California Consumer Privacy Act (CCPA)

Updated September 10, 2020

Overview

The California Consumer Privacy Act of 2018 (“CCPA”) becomes effective on January 1, 2020 and creates a variety of privacy rights for California consumers. We share the same information about our practices with everyone but use this notice to make disclosures required by the CCPA.

This notice includes the following parts:

Transparency: Tarmin is transparent about how personal information is collected, used & shared.

Control: Tarmin puts the customer in control of their personal information, including accessing and deleting personal information.

Benefits: Tarmin uses personal information to benefit the Customer and improve their experience.

To learn more about Tarmin's privacy policy visit www.tarmin.com/privacy.

Transparency

What Personal Information We Collect

Customers have the right to know what kinds of personal information Tarmin is collecting and our business purposes for that collection.

Tarmin collects data from customers through interactions with the customer and through products. Customers provide some of this data directly, and Tarmin gets some of it by collecting data about interactions, use, and experiences with our products. The data we collect depends on the context of the customers interactions with Tarmin and their choices, including privacy settings and the products and features being used. Tarmin also obtains data from third parties.

Customers have choices when it comes to the technology they use and data they share. When Tarmin asks customers to provide personal data, they can decline. Many of our products require some personal data to provide you with a service. If the customer chooses not to provide data required, the customer cannot use that product or feature. Likewise, where Tarmin needs to collect personal data by law or to enter into or carry out a contract, and the customer does not provide the data, Tarmin will not be able to enter into the contract; or if this relates to an existing product the customer is using, Tarmin may have to suspend or cancel it. Tarmin will notify the customer if this is the case at the time. Where providing the data is optional, and the customer chooses not to share personal data, features like personalization that use such data will not work.

How We Use Your Personal Information

Customers have the right to know how personal information is obtained, how it is used, and our business purposes for that use. Tarmin uses the data collected to provide customers with rich, interactive experiences. In particular, Tarmin uses data to:

• Provide products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions requested
• Improve and develop our products
• Personalize products and make recommendations
• Advertise and market products, which includes sending promotional communications, targeting advertising, and presenting relevant offers

Tarmin also uses the data to operate our business, which includes analyzing performance, meeting legal obligations, developing workforce, and doing research.

In carrying out these purposes, Tarmin combines data collected from different contexts or obtain from third parties to give customers a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

How We Share Your Personal Data

Customers have the right to know if their personal information is shared with any third parties. Tarmin may share personal information to have Service Providers, as defined by the CCPA, perform services specified by written contract. In addition, Tarmin may share personal information with third parties for other notified purposes, as permitted by the CCPA. Tarmin shares customer personal data with consent or to complete any transaction or provide any product customers have requested or authorized. Tarmin also shares data with Tarmin-controlled affiliates and subsidiaries; with vendors working on Tarmin’s behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights and property of Tarmin and its customers.

We Do Not Sell Your Personal Information

Customers have the right to know whether their personal information is being sold. Customers personal information is sold when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA.

Control

Right to Know, Right to Receive, Right to Delete

Customers have the right to:

• Know what specific pieces of personal information Tarmin has collected and retained about you over the previous 12 months.
• Receive a copy of your personal information.
• Delete your personal information.

Tarmin makes it easy for you to exercise your rights. If you want to control personal data processed by Tarmin, please contact us at www.tarmin.com/Contactus. Tarmin may ask to verify your identity or the identity of your authorized agent before proceeding.

Right to “Opt-Out” of “Sale”

Tarmin does not sell your personal information, so we do not offer an opt out.

Benefits to You

Non-Discrimination

The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.