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PRIVACY POLICY
At Tightrope Media Systems, Inc. (“Tightrope”, “we”, and “our”) we are committed to safeguarding the privacy of our customers and of the data collected through the use of our Tightrope and Carousel brand websites, our software products, and all services we provide (collectively, the “Services”).
Tightrope and its licensors own, operate, and maintain the Services. Tightrope is a Minnesota corporation with its principal place of business at 400 South 4th Street Suite 410, PMB 92452, Minneapolis, Minnesota, U.S.A. Should you have any privacy questions or concerns you may contact Tightrope by sending an email to privacy@carouselsignage.com.
This Privacy Policy sets out how we treat the personal information of our (a) customers (“Customers”) and all of their authorized users (collectively the “User,” “you,” and “your”), and (b) non-users in our role as a processor of information and data for our Customers and Users.
This Privacy Policy also defines your privacy options and describes how information is collected from you and is used. By using the Services, you agree to the information collection and use policies and practices stated herein. If we make material changes to this policy, we will notify you by email, with a notice the next time you log into or access the Services, or by other means. Such revisions and additions shall be effective immediately upon notice. You are responsible for reviewing the Services for any modification to this policy. Any access or use of the Services by you after notice of modifications to this policy shall constitute and be deemed to be your agreement to such modifications.
WHEN YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY, YOU AGREE TO THE INFORMATION COLLECTION AND USE TERMS STATED IN IT. TIGHTROPE HAS THE RIGHT TO REVISE THIS PRIVACY POLICY ON THE TERMS STATED BELOW. WE ENCOURAGE YOU TO CHECK THIS PRIVACY POLICY FREQUENTLY FOR CHANGES. Use of the Services is further subject to the Carousel Cloud Terms of Use and the “Additional Agreements” as defined therein, both of which are available via the Tightrope website.
Visitors to our website may voluntarily provide their contact information to Tightrope for purposes of obtaining information about our products and services. Tightrope handles the personal information of website visitors in the same manner as the personal information of its Customers and Users. References to Customers and Users in the remainder of this Privacy Policy shall include website visitors to the extent applicable.
Customers and Users of the Services are required to provide personal information to Tightrope to establish and maintain access to the Services. Customers must provide the following personal and business information to Tightrope as part of the Services registration process:
- the administrator’s telephone number
- the Customer business or organization name
- the Customer street address
- the Customer payment information
All Users of the Services must be authorized to use the Services by a Tightrope Customer. We may collect the following personal information from Users for this purpose:
- first and last name
- email address
- password
We collect information about the web browser (“browser”) and computer or electronic device (“device”) you use to access and use the Services. This information may include unique device identifiers, your browser type and settings, device type and settings, and operating system. We may also collect information about the interaction of your browser and device with our Services, including IP addresses, crash reports, system activity, and the date and time you use the Services. We collect your browser and device information whenever you log into and use the Services from your device.
We may collect information about how you use the Services when you are logged in and using its functionality. This may include information about the types of content that users upload, manage, and display when using the Services. We may also compile certain general usage information concerning the Services. You agree that we are authorized to use, reproduce and generally make such information available to third parties in the aggregate, provided that such information shall not include personal information about you, a User or any data subject. If your use of the Services is paid for by an organization (e.g. employer), you agree that we may make your usage information available to such organization, including but not limited to, content created and loaded to the Services including the dates and times of your use and actions.
We process your personal information so we can maintain your Customer and User account and provide you with the Services and Services functionality. We also use information about your devices and browser to automatically configure the Services for your use when you log-in. We may also use other information about your device, browser, operating system, and similar information to enhance your use of the Services.
If we collect payment information from the Customer account administrator, we use this information to process payments of the subscription fees we charge.
Customers and Users save, manage, and display Customer Content when using the Services. We do not generally view or monitor the Customer Content as we operate and provide the Services functionality. We may need to view and monitor the Customer Content to provide support and maintenance services to our Customers and Users.
We may use personal information like your email address to communicate and interact with you directly. For example, we may let you know about upcoming changes or improvements to the Services. If you contact Tightrope for support or assistance in using the Services, we’ll keep a record of your request and our communications with you so we can better assist you in addressing the issues.
If we collect a mobile telephone from you, we may use the number to communicate with you concerning all aspects of the Services. Your mobile number will not be used for any other purpose. You may opt out of receiving electronic messages from Tightrope at any time by texting STOP in response to a message received from us, or by emailing us at privacy@carouselsignage.com, or by mailing a request via U.S. Mail using the contact information provided at the end of this Privacy Policy. We may continue using your mobile number for as long as you remain a User of the Services, or until you expressly revoke your consent to our use of your mobile number. If you revoke your consent for the use of your mobile number in connection with your use of the Services, you may not have access to all Services functionality.
