Privacy Policy

Introducing the Privacy Policy

This privacy statement (“Privacy Policy”) explains how Tickle Global LTD (“Tickle” or “we”) collects and processes information from members and users of the website, software applications, and other online services we provide (collectively “Tickle’s products”). Tickle’s products include, but are not limited to, the Tickle mobile application (the “Mobile App”), the Tickle extension for web browsers (the “Extension”), and the Tickle website located at www.JoinTickle.com (the “Website”).

To the extent that Tickle has links to other websites (like retailers and advertising publishers), please note that we do not own, operate, or control them, and they have their own controlling privacy policies that you should review.

What data we collect and why

In order to provide our services, Tickle collects information that you share directly with us when you use our website, extension, or Mobile App. To access our main Service you may choose to provide your email address and phone number with us. This enables you to become a Tickle Member and benefit from the Services we offer to save advertisements and contents to your Tickle Member Mobile App in a number of different ways. This also enables you multiple further benefits from unlocking offers, reward and experiences from our brand and affiliate partners and to unlock, earn and spend Tickle Gold (also referred to as “Tickle Coins”) on goods, features and services that we may offer through our Tickle Gold loyalty points programme. You can also set up your profile with your name and other info for a more personalised experience.

Tickle also collects technical information about your device and use of Tickle to make sure that our products are working correctly. The information we collect is geared to providing Tickle members with a better way to shop online and to help us develop, improve, and market our services.

Account and Profile Information.

When you become a member of Tickle, you share a limited amount of information during the registration process, including your name, email address, phone number and other registration information to personalise your profile. You can also optionally choose a “Username” that can be used to keep your personal information private from other Users and/or Members for any features that may enable you to create User Content either now or in the future.

If you choose to link a social media profile (like Facebook) at sign-in (if offered), Tickle will store this information for login purposes. Linking your social media profile grants Tickle access to the profile, but only to the extent allowed by your permission settings, that platform's terms of service, and this Privacy Statement. We will NOT track any of your social media activity or post anything on your behalf.

If you choose to connect your phone book when prompted, you'll have the option of importing your contacts so that you can refer your friends to Tickle with ease. Referral information is masked, so we never see or store them, nor can we contact anyone without your permission.

As you continue to use Tickle's products, you might also provide information when you:

• Save advertisements and content for later from our publisher partners

• Share coupons, promo codes, and deals you found

• Refer friends from your contacts to Tickle

• Click “follow” on brand pages you like

• Use the Tickle Mobile App and/or extension to make a purchase from a retailer

• Communicate with Tickle through email or other means

Tickle Payment Information.

The Tickle extension, mobile app, or other products may offer the opportunity to purchase discounted gift cards or other products or services from Tickle, as well as the opportunity to save your payment information to your Tickle account in order to allow you checkout easier when shopping on retailer or publisher partner websites. In those cases, you will be asked to input a payment option (i.e., a debit or credit card), as well as information needed to complete those purchases (such as your billing address). In those instances, your payment information is secured and stored through our chosen PCI Level 1 payment processor whose details will be shared with you once this service is enabled.

Alternatively, please note that if you are purchasing an item on a third party merchant’s website that is being displayed within the Tickle Mobile App, then that merchant and not Tickle, will collect, store, and process your payment information in connection with that purchase.

Technical Information.

Tickle automatically collects information to ensure that our products work correctly on different devices and browsers. This includes data like;

• the type of device you're using

• the device's unique ID (where available)

• operating system

• browser type

• IP address

• event stamp

• error logs

This data allows us to make sure Tickle products are working correctly, to make your experience better, to detect and prevent fraud, and to manage our legal obligations. Also, to help us coordinate our communications and marketing campaigns, and to understand how our users engage with our products, we use common digital tools that allow us to see if you opened an email we sent, visited a link in those emails, or generally interacted with Tickle as a result of our marketing efforts.

Similarly, our system will also be able to tell us which advertisements and content you save and where you saved it from so that we can match your saved content with appropriate offers, rewards and/or experiences from the advertising brand, a similar brand and/or publisher.

Tickle does not track your search engine history, emails, or your browsing on any site that is not a retail website (a site where you can shop and make a purchase). When you are on a pre-approved retail site, to help you save money, Tickle may collect information about that site that lets us know which coupons and promos to find for you. This information will remain entirely confidential from third parties.

Shopping and Usage Data.

On partner retail and/or publisher sites and apps, Tickle collects the name of the retailer, page views, and in some cases, product information when you save the Tickle-enabled content. We may also collect information regarding your purchases on a retail site while using Tickle (for example, the transaction value, and the fact that an order was completed or returned) for purposes including internal analytics, commission collection, and managing and delivering your Rewards. The information you share, and we collect, enables us to improve our products and gives us insights about coupons, deals, pricing, and availability of retail items, which we can share with the rest of the Tickle community independent of your personal data which we do not share . We may also use this information to understand your shopping history, merchant and shopping preferences to provide you with a more tailored, relevant experience or show sponsored product offers that may interest you across our Services.

