Privacy Policy

TELLIUS PRIVACY POLICY
version 2.0, August 13, 2023
Tellius Confidential and Proprietary

Welcome to Tellius, the online and mobile web sites and other interactive features (collectively, “Tellius Web Sites” or “Web Sites”) of Tellius, Inc. (“Tellius,” “we,” or “us”). Tellius is committed to protecting your privacy. Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Web Sites, and your choices about the collection and use of your information.

1. How We Collect and Use Information

We collect the following types of information about you:

Information you provide us directly: You are not required to provide information about yourself when you visit a Tellius Web Site. Tellius Web Sites may ask you for different types of information when you register for certain services, access various content or features, or directly contact the Web Site including: contact information, such as name, email address, postal address, phone number, facsimile number, and mobile number; user name, password, and password reminder questions and answers; age and date of birth; other demographic information, such as gender, job information, and zip code; information for a public profile, such as your interests and the address of your web site; communications preferences, such as which newsletters you would like to receive; search queries; in limited circumstances, payment and identity verification information, such as credit card number, social security number or comparable national identifiers, and driver’s license number where needed for payment, to complete a particular transaction, or to access a particular service (e.g., paid subscriptions); information posted in community discussions and other interactive online features; and correspondence you send to us. We may also retain any messages you send through the Web Sites and may collect information you provide in User Content you post to the Web Sites. We use this information to operate, maintain, and provide to you the features and functionality of the Web Sites.

Information we collect automatically on Tellius Web Sites: Tellius Web Sites may collect certain information automatically, including: your browser type and operating system; your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area; sites you visited before and after visiting a Tellius Web Site; web pages and advertisements you view and links you click on within Tellius Web Sites; unique identifiers, including mobile device identification numbers that can identify the physical location of such devices in accordance with applicable law; information collected through cookies (described below), web beacons, and other technologies; information about your interactions with audio and video content, such as the type of content listened to and viewed, and information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded; upon request, your bandwidth speed and information about the software programs installed on your computer; and standard server log information.

Information we may receive from third parties: We may also use third parties to provide certain services, such as collecting, tracking and analyzing non-personally identifiable usage and statistical information from users, such as the user’s browser type, operating system, browsing behavior and demographic information. These third parties may place cookies, web beacons or other devices on your computer or device to collect non-personal information which may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Site and the other sites tracked by these third parties. We will not allow such third parties to capture your personally identifying information unless you approve of such data gathering.

We use this information to operate, maintain, and provide to you the features and functionality of the Web Sites, as well as to communicate directly with you, such as to send you email messages and push notifications. We may use this information for retargeting. We may also send you Tellius-related emails or messages (e.g., account verification, order confirmations, change or updates to features of the Web Sites, technical and security notices). For more information about your communication preferences, see “Your Choices Regarding Your Information” below.

Use of cookies and other technology to collect information:

We automatically collect certain types of usage information when you visit or use our Web Sites. When you visit the Web Sites, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Web Sites (e.g., the pages you view, the links you click, how frequently you access the Web Sites, and other actions you take on the Web Sites) and allow us to track your usage of the Web Sites over time. We may collect log file information from your browser or mobile device each time you access the Web Sites. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Web Sites, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Web Sites. We may also collect analytics data or use third-party analytics tools (such as Google Analytics), to help us measure traffic and usage trends for the Web Sites. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analyzing and improving the Web Sites.

When you access our Web Sites by or through a mobile device, we may receive or collect and store a unique identification number associated with your device (“Device ID”), mobile carrier, device type and manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.

We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of our Web Sites; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Web Sites; (e) diagnose or fix technology problems; (f) otherwise plan for and enhance our service; and (g) automatically update the Tellius application on your mobile devices.

2. Sharing of Your Information

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the section below called, “Your Choices Regarding Your Information.

We may share your personal information with:

• Other companies owned by or under common ownership as Tellius, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.
• Third party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us, which may include identifying and serving targeted advertisements, content or service fulfillment, or providing analytics services; additionally, we may use credit card processing or verification service companies to verify credit card information and process payments. We will require any such processing or verification services to comply with PCI privacy and security requirements.
• Third parties who we think may offer you products or services you may enjoy, if you have indicated to us that you wish to receive information from such parties.
• Other parties in connection with any company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.
• Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Go OUt, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

Use of Google Analytics:

Tellius may use any of the following services from Google Analytics:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting

We will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any Google advertising product or feature unless we have robust notice of, and the user’s prior affirmative (i.e., opt-in) consent to, that merger.

To see how Google uses your information, review How Google uses data when you use Google’s partners’ sites or apps.

