Last updated: June 19, 2020
Information We Collect
You are free to explore the Websites without providing any Personal Information. When you visit the Websites, we may request that you provide Personal Information, and we collect Navigational Information. Often you are able to choose what information you provide, but from time to time we may require certain information in order to provide the Services.
“Personal Information” means any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites. Personal Information may further include your IP address or other Navigational Information discussed further below if applicable.
“Navigational Information” means information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigational Information” section below.
We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our products, services or Websites. Such Content includes any Personal Information or other sensitive information that you choose to include (“passively-collected Personal Information”).
We and our analytics provider collect and store analytics information when you use our Websites and/or our products and services to help us improve our Websites, products and services. This analytics information consists of web browsing behavior collected through a combination of HTTP beacons and cookies. Analytics information also consists of data we collect as a result of running queries against Content across our user base for the purposes of generating Usage Data. “Usage Data” is aggregated data about a group or category of services, features or users that does not contain Personal Information. Though we may happen upon sensitive or Personal Information as we compile Usage Data from Content across user instances, this is a byproduct of our efforts to understand broader patterns and trends. It is not a concerted effort by us to examine the Content of any particular customer. Some of our products contain a feature that sends information about the version of the products on your systems (“System Information”) to us. System Information includes information about (i) the server environment in which the product is operating: OS type and version, language and locale settings; (ii) user client information, for example: browser type and version, native client type and version, and client device specifications (e.g. screen resolution, OS version, device type, etc.). You can disable our collection of analytics information from products via the administrator settings or by blocking collection at the local network level.
Information About Children
The Websites are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at firstname.lastname@example.org, so that we may delete the information.
Tulip’s Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). Tulip will not review, share, distribute, or reference any such Customer Data except as provided in Tulip’s Terms of Servce, or as may be required by law. In accordance with Tulip’s Terms of Service, Tulip may access Customer Data only for the purpose of providing the Services, preventing or addressing service or technical problems or as may be required by law. Tulip will additionally collect diagnostic information regarding your use of Tulip software or hardware in order to help our engineers improve Tulip products. Tulip acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by a Tulip customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. If you wish to make your request directly to Tulip, please provide the name of the Tulip customer who submitted your data to our Services. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.
Customer-Generated Content and Applications
Consent and Use of Collected Information
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
- Improve your browsing experience by personalizing the Websites;
- Communicate with you, including responding to your comments, questions, and requests; providing customer service and support; providing you with information about services, features, surveys, newsletters, offers, promotions, contests and events; providing other news or information about us and our select partners; and sending you technical notices, updates, security alerts, and support and administrative messages;
- Send information (other than marketing communications) which we think may be of interest to you or that you have consented to receiving by post, email, or other means.
- Send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you;
- Process and complete transactions, and send you related information, including purchase confirmations and invoices;
- Provide and deliver products or services;
- Operate and improve our operations, systems, products, and services;
- Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes;
- Investigate and prevent fraudulent transactions, unauthorized access to our products and services, and other illegal activities; and
- Provide other companies with statistical information about our users – but this information will not include Personal Information of any kind or be used to identify any individual user.
- In addition, we may share data with trusted partners to contact you based on your interest to receive such communications, help us perform statistical analysis, send you email or postal mail, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
Use of Navigational Information
We use Navigational Information as necessary to operate and improve the Websites. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Tulip.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
Use of Credit Card Information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing.
Service Providers and Third Parties
Security of your Personal Information
We have reasonable and appropriate physical, electronic, and managerial procedures in place to help safeguard your personal information. However, you should know that no company, including Tulip, can fully eliminate security risks associated with personal information.n There is no guarantee that your information may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards and we are not responsible for third party circumvention of your privacy settings or our security measures. To help protect yourself, use a strong password, do not use the same passwords to access your Tulip accounts that you use with other accounts or services, and protect your usernames and passwords to help prevent others from accessing your accounts and services. When sensitive Personal Information (such as a credit card information) is collected in our store, it is protected by our third-party e-commerce provider.
Social Media Features
We may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on our servers if you so request, as described in “Opting-Out and Unsubscribing” below.
Retention of Personal Information
We retain Personal Information that you provide us only for as long as we consider it necessary to fulfil the purpose of storage requirements and provide service to the customer. These services may be, for example, contacting you about our company, products or services as requested, or providing Services to you. We may also use the retained information to improve our Services and ensure the Websites are functioning properly. If you no longer want Tulip to use your information to provide the Services to you, you may rescind consent as described below. Tulip may retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, enforce agreements, and as otherwise described in this policy. We also maintain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site security and safety, to improve site functionality, or we are legally obligated to retain them for longer time periods. If such log files are maintained for a longer time period, they are anonymized and are not associated with Personal Information. We will remove this information from our servers at an earlier date if you so request, as described in “Opting-Out and Unsubscribing” below. In certain circumstances we may retain your Personal Information after you have closed your account or are no longer actively engaged with Tulip. For example: We may retain your personal information after you have closed your account so that we can send you information about products, services and publications we think you may be interested in. You can “unsubscribe” to receiving such messages or tell us you are no longer interested; We may retain your Personal Information in order to protect our legal rights, or those of third parties, or to comply with the law; and We may retain Personal Information about how you have used our products and services in order to improve and develop our business. If you purchase products or services from us, we may retain your Personal Information for as long as we need to in order to provide you with customer service, or for compliance purposes, for example, in order to comply with our record keeping requirements.
If you have submitted a valid European Union General Data Protection Regulation data subject access request to exercise your right to be forgotten we will delete your personal data within 30 days of the request.