Aggregate and Anonymised Data

We may also use the information we collect in aggregate or otherwise anonymised form. This lets us look at interactions with our site, mobile app, extension, other technology and products generally and does not identify you or any specific person. We use this general data for research, development, marketing, analytics, and to enhance the shopping experience for the Tickle community including our publisher partners.

What data we do not collect

We collect information that we believe can help us save our users time and money. This does not include, and we do not collect, any information from your search engine history, emails, or from websites that are not retail or Tickle-enabled content publisher sites and apps.

We also do not collect bank or credit card information (unless you expressly provide those to us when you make a purchase through Tickle).

How we share your data

We know how important your personal data is to you, so we will never sell it without your express permission first. We'll only share your personal data with your consent or in ways you'd expect (as we explain here). That means we will share your data if needed to complete your purchase, with businesses who help us operate Tickle, or if we are legally required to do so.

We may share information with our service providers (businesses that work for and with us) for the purpose of running Tickle and fulfilling our commitments to you. These include businesses that perform services on our behalf, including to help us maintain our products, to provide support for legal, banking, security protection, payment processing, our own marketing, and customer service. Please know that when we share information with our service providers, it's for the purposes outlined in this Privacy Statement and not for their independent use.

We may also share information in the following cases:

• with your express consent;

• with our affiliates and subsidiaries but only for purposes allowed by this Privacy Statement, including to identify, manage and deliver your Rewards;

• in an aggregate or anonymised format that does not identify any specific person;

• as required by law, or to comply or respond to a valid government request;

• when we believe in good faith that it's necessary to protect our rights, protect your safety or the safety of others, or investigate fraud; and

• with a buyer or successor if Tickle Global LTD is involved in a merger, acquisition, or similar corporate transaction. If that happens, you will be notified via email and/or a prominent notice on the Website and/or Mobile App of any change in ownership, as well as any choices you will have as a result.

In instances where you give your express permission for Tickle to share personal information with a brand partner for the servicing or delivery of an offer or reward or as part of our functionality such as the Hot Keys features including Newsletter sign up and Claiming a sample, the receiving brand then takes ownership of your information for the purposes you agreed to. Tickle will then store that information in your profile if it does not already exist to enable you to repeat this or any other action with future brands quicker and easier.You can amend or delete this data at any time in your profile area. Should you wish to rescind your information from the brand with whom you shared your data with then you need to contact the brand directly. In using Tickle’s services you agree to wholly indemnify Tickle, the staff and company, from any and all actions from that point on in relation to how the receiving brand uses your data and agree that from that point forward that the use of your shared data is governed by the partner brands own privacy and data policies.

How we protect your data

The security of your information is as important to us as it is to you, after-all, we are all consumers first. We have a team dedicated to protecting your information and have put in place physical, electronic, and procedural safeguards.

These measures include limiting access, using encryption, testing for vulnerabilities, advanced malware detection, employing pseudonymisation and anonymisation techniques, and more.

Though we hate to say it, despite our efforts, we can't guarantee that user information will not be accessed, viewed, disclosed, altered, or destroyed as a result of a breach of any of our safeguards. You provide us with information at your own risk. We do follow recognised security frameworks, policies and testing procedures. We use regular testing to check our security is working correctly and your data has not been compromised. If this were to occur we would tell you promptly as required by GDPR regulations.

Tickle only retains information about you as long as you keep using Tickle, though we’ll keep information if we need it to meet our legal obligations and to defend against legal claims. Data shared with Tickle is subject to data retention periods as set out in the Tickle Privacy Statement.

How we use cookies and similar technologies

A huge part of Tickle’s mission is to provide brands, publishers and brands an alternative to using third party cookies that chase people around the web without bringing you, the consumer, any value in return. This is fundamentally why we exist.

Like most other online services, Tickle uses cookies, pixel tags, web beacons, and other markers (we'll just call them “cookies”) to collect some of the data discussed in this Privacy Statement. These help us operate our products, analyse engagement and usage, and provide a relevant and personalised shopping experience for you. See below to learn how you can manage your cookie preferences.

Some cookies can be temporary (“session cookies” like those used for navigating your browser) and disappear once you close it. Others last longer (“persistent cookies,” like when you ask a site to remember your login) and are saved to your computer or mobile phone until you delete them.

Our uses of cookies and similar technologies fall into the following general categories:

• Essential: We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

• Performance: We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors and Members use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item, advertisement or link, or to improve our website content, applications, services, or tools;

• Functionality: We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into or engage with our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

• Marketing: We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites - after-all, this is the core feature of the Tickle Service. This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked, swiped or saved an advertisement or our content.