We also provide your personal information to third-party data processors as necessary to operate the Services and provide the Services, such as companies which host servers and process data for the Services, or which process your payments. These third-party data processors are currently located in the United States. Tightrope may provide your personal information to its subsidiaries, affiliates,\ professional advisors, and other third parties to provide services such as customer communications, hosting, data analytics, advertising, and other services. Tightrope may provide your personal information to these third parties only to provide those services, and the third parties are not authorized to use or disclose your personal information for any other purpose. Our third-party data processors will not use your personal information for any purpose other than those identified within this Privacy Policy
and to enable Tightrope to provide you with the Services functionality.
Except for our third party data processors, we will not voluntarily share your personal information with a third party without your prior authorization, except (a) to enforce our privacy policy, to comply with law, regulation, or other legal processes or to protect the rights, property or safety of us or others, (b) to a government regulator, law enforcement agency, or other public authorities, including to meet national security standards, (c) in emergency situations, (d) to protect against misuse or unauthorized use of the Services, (e) to detect or prevent criminal activity or fraud, or (f) in the event that Tightrope or substantially all of its assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, in which case personal information may be one of the transferred assets. (h) Our Use of Your Services Usage Information We use the information that we collect about your use of the Services to analyze, measure, evaluate, and improve or change the features and functionality of the Services. We may also use this information for product marketing, promotion, and sales purposes in our business discretion. We may share this usage information with third parties for marketing, advertising, or other similar uses. Your usage information will not include any personal information which identifies or can be attributed to a user unless we first notify you and obtain your consent.
We collect information about your use of the Services with cookies. Cookies are small files that a software application stores on your computer’s hard drive or other memory for record-keeping or other administrative purposes. If you are concerned about the use of cookies, you can choose to enable a feature in your browser that will erase cookies, block all cookies, or warn you before cookies are stored or exchanged. If you reject cookies, you may not have access to all features or functionality offered by the Services.
Our legitimate business interest for collecting our users’ personal information is to operate the Services for the benefit of our Customers and Users in return for subscription fees. We use the subscription fees to pay our business expenses and operate Tightrope, which is a for-profit business.
Data security is implemented through physical, administrative, and technical safeguards we put in place and operational procedures we follow to protect personal information. We protect your transactions involving personal information over the Internet using Transport Level Security (TLS) technology. We restrict access to your personal information in our database to our authorized employees, our agents, and certain of our authorized contractors. We will promptly notify you if we learn or have reason to believe that any person or entity has breached our safeguards and gained unauthorized access to your personal information.
You can review and correct any personal information we store in the Services by contacting us at privacy@carouselsignage.com or by U.S. Mail to the address given in the Contact Information section of this Privacy Policy, below. You can export or copy the content, data, or other files stored in the Services at any time. To delete your personal information from the Services, you can terminate your User account which will delete your personal information from the operating version of the Services.
We may need to retain some of your personal information and content for limited periods for our legitimate business or legal purposes. Contact us for more information about our data retention periods and how long it takes us to delete your information.
The Services is not intended for use by children or persons under the age of 18. We will not knowingly collect any personal information from minors through this Services. If you think that we have collected personal information from a minor, please contact us immediately using the information in Section 12, below.
U.S. state consumer privacy laws may provide their residents with additional rights regarding our collection and use of their personal information. California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding any disclosures of personal information we make to third parties for direct marketing purposes. Colorado, Connecticut, Virginia, and Utah each currently or will provide their residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales. Colorado, Connecticut, and Virginia also currently or will provide their state residents with rights to:
- Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
Nevada currently or will provide its residents with a limited right to opt-out of certain personal information sales.
Not all of the foregoing state rights apply to Tightrope’s collection and processing of your personal information. If you believe any of the foregoing state rights do apply to us and you wish to exercise such rights, please contact us using the information at the end of this Privacy Policy.
This Privacy Policy is intended to comply with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and the Australian Privacy Act of 1988. Residents of Canada and Australia may contact Tightrope directly with privacy questions by sending an email to privacy@carouselsignage.com.