If you are an individual based in the European Union you can request a copy of your personal data and you can update any incorrect information.
If you are an individual based in the European Union, you can ask to have your personal data removed, or in some cases limit our processing of personal data. This does not apply when we need to keep your personal data for legal reasons.
International Transfer of Information
To facilitate our global operations, we may transfer and access Personal Information from around the world, including the United States. If you are in the European Union, or other regions with laws governing data collection and use, by providing your personal data to us, you consent to the transfer to, processing, and storage of your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region. This consent applies in addition to other legal grounds for transfer, processing and storage of your Personal Information, such as for contract fulfillment purposes. To the extent that Tulip is deemed to transfer Personal Information outside of the European Union we rely separately, alternatively, and independently on the following legal bases to transfer your information:
The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of Europe. We often use these Model Clauses when transferring personal information outside of Europe. You can request a copy of our Model Clauses by emailing email@example.com.
Tulip Interfaces Inc. does not participate in Privacy Shield at this time. However, we may rely on the EU-US Privacy Shield to transfer Personal Information to some of our third party service providers in the United States, where they may be certified to receive such information under the Privacy Shield Program.
Your Rights as an Individual Based in the EU
In compliance with the Privacy Shield Principles, Tulip commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Tulip at firstname.lastname@example.org.
Access to your information: You have the right to request a copy of the personal data we hold about you.
Correcting your information: We want to have accurate data. Please contact us if you think the personal data you provided to us is not up to date or correct.
Deletion of your information: You have the right to ask us to delete personal data about you if it no longer is required for the purpose it was collected, you have withdrawn your consent, you have a valid objection to us using your personal data, or our use of your personal data is contrary to law or our other legal obligations.
Objecting to how we may use your information: You have the right at any time to require us to stop using your personal data for direct marketing purposes. In addition, where we use your personal data to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal data unless there are overriding legitimate grounds to continue.
Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal data. This right might apply, for example, where we are checking the accuracy of personal data about you that we hold or assessing the validity of any objection you have made to our use of your personal data. The right might also apply where this is no longer a basis for using your personal data but you don’t want us to delete the data. Where this right to validly exercised, we may only use the relevant personal data with your consent, for legal claims or where there are other public interest grounds to do so.
Automated processing: If we use your personal data on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your personal data with your consent or as part of a contractual relationship with you.
Withdrawing consent using your information: Where we use your personal data with your consent you may withdraw that consent at any time and we will stop using your personal data for the purpose(s) for which consent was given.
Please contact us at email@example.com to exercise any of the foregoing rights.
Necessary For The Performance of The Contract Between Tulip and Its Customers
Tulip provides a voluntary service; you can choose whether or not you want to use the services. However, if you want to use the services, you need to agree to our Terms of Service , which set out the contract between Tulip and its customers. As we operate in countries worldwide (including in the US) and use technical infrastructure in the US to deliver the Services to you, in accordance with the contract between us, we need to transfer your Personal Information to the US and to other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your Personal Information around the world.
Compliance with Legal Process
Cookies and Web Beacons
Our websites may use various software technologies including “cookies,” “web beacons” and “pixel tags.” We use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, or register for our store, a cookie helps us to recall your specific information on subsequent visits. “Web beacons” or “Pixel tags” are small pieces of code placed on a web page or within the body of an email to monitor the behavior and collect data about the visitors viewing a web page or viewing or opening an email. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons on our websites from time to time for this and advertising purposes. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the features that you customized. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Websites. We keep track of the pages you visit on the Websites, in order to determine what parts of our store and the Websites are the most popular. This data is used to deliver customized content and advertising on the Websites to visitors whose behavior indicates that they are interested in a particular subject area. We partner with third parties who may place cookies on your browser when you visit our websites, may send their own cookies to your cookie file, and may use those cookies to track and collect information about you and your online activities over time and across different websites, devices, and applications and to provide targeted advertising based on your interests and previous browsing history.
Consent and Legitimate Interests in Processing
Certain Cookie Technologies are employed to make the Websites function for their intended purposes. By choosing to use our Services after having been notified of our use of Cookie Technologies in the ways described in this Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.
Tulip may also collect anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites using log files. Log files may also include information regarding the success, failure of, or individual satisfaction with recent print jobs. There is also information about your computer hardware and software that is automatically collected by Tulip. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Tulip for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Tulip website. This temporary storage of Personal Information by the system is necessary to allow delivery of the website to the computer of the user. To do this, the user’s IP address must be kept for the duration of the session. The data is stored in order to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. The log files will be deleted or anonymized after a reasonable period, unless there is a need to keep the data for the aforementioned purpose due to specific events.
Opting-Out and Unsubscribing, Reviewing, Correcting and Removing Your Personal Information
If you provide us with your Personal Information, you have the following rights with respect to that information:
- To review the user information that you have supplied to us
- To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
- To request that your user information not be used to contact you
- To request that your user information be removed from any solicitation list that we use
- To request that your user information be deleted from our records
- To opt out of being solicited by the Websites or third parties To exercise any of these rights, please contact us at firstname.lastname@example.org or by mail to Tulip Interfaces, Inc., 561 Windsor St., Suite B204, Somerville, MA 02143, Attention: Privacy. We will promptly change, correct, or delete your information. Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data is violating the GDPR.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, or by sending us email us at email@example.com, or by sending us postal mail to Tulip Interfaces, Inc., 561 Windsor St., Suite B201, Somerville, MA 02143, Attention: Privacy. Customers cannot opt out of receiving transactional emails related to their account with us or our store as these communications are necessary for the completion of the Services.