Any personal information that we collect and store through use of these technologies for categories other than “Essential” are based on your consent, obtained through a conspicuous disclosure on our website. You can withdraw this consent in your account settings at any time. If you want to disable cookies entirely, your browser or mobile device might have an option to do that. For more information, including instructions on disabling cookies, please visit: http://www.allaboutcookies.org/. You accept that removing all permissions will likely result in you not being able to benefit from Tickle and its Services.

Your choices for managing your data

We've made it easy to opt out of Tickle's products at any time.

You can always adjust your personal settings regarding what information you share and how Tickle communicates with you by going to your profile page and clicking on the “permissions” headings. Please note that limiting the information you offer to provide may impact Tickle's ability to provide certain deals and products to you.

If you want to stop using Tickle, we have instructions on how to uninstall the Extension on our Website or in FAQ section and if you have any issues you can contact our support team for assistance by sending an email to TheTeam@JoinTickle.com.

You can also uninstall the Tickle Mobile App in the same way you would uninstall other mobile apps from your mobile device.

If you would like to delete your profile or personal information, you can always ask us by emailing privacy@JoinTickle.com. We will delete any personal information we have, although the following exceptions apply: (1) we may still store your personal information if we need it to meet our legal or compliance obligations and/or to defend against legal claims; and (2) we may also continue to store your personal data in an aggregated and anonymised format that doesn’t identify you and can’t be attributed to you, even after you’ve deleted your profile.

Additional rights regarding your data

Depending on where you live, you may have additional rights as to the personal information that you share and Tickle collects. Residents of the EU, UK, Canada, Australia, New Zealand, and California can click below to learn more.

EU, UK, Canada, Australia, and New Zealand residents.

Controller: Tickle Global LTD is established in the United Kingdom. Our registered address is 167-169 Great Portland Street, London, W1W 5PF. Please send any request to our contact email address privacy@JoinTickle.com. For the purposes of the General Data Protection Regulation (GDPR), we are the data controller.

Legal Bases: The personal information that you share and we collect, as well as its purposes, are described in this Privacy Statement. Tickle will only collect or process your personal information if we have a legal basis to do so. These are:

• When you agree to our use of your data for a specific purpose.

• When necessary to enact a transaction or to provide you with services and products that you request. This includes personalising features and protecting the security of Tickle and its users.

• When Tickle has a legitimate interest in using that data in the normal ways you'd expect, like ensuring Tickle's products run properly, improving and creating new products, historical analytics research, promoting Tickle, and protecting our legal rights.

• When we need to process your data to comply with a legal or regulatory obligation.

Your rights: You have the following rights with regard to your personal data. To exercise any of these rights, please contact us at privacy@JoinTickle.com. Please note that these rights are limited, like for example, where fulfilling your request would adversely affect other individuals or our legal obligations.

Right to Access: You have the right to request information about your personal data that we hold, how we use it, and who we share it with.

• Right to Portability: Where you have provided your personal data to us on the basis of your consent, you have the right to ask us for a copy of this data in a structured, machine-readable format and to ask us to send this data to another data controller.

• Right to Rectification: You have the right to ask us to correct your personal data where it is inaccurate or incomplete.

• Right to Delete: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.

• Right to Withdraw Consent: In situations where we are processing your personal data based on your consent, you may withdraw this consent at any time.

• Right to Object to Processing: In situations where we are processing your personal data based on our legitimate interest, you can object that the interest is no longer legitimate. Tickle will stop processing that data, unless we can demonstrate an overriding legitimate ground. You can also request to opt out of direct marketing.

• Right to Restrict Processing: You have the right to ask us to stop any active processing of your personal data while we seek to verify data you claim is inaccurate, while we verify our legitimate interests, or while we cannot erase that data due to legal obligations.

Tickle will try to respond to these requests within 30 days, but some might take longer. You will typically not be charged any fee for effecting these rights, but Tickle reserves the right to charge a reasonable fee (or refuse to comply) if the request is unfounded, repetitive, or excessive.

Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us at privacy@JoinTickle.com and we will do our best to resolve it. You can also choose to file a complaint with the relevant data protection authority.

California residents.

If you live in California and use Tickle, you have some additional rights when it comes to your data.

• Right to Delete: You can ask us to delete the personal information we have about you.

• Right to Know: You can ask us for a list of the categories of personal information we have about you, the categories of sources from which we get personal information, the business purposes for which we collect personal information, and the categories of third parties with whom it is shared (you can also see that in this Privacy Statement). You can also ask us for a copy of the pieces of personal information we have about you.