European and Canadian data protection laws give data subjects certain rights regarding their personal information. Tightrope Customers and Users are required to notify data subjects when the Customer or User has obtained a data subject’s personal information and the specific purposes for which the personal information may be used. It is the obligation of the Customer or User of the Services to obtain consent from the data subject for the use of their personal information. If you are a User located within the European Union or Canada, you may ask us to take the following actions in relation to your personal information that we hold:
● Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
● Access. Provide you with information about our processing of your personal information and give you access to your personal information.
● Correct. Update or correct inaccuracies in your personal information.
● Delete. Delete your personal information.
● Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
● Restrict. Restrict the processing of your personal information.
● Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.
You can submit these requests by email to privacy@carouselsignage.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. European Union residents can find their data protection regulators here.
If we hold your personal information in connection with services that we provide to one of our Users, we will direct your request to the applicable User of our Services.
Send Tightrope an email at privacy@carouselsignage.com if you want to access, review, correct or delete the personal information collected from you by Tightrope. To protect your privacy and security, Tightrope requires a Customer or User ID and password to verify your identity before granting you the right to access, review, or make corrections to your personal information. Please be advised that certain personal information may not be corrected or deleted if we must by law retain such information as submitted.
We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order or legal process.
It is also possible that Tightrope would sell its business (by merger, acquisition or otherwise) or sell all or substantially all of its assets. In any transaction of this kind, Customer and User information, including your personal information, may be among the assets that are transferred. If we decide to so transfer your personal information, you will be notified by an email sent to the last know email address in our files or by notice posted on the Services.
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have otherwise collected about you, such as when you cease to be a registered Customer or User of the Services, we will dissociate such identifying information from the personal information attached to your content to the extent possible while retaining such information only so long as needed to comply with business, legal or regulatory obligations and requirements. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
Customers and Users located outside of the United States, including all Customers and Users located in the European Union and Canada (“International Users”), are hereby notified that their personal information may be collected, used, disclosed, transferred and stored in the United States. By accepting this Privacy Policy, International Users consent to the collection, use, disclosure, transfer, and storage of their personal information in the United States for the purposes stated in this Privacy Policy. Personal information of International Users will be subject to lawful access requests from U.S. governmental agencies for as long as it is stored in the United States. For our Customers and Users residing in the European Union, whenever we transfer your personal information to the United States, or other countries not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be made:
● Pursuant to the recipient’s compliance with current Standard Contractual Clauses adopted by the European Commission or Binding Corporate Rules; or
● Pursuant to the consent of the individual to whom the personal information pertains; or
● As otherwise permitted by European law.
For data subjects located in the EU, we have appointed GDPR-Rep.eu as our representative pursuant to Article 27 of GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/11082518 for more information.
Contact information for GDPR-Rep.eu:
Tightrope Media Systems, Inc.
c/o GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence: GDPR-REP ID: 11082518.
The Services may contain links or provide access to third party websites or software applications. Tightrope is not responsible for the privacy practices of these websites or applications. This Privacy Policy only applies to information collected by Tightrope.
The Services may use YouTube API Services to provide video functionality for Users. Your use of the YouTube functionality may result in the collection of use of your personal information by YouTube and
its affiliates. Your use of the YouTube functionality is subject to the Google Privacy Policy available at http://www.google.com/policies/privacy. Please read the Google Privacy Policy prior to making any use of the YouTube functionality. By accepting this Privacy Policy, you also agree to be bound by the Google Privacy Policy.
If you acknowledge that you have reviewed this Privacy Policy and accept its terms when registering to use the Services, or otherwise, then you have expressly consented to the use of your personal information as stated in this Privacy Policy. You may withdraw your consent to the use of your personal information, unless you are withdrawing your consent to avoid a legal obligation to Tightrope. Tightrope’s continued use of your personal information, after you withdraw your consent to its use, may be required for Tightrope to comply with federal and state laws and regulations. We will change this Privacy Policy periodically. We will not reduce your rights without your consent. The
date at the end of this Privacy Policy indicates when the most recent changes to this Privacy Policy were posted. If changes are significant, we’ll provide a more prominent notice, including email notification. Again, if you acknowledge that you have reviewed an updated version of this Privacy Policy in response to an update notice from us, then you have expressly consented to the use of your personal information as stated in this Privacy Policy.
If you have any other questions, comments or concerns about this Privacy Policy or your privacy please contact us via U.S. Mail or email to:
Tightrope Media Systems, Inc.
400 South 4th Street Suite 410
PMB 92452
Minneapolis, MN 55415-1419
privacy@carouselsignage.com
Copyright © 2018-2022. Tightrope Media Systems, Inc. All rights reserved.
Last revised: September 30, 2022.