Ads on Tellius: We may also share certain information such as your location, browser and cookie data and other data relating to your use of our Web Sites with our business partners to deliver advertisements (“ads”) that may be of interest to you. Tellius may allow third-party ad servers or ad networks to serve advertisements on the Web Sites. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Web Sites and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browsers or device’s visits and usage patterns on the Web Sites, and to measure the effectiveness of their ads and to personalize the advertising content. Tellius does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask Tellius to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, Tellius determines the target audience and Tellius serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

The Tellius Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

3. How We Store and Protect Your Information

Storage and Processing: Your information collected through the Web Sites may be stored and processed in the United States or any other country in which Tellius or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Tellius or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Keeping your information safe: Tellius cares about the security of your information and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Web Sites. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Tellius, at all times. However, Tellius cannot ensure or warrant the security of any information you transmit to Tellius or guarantee that information on the Web Sites may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Tellius Web Sites, such as social networks. Tellius is not responsible for the functionality or security measures of any third party.

Compromise of information: In the event that any information under our control is compromised as a result of a breach of security, Tellius will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4. California-Specific Disclosures

The California Consumer Privacy Act of 2018 (CCPA) requires us to provide additional and different information to California residents. The statements in this Section are addressed to California residents only. This Privacy Policy sets out the categories of personal information we have collected about California residents in the past 12 months, the business or commercial purposes for which we collected the information, the categories of third parties to whom we disclosed the personal information, and the sources of the personal information. The types of personal information we have collected from California residents over the past 12 months correspond with the following categories of personal information under the CCPA definition of “personal information”:

• Name, email address, postal address, account name.
• Information that identifies, relates to, describes or is capable of being associated with a particular individual, including signature, financial information, credit card number, debit card number, telephone number.
• Commercial information, including records of services purchased, obtained or considered.
• Internet or other electronic network activity information, including information regarding individuals’ interaction with an Internet website, application, or advertisement.
• Electronic information.

This Privacy Policy does not reflect our processing of California residents’ personal information where an exception under California law applies.

5. EEA- and UK-Specific Disclosures

The General Data Protection Regulation (GDPR) requires us to provide additional and different information to individuals in the EEA and UK. The following statements are addressed to individuals located in the EEA and UK only.

Legal Basis for Processing

• We need to use your personal data to perform our responsibilities under our contract with you such as to process payments for and provide the Services you have requested.
• We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Sites and Services.
• We may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process.
• In cases where we ask for your consent to process your personal data and you provide your consent, we process your personal data according to your consent.

Your Rights

Subject to applicable law, you have the right to:

• ask whether we process your personal data and request copies of such personal data and information about how it is processed.
• request that inaccurate personal data be corrected.
• request deletion of personal data that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements.
• request that we restrict the processing of your personal data where the processing is inappropriate.
• object to our processing of your personal data; and
• request portability of personal data that you have provided to us.

Please see Section 6 below if you would like to exercise any of these rights.

Questions or Complaints

If you are located in the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. If you are located in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. Your Choices About Your Information

Commercial and marketing communications: We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Web Sites-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Web Sites, technical and security notices). You may not opt out of Web Sites-related e-mails. You will also be able to be “found” on Tellius based on information that you provide (see “Find friends on Tellius”) above.

You control your account information and settings: You may update your account information and email-communication preferences at any time by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Web Sites-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Web Sites, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at [email protected].

7. Advertising and Analytics Services Provided By Others

We may permit third party online advertising networks to collect information about your use of our website over time so that they may display ads that may be relevant to your interests on our Web Sites as well as on other websites or apps. Typically, the information collected for this purpose is collected through cookies or similar tracking technology. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, located at http://www.networkadvertising.org). Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents Tellius or its business partners from tracking your browser’s activities in relation to the Web Sites, and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the Web Sites. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at [email protected].

How long we keep your User Content: Following termination or deactivation of your User account, Tellius may retain your profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes.

You can designate an authorized agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, we may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CCPA on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA. You may not be discriminated against because you exercise any of your rights under the CCPA.

8. “Do Not Track” and Opting Out

Although we do our best to honor the privacy preferences of our customers, we are not able to respond to Do-Not-Track signals from your browser at this time. As discussed above, we track website usage information through the use of cookies for analytic and internal purposes only. Because we do not collect this information to track you across websites over time, your selection of the “Do Not Track” option provided by your browser will not have any effect on our collection of cookie information for analytics or internal purposes.

To opt out of cookies and other tracking tools, please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. To opt out of information collected by Google Analytics, see currently available opt-outs for the web. Information about opting out of Google’s use of cookies is available by visiting Google’s Ads Settings. You can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. To opt out of DoubleClick’s remarketing pixels and use of cookies, visit the DoubleClick opt-out page or the Network Advertising Initiative opt-out page. You can opt out of being solicited by Tellius by email, by using the unsubscribe link in the bottom of emails you receive from us.

9. Children’s Privacy

Tellius does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Web Sites and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at [email protected].

10. Links to Other Web Sites and Services

We are not responsible for the practices employed by websites or services linked to or from the Web Sites, including the information or content contained therein. Please remember that when you use a link to go from the Web Sites to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not have any control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Web Sites.

11. How to Contact Us

If you have any questions about this Privacy Policy or the Web Sites, please contact us at [email protected].

12. Changes to Our Privacy Policy

Tellius may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the ‘last modified’ date at the bottom of this page.

This privacy policy was last modified on August 13, 2023.