORGANIZATIONS
Some Data Processors, in providing their services to the Data Controller, may transfer your personal data to servers located in non-EU territory. Please note that not all non-EU countries guarantee the same European safety standards; by giving consent to the processing of your data, where applicable, you also consent to their transfer to servers located in these territories.
LEGITIMATE INTEREST OF DATA CONTROLLER
The legitimate interest of the Data Controller indicated for the following purpose: (i) Facilitation in navigation / cookies (ref.PW8): is the correct and fluid operation of the site; (ii) Research and Development of new products / features (ref. RD1) and Identification, analysis and management of company data for a proper performance of the business (B1): is the ordinary interest in the evolution of the company; (iii) Maintenance, operation and security of IT services (ref. CT1): is the proper and safe conduct of the business activity.
SOURCE ORIGINATING THE DATA
Your data could be provided by subsidiaries or affiliated companies, IT providers (e.g. Google Login) and social networks (e.g. Facebook Login, Fan Page).
Which are your rights?
You can exercise the following rights by sending a specific request to the Data Controller at the following email address: legal@tenni.app
RIGHT
DESCRIPTION
ACCESS (see Article 15 GDPR)
The data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him are being processed, and, where that is the case, access to the personal data and to the following information: purpose of management, categories of processed data, recipients (if any), transfer and adequate guarantees (if any), period for which personal data will be stored, rights of data subjects, existence of an automated decision-making process (if any). The Data Controller provides a copy of personal data. If the request is made by electronic means, information are supplied in a commonly used electronic format, unless otherwise indicated.
RECTIFICATION(see Article 16 GDPR)
The data subject has the right to obtain the rectification of wrong personal data and the integration of incomplete personal data.
ERASURE (see Article 17 GDPR)
The data subject shall have the right to obtain from the Data Controller the erasure of his personal data in the following cases: the personal data are no longer necessary in relation to the purpose for which they were collected or otherwise processed, withdrawal of consent (and there is no other legal bases for the processing), he opposes the processing for the reasons related to his particular situation (and the are no overriding legitimate grounds for the processing), he opposes the processing for direct marketing purposes, the personal data have been unlawfully processed, the personal data have to be erased for compliance with legal obligation, the data have been collected in relation to the offer of information society services. The right shall not apply if the processing is necessary for exercising the right of freedom of expression and information, for compliance with legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority, for reasons of public interest in the area of public health, for archiving purpose in the public interest, scientific and historical research purpose or statistical purpose, for the establishment, exercise or defense of legal claim.
RESTRICTION OF PROCESSING(see Article 18 GDPR)
The data subject shall have the right to obtain from the Data Controller the restriction of processing if: the accuracy of the personal data is contested by the the data subject (for a period enabling the Controller to verify the accuracy), the processing is unlawful (but the data subject opposes the erasure of the personal data and requests the restriction of their use rather than erasure), the personal data are required by the data subject for the establishment, exercise or defense of legal claim e, although the Data Controller no longer needs it, he exercised the right to object (while the Data Controller verifies the existence of legitimate and prevailing reasons).
OBJECTION(see Article 21 GDPR)
The data subject shall have the right of object to processing of personal data if (i) it is based on public interest or legitimate interest and (ii) if personal data are processed for direct marketing purpose, including profiling.
DATA PORTABILITY(see Article 20 GDPR)
The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a data Controller, in a structured, commonly used and machine- readable format (applicable to automated decision- making processes).
WITHDRAWAL(see Article 13, d.2, d)
The data subject has the right to withdraw the consent any time without affect the lawfulness of processing based on the consent before withdrawal.
COMPLAINT(see Article 13, d.2, d)
The data subject has the right to pledge a complaint with a supervisory authority.
Tenni Privacy Policy details
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
When you provide such information directly to us.
When you create an account or use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Public Records
From the government or other sources with results such as tennis federations.
Third Parties
Vendors
We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles.
Advertising partners
We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
Social Networks
If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
Users and Clubs
If you are a providers such as a club, college or coach that has elected to adopt Tenni’s Pro and/or Premium products or services (the “Club”), we may ask you during the onboarding process or through your use of the Services to provide us with the first name, last name, and email addresses of your individual club members (“Club Member Information”) for the purpose of registering these members within the Club’s page on the Services and pursuant to this Privacy Policy. We will not distribute, sell, or rent such Club Member Information, or use such Club Member Information in any way that is not described in this Privacy Policy. By providing us with any Club Member Information, you represent and warrant that you have obtained all necessary rights and consents from each such Club member to provide us with his or her Club Member Information and to allow us to use his or her Club Member Information in accordance with the terms of this Privacy Policy. You may also invite your individual Club members to use and register for our Services by distributing to those individuals the specific codes/links provided to you by Tenni. It is your responsibility to maintain and monitor the accuracy of a list of those individuals to whom you have distributed such codes/links. Any individual or Club member who has registered for our Services may choose at any time to remove his or her Club Member Information from the Service by sending a removal notice to support@tenni.app.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you with the products, services or information you request.
• Calculating your rating.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA").
Marketing and selling the Services
Corresponding with You
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Tenni or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Tenni or another party.
• Enforcing any agreements with you.
• Responding to any claims that any posting or other content violates third-party rights.
• Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.
How We Disclose Your Personal Data
We disclose your Personal Data to categories of service providers and other parties listed in this section.
Depending on national and/or state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties that help us provide the Services or perform business functions on our behalf. They include:
• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Payment processors.