California law gives you the right to opt out of the sale of your personal information. But Tickle does not and will not sell (or rent, or disclose for value) any of your personal information in the first place. Our goal is to facilitate a platform of value exchange between you and your favourite brands, not to harvest and sell your data like other companies might.

To exercise any of these rights, you (or your authorised agent) can contact us through the “Contact us” webform on our Help page (www.JoinTickle.com/help) or by email at privacy@JoinTickle.com. We will confirm receipt of your request within 10 days, and will provide a response to you within 45 days of your request, though in some exceptional cases it might take longer (if that happens, we'll let you know). We will need your name and the email address you registered with to verify your request, and may also ask for additional information if necessary to verify the identity of the person making the request. We reserve the right to deny your request if we cannot verify your identity, or if an exemption applies (for example, where fulfilling your request would adversely affect other individuals, or where we have a conflicting legal obligation). That said, we will not discriminate against you for exercising any of your privacy rights.

To learn about the categories of personal information that Tickle uses, please see the section of this Privacy Statement called “What data we collect and why.” The personal information that we have collected in the past 12 months falls into the following categories as set out under California law:

• The contact information you provide – California law refers to these as identifiers.

• If you shop through the Tickle Mobile App, other individual information like billing address, credit or debit card information – this category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories.

• We don't track your location unless we have specifically asked for it as part of a feature, but your IP address gives us a general idea of the city, state, and country - what California law calls geolocation.

• Shopping, Tickle usage data and, of course, the Tickle-enabled content that you save to the Tickle Mobile App and/or via our extension – California law calls this internet activity.

• Purchases on retail sites when using Tickle – this is commercial information under California law.

To learn about the limited ways in which we disclose data for our business purposes -- that is, to a service provider -- and the categories of those service providers, please see the section of this Privacy Statement called "How we share your data."

Please note that, while Tickle provides tools to manage your privacy as described in this Privacy Statement, we do not support “Do Not Track” browser settings at this time.

California residents also have the right to request this information in an accessible alternative format. If you have a disability and would like to access this Privacy Statement in an alternative format, please contact us by email or mail as detailed below.

Notice of Financial Incentive

If you are a California resident, you have a right to receive this Notice of Financial Incentive.

Our rewards program, sometimes referred to as Tickle Gold, Tickle Coins or Tickle Rewards, is offered with Tickle (together, “Rewards”) and provides you with the ability to earn points on eligible purchases, eligible Tickle transactions, or completing other actions, such as referring a friend.

The Rewards can be earned through our website, the Tickle app, the Tickle extension or through checkout and may be redeemed for gift cards, Tickle or partner merch, Tickle transaction discounts or cash back with a valid Tickle account once these services are established. You can earn Rewards on purchases from eligible merchants, eligible Tickle transactions or other activity. The Rewards are subject to the Tickle Rewards Program Agreement. Additional terms and exclusions may apply and are presented at the time the Reward is offered or saved.

To manage Rewards the following Personal information is collected:

• Identifiers, such as name and email and account location

• Shopping and Usage Information, such as shopping history, transaction value and returns

• Preferred merchants, publishers or categories

• Internet and Network activity such as IP address

• Inferences drawn from one or more of the above, including a consumer's shopping history, save history and like history that reflects a consumer’s shopping preferences.

You opt into Rewards by registering for the Tickle Services. You have the right to opt-out of the Rewards program by contacting customer support at privacy@JoinTickle.com, or you may uninstall or delete your account at any time.

Data Transfers from the EU

If we transfer your data outside of the European Economic Area, we will do so within the safeguards of Binding Corporate Rules, Model Contract Clauses and the EU-US Privacy Shield framework.

As we are located in the United Kingdom and Tickle's products are operated in the United Kingdom, if you are located outside of the United Kingdom, please be aware that information you share and we collect will be transferred to, and processed, stored, and used in the United Kingdom in order to provide Tickle's products to you. Should this change either in part or in whole we will make you aware.

Tickle complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

We will respond to complaints in a timely fashion, and further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit http://go.adr.org/privacyshield for more information or to file a complaint. The services of the AAA are provided at no cost to you.

Minors

We created Tickle for the use of adults (18 and older). We don't knowingly collect or solicit personal information from children. If you are under 18, please do not attempt to use or register for Tickle's products or send any personal information to us.

If we learn we have collected personal information from someone under 18, we will delete that information as quickly as possible. If you are a parent or guardian of a child who you think may have given us some personal information or posted information on any public portion of Tickle's products, please let us know at privacy@JoinTickle.com. We'll help you remove it.

Changes to this Privacy Statement

We will continue to update our policies and practices as needed. We will notify you of any changes to our Privacy Statement by posting any changes here. If we do, you'll see that the date at the top of this Privacy Statement has changed.

How to contact us

If you have any questions about our privacy policies and practice, please contact us at privacy@JoinTickle.com.