Tumodo Privacy Policy
Last updated February 1, 2023
Privacy Policy

Hello. We are Tumodo. Here's how we protect your personal data and respect your privacy.

Our role in your privacy
If you are a Tumodo user, prospective customer, tester, attendee to a Tumodo event, or just visiting our website, this policy applies to you.

Our responsibilities
We act as the data controller of personal data about you when we process your information for the reasons mentioned in the “How and why we use your data” section below.

Your responsibilities
* Read this Privacy Policy.
* If you are our customer, please also check the contracts between us (including our Data Processing Agreement): they may contain the details on how we collect and process your data as a ‘data processor’ on behalf of your employer.
* If you share personal information about someone else, or if someone else shares your information with us, we promise to only use that information for the reasons mentioned here. When you give us this information, you confirm that you have the right to let us use it according to this Privacy Policy.

Types of data we collect

Contact details
Your name, email address, role in your company, and any other contact details you may share with us.
Professional information
Details on the company, entity or organization you work for, collaborate with, or represent.
Data that identifies you
Your identity document, IP address, login information, browser details (such as type and version), time zone settings, browser plug-ins, geolocation information, and operating system details (such as version).
Data on how you use Tumodo
Your app usage, including your clickstreams (the path you take through our app), the products/services you view, page response times, any download errors you encounter, how long you stay on our pages, what you do on those pages, how often you do it, and other actions you take.
Image and voice
Your image or voice may be recorded in specific interactions with the Tumodo team (e.g.: calls with sales representatives and customer care agents, or product research sessions).
Feedback data
Additional personal data you share during customer feedback sessions (e.g.: via screen sharing, direct interviews, etc.) or in response to feedback surveys.
Other information
Any other information you provide in your requests for information or that is generated during the contractual relationship between your company, organization, or entity and Tumodo.
What about sensitive data?
We don’t collect any “sensitive data” about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences) except when you consent to it by voluntarily disclosing your sensitive data with us to ask for a service.
What about children’s data?
Tumodo is a business-to-business service directed to and intended for use only by those who are 18 years of age or over. We do not target Tumodo at children, and we do not authorize people under 18 years of age to create a Tumodo account or directly request our services.
In some exceptional cases, users who travel with their children can provide the personal data of those minors to use our services. This is only allowed if it's necessary to use the services. For children under 14, the authorized adult must have legal permission to give consent on behalf of the child. For children between 14 and 18, the authorized adult must obtain and provide proof of the consent given by the child.

How and why we use your data
We can only use your data for specific reasons and if we have a legal basis to do so. These reasons are:
Managing our contractual relationship
Executing, fulfilling, monitoring and enforcing compliance of contracts; issuing invoices and cost reports to customers and collecting payments. This includes personal data of individuals who sign contracts with Tumodo or are authorized to hire our services on behalf of the customer.
Legal basis: Contract
Data categories: Contact details, Professional information, Other information
Prospective contractual relationship
Handling information requests about our company or services, processing requests for Tumodo services on behalf of your company, entity, or organization, and managing potential contractual relationships between Tumodo and your company, entity, or organization.
Legal basis: Pre-contractual processing
Data categories: Contact details, Professional information, Data that identifies you
Marketing communications
Sending you commercial and promotional communications related to Tumodo’s services or products that are similar to those you have requested or shown interest in. This may include electronic or telephone communications. If applicable regulations allow, we may also send you commercial communications about products or services that could be relevant to your company.
If you don't want to receive such communications, you can object at any time by clicking the unsubscribe link on the message or by emailing us at hello@tumodo.io
Legal basis: Consent (where legally required), Legitimate interest - developing and growing our business with our clients. You can request to unsubscribe from receiving commercial communications at any time and no cost.
Data categories: Contact details, Professional information
Marketplace & Integrations
Sharing your contact with our Integrated Partners if you give us your consent.
Legal basis: Consent
Data categories: Contact details, Professional information
Improving Tumodo
Managing landing pages and heat mapping our website, testing features, optimizing traffic; collecting your feedback via platforms, questionnaires and live sessions; anonymizing data for development, testing and analytics; recording and reviewing calls with the Tumodo team for quality assurance; analyzing data, including using artificial intelligence and other techniques, and in some cases, using third parties to do this.
Legal basis: Legitimate interests - (i) having tools to improve customer service and be in a position to defend from and minimize claims from our clients, and (ii) analyzing our business practices so that we can make informed decisions and define our strategies for developing and growing our business.
Data categories: Contact details, Professional information, Data that identifies you, Data on how you use Tumodo, Image and voice, Feedback data
Customer support
Sending you notifications of any changes to our services and solving issues with our platform through email, phone or chat.
Legal basis: Legitimate interests - i) fulfilling our contractual obligations towards our clients, and (ii) developing and strengthening our brand reputation and protecting and growing our business.
Data categories: Contact details, Professional information, Data that identifies you, Other information
Maintaining security of the Tumodo services and website
Ensuring that our services and website are not being used in an unauthorized or abusive way by detecting, investigating or preventing activities that go against Tumodo policies or laws.
Legal basis: Legitimate interest - protecting our assets and clients from cyberattacks and similar malicious actions.
Data categories: Contact details, Professional information, Data that identifies you, Other information
Event registration and attendance
Planning and hosting events that you have registered for or are attending, including sending communications related to these events.
Legal basis: Contract
Data categories: Contact details, professional information
Fraud prevention
Detecting and preventing potentially prohibited or illegal activities, and comply with legal obligations and requirements. This includes issuing invoices to customers and fulfilling applicable fraud prevention laws.
Legal basis: Legitimate interest - protecting our business and clients from fraudulent actions with both internal and external sources.
Data categories: Contact details, Professional information, Data that identifies you, Other information
Complying with legal obligations
Fulfilling valid requests from authorities and complying with applicable regulation on terrorism prevention and other legal requirements.
Legal basis: Legal obligation
Data categories: Contact details, Professional information, Data that identifies you, Other information

Your privacy choices and rights
Your choices
You can choose not to provide us with personal data
If you choose to do this, some website functionalities may not work as intended, and you will be unable to access our app.
You can turn off cookies
You have the option to block cookies by changing your browser settings or using the cookie banner on our website. Additionally, you may delete cookies via your browser settings. Certain services may not function properly if cookies are turned off.
You can ask us not to use your data for marketing
Unless we rely on your consent, which you can also withdraw at any time, we will notify you if we plan to utilize your information for marketing purposes and whether any third parties will be involved. If you wish to opt out of marketing, please contact us at hello@tumodo.io
Your rights
You can exercise your rights by sending us an email at hello@tumodo.io
You have the right to access information we hold about you
You have the right to request additional information about:
* The categories of data we process
* The purposes of data processing
* The categories of third parties to whom the data may be shared
* The length of time the data will be stored (or the criteria used to determine this)
* Your other rights relating to our use of your data
We will respond to your request with the requested information within one month, unless providing such information would harm the rights and freedoms of others, such as another person's confidentiality or intellectual property rights. If we cannot provide the information for this reason, we will inform you of our inability to do so.
You have the right to make us correct any inaccurate personal data about you
If the data we hold about you is incorrect, please correct it on your Tumodo account or send us an email to correct it at hello@tumodo.io
You can object to us using your data for profiling you or making automated decisions about you
We don't adopt any decisions that could affect you in a significant manner based solely on automated processing of your data. Our decision-making processes related to your requests are conducted with human intervention.
You have the right to port your data to another service
We can give you a copy of your data in a commonly used digital format that can be shared with another service. However, we cannot share data about another person without their consent.
You have the right to be ‘forgotten’ by us
You can ask us to delete any personal information we have about you if we no longer need it for your use of Tumodo. This may not always be possible (for example, if we have a contract with you), but we will let you know if we cannot delete your data.
You have the right to lodge a complaint regarding our use of your data

How secure is the data we collect?
We have a comprehensive security program designed to keep your personal data safe.
* ISO 27001, ISO 27017, ISO 27018, SOC 1, SOC 2, SOC 3, PCI DSS Level 1, and BSI’s C5 certified data center (AWS).
* Encryption in transit and at rest with both the platform and at the Tumodo endpoint.
* Firewalls on Network and Application Layer.
* Data pseudonymization where necessary.
Check our Security Whitepaper for more information. And please remember:
* You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure
* You are responsible of your username and password: keep them secret and safe!
* If you believe your privacy has been breached, please contact us immediately on hello@tumodo.io
* Our content may include links to third-party websites and apps. Please note that this privacy policy does not apply to any third-party website or app. We are not responsible or liable for the privacy policies or practices of any third-party websites or apps. Before submitting any personal data to these websites, please review their policies.

How long do we store your data?
We will keep your personal data as long as you are in a relationship with Tumodo. If the relationship ends, for any reason, we will block your personal data for the entire duration of any and all statutory limitation periods that apply to the processing. This is to prove that we are complying with our legal and contractual obligations. Once these periods have passed, we will either delete or anonymize your personal data.

Third parties who process your data
We may share your data with different companies or organizations for the following reasons:
* Data processors: We may share your data with service providers who help us provide our services well. These providers include tools for customer service, marketing, operational optimization, cybersecurity, financial services, and Tumodo's affiliates. We sign agreements with these providers to protect your privacy.
* Professional advisors: We may need to share your information with professional advisors, such as accountants, auditors, insurers, and law firms, in relation to the professional services provided by them.
* Integration partners: If you have shown interest in one of our integration partner's products or services, we may share your contact information so they can contact you as your company's representative. This disclosure is necessary in order to fulfill your request.
* Public bodies: We may share your data with government and law-enforcement agencies, courts and tribunals if we are required to by law or to make or defend legal claims to protect our rights or the rights of others, including you.
If we ever need to share your data with any other category of third parties in the future, we will let you know.

We use cookies to enhance your interaction with Tumodo. These cookies may be 'session' cookies, which are deleted when you leave our website or app, or 'persistent' cookies, which remain on your device and allow us to recognize you when you return, providing a tailored service.
Please check our Cookies Policy for more information on how we use cookies.
How can I block cookies?
To block cookies, activate a setting on your browser that allows you to refuse their setting. You can also manage your preferences with our cookie banner, or delete cookies through your browser settings. However, if you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website or app may not function fully. In some cases, our website or app may not be accessible at all. Please note that we have no control over how third parties use cookies when they are used.