- If you elect to purchase and/or provide any paid services (one-time and/or on a recurring subscription basis), you will enter into an agreement with our payments partner, Stripe, Inc., for the payments service and Stripe's use of your data.
- Please review the Stripe Privacy Policy (https://stripe.com/privacy), which will apply to you.
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
• Marketing providers.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.
Affiliates. These are our corporate affiliates.
Business Partners. These parties partner with us in offering various services. They include:
• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities or joint marketing campaigns.
• Resellers and integrators, including, for example, third party platforms we may integrate our rating system with or who may receive our match score data feeds.
• Other associations you are affiliated with or in the territory where you reside.
Parties You Authorize, Access or Authenticate
• Third parties you access through the services.
• Social media services.
• Other users.
Legal Obligations and Anti-Corruption Investigations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools, Advertising and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.” You can decide whether to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or in the United Kingdom.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as you have an open account with us or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
We retain your payment data for as long as we need to process your purchase or subscription.
We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age or from EU or UK residents under 16 years of age; if you are a child under the age of 13 (or an EU or UK resident under the age of 16), please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age or an EU or UK resident under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age or an EU or UK resident under 16 years of age may have provided Personal Data to us, please contact our support team.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact our support team.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA or the GDPR, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA or the GDPR, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
Email us at: support@tenni.app
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Under the CCPA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We have shared the following categories of Personal Data for the purposes of cross-contextual behavioral advertising:
Device/IP Data
Web Analytics Data
As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of data selling and/or sharing by following the instructions in this section.
We share Personal Data of website visitors with the following categories of third parties:
Ad Networks.
Marketing providers (including for cross-contextual behavioral advertising purposes)
We have shared the following categories of Personal Data of website visitors with the categories of third parties listed for the following purposes:
Marketing and selling the Services.
Showing you advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the sharing of your Personal Data. You can opt-out using the following methods:
You can email us at support@tenni.app.
You can opt-out of retargeted advertising cookies by visiting your Cookie management settings here: [LINK].
You can use a Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
Once you have submitted an opt-out request, we will not ask you to reauthorize the sharing of your Personal Data for at least 12 months.
To our knowledge, we do not share the Personal Data of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Opt-Out from Certain Third Party Marketing
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact our support team.
Other State Law Privacy Rights
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting our support team with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.
Colorado Resident Rights
If you are a Colorado resident subject to the Colorado Student Data Transparency and Security Act (C.R.S. section 22-16-101 et seq.), we will not sell your Personal Data, use your Personal Data for targeted advertising, or use your Personal Data to build a user profile other than in connection with our Services as set forth in this Privacy Policy. Personal Data will be stored in a manner that protects its security, privacy, confidentiality, and integrity, including appropriate administrative, technological and physical safeguards.
European Union and United Kingdom Data Subject Rights
EU and UK Residents
If you are a resident of the European Union (“EU”), the United Kingdom (“UK”), Liechtenstein, Norway or Iceland, you may have additional rights under the EU / UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Tenni will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact our support team.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Profile or Contact Data.
• Payment Data.
• Social Network Data.
• Consumer Demographic Data.
• Non-Public Education Data.
• Geolocation Data.
• Inferences Drawn From Other Personal Data Collected.
• Other Identifying Information that You Voluntarily Choose to Provide.
• Other Data.
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
• Profile or Contact Data.
• Payment Data.
• Device/IP Data.
• Web Analytics.
• Social Network Data.
• Consumer Demographic Data.
• Non-Public Education Data.
• Geolocation Data.
• Inferences Drawn From Other Personal Data Collected.
• Other Identifying Information that You Voluntarily Choose to Provide.
• Other Data.
• We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
• Providing, customizing and improving the Services.
• Marketing the Services.
• Corresponding with you.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU and UK Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at legal@tenni.app. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Tenni’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here:
https://edpb.europa.eu/about-edpb/board/members_en.
Please note that automated decision making or profiling according to Art. 22 GDPR does not take place.
Transfers of Personal Data
The Services are hosted and operated in the European Union (“EU”) through Tenni and its service providers. The Services might transfer you data outside of the EU for hosting it in an additional region, such as the US. If you do not reside in the EU, laws in the EU may differ from the laws where you reside (e.g. the US). The U.S. is not deemed by the European Commission or the United Kingdom as providing an adequate level of protection for Personal Data, and is not covered by a suitable framework or certification recognized by the relevant independent public data protection authority as providing an adequate level of protection for Personal Data. If you do not wish for your Personal Data to be transferred to the US or other jurisdictions, please do not submit your Personal Data to Tenni. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Tenni in the EU and will be hosted on EU servers, and you authorize Tenni to transfer, store and process your information to and in the EU, US, and possibly other countries. We undertake that when we transfer EU or UK Personal Data to a jurisdiction outside the EU or the UK, such as the US, to the extent applicable, we will follow and adhere to the European Commission’s Standard Contractual Clauses for the transfer of personal data to third countries, pursuant to Decision 2004/915/EC (the Standard Contractual Clauses, available at http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32004D0915&from=EN). If, in the future, there are alternative means of giving you equivalent protection to the GDPR when we transfer EU Personal Data outside the EU, United Kingdom, Liechtenstein, Norway or Iceland, for example, statutory codes of practice approved for our use, then we may use those methods instead.
Changes to this Privacy Policy
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Tenni website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
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: