Tetra House Privacy Policy

Effective Date: [09/12/2021]

Last Updated: [09/12/2021]

Tetra House and its affiliated entities (“Tetra,” “we,” “us,” or “our”), are committed to your privacy and the security of your personal information. 

This Privacy Policy (“Privacy Policy” or “Policy”) explains the types of personal data we may collect from visitors to www.tetra.house any all related websites, apps, and/or web-based services (our “Sites”), or in the context of any products and services we provide whether online or offline (our “Services”).  This Policy also describes how we use personal data, the purpose for sharing and recipients of personal data, and your available rights and choices associated with that data.

In some instances, this Policy may be in addition to other terms, conditions, or disclosures that apply to other programs involving our collection of personal data about you (“Additional Terms and Policies”).  To the extent there is a conflict between this Policy and any Additional Terms and Policies, the Additional Terms and Policies will control unless they expressly state otherwise. This Policy does not apply to third-party sites, products, or services, even if they link to our Sites or Services, and we encourage you to read the privacy policies of any third-party site with which you choose to interact.

We also encourage you to review our Terms of Use to understand how your personal information will be treated as you make full use of our Sites.  Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Through your continued use of our Services, you acknowledge the collection, use, and sharing of your personal data as described in this Privacy Policy.  If you object to anything in this Privacy Policy, you may cease using the Services and, if applicable, terminate your account.

Table of Contents

1.    Our Collection of Personal Data.  We collect personal data when you register and utilize our Sites and Services, including automatically collecting data. 

2.    Our Use of Personal Data.  We use your personal data in many ways, including to provide our Sites and Services, communicate with you, maintain a safe and secure environment, and comply with legal obligations. 

3.    Our Sharing of Personal Data.  We share your personal data only for our own internal purposes, to promote our Sites and Services, and according to your notice and consent. 

4.    Your Rights and Choices.  We allow you to change certain privacy and communications preferences at any time. 

5.    Cookie Policy.  We may collect personal data from you automatically through the use of cookies and other tracking technologies. 

6.    Data Security and Retention.  We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal data. 

7.    International Data Transfers.  We may transfer personal data, including sensitive data, to the United States or other countries from which the personal data was collected for storage, processing, and use by us.

8.    Children’s Privacy.  We do not knowingly collect personal data from individuals under the age of 18 years without parental consent. 

9.    Links to Other Sites.  This Privacy Policy does not apply to third-party sites. 

10. European Privacy Notice.  Individuals located in Europe may have specific rights applicable to the Sites and Services. 

11. Other Privacy Notices.  Individuals located in various other locations may have specific rights applicable to the Sites and Services. 

12. Updates to This Privacy Policy.  We may update this Privacy Policy from time to time. 

13. Contact Us.  You may contact us in several ways. 

1. Our Collection of Personal Data

For the purposes of this Privacy Policy, unless otherwise noted, “personal data” means any information that relates to an identified or identifiable individual or household.  Personal data does not include publicly available information or information that has been anonymized, de-identified, or aggregated. 

a.            Personal Data You Provide Us

Tetra may collect the following categories of personal data about you that you choose to provide to us when you use the Sites and Services:

·      Contact information.  You may have the opportunity to provide various contact information, including your first and last name and email address.

·      Project information.  As part of a request to receive a quote from us, you may have the opportunity to provide certain information related to your proposed project, including your website URL and the title, genre, word count, comparable titles, and other details about your project.

·      Communication information.  When you respond to Tetra emails or messages, we may collect your email address, name, and any other personal data you choose to include in the body of your email or responses. 

·      Payments and other transaction-related information.  In order to facilitate certain transactions, you may be asked to provide your payment card information and bank account information.

b.           Personal Data From Third-Party Sources

We may collect personal data about you from third-party sources, including third party list providers and other third parties to help us provide, improve, and promote the Sites and Services.  These third parties collect and provide this personal data to us pursuant to their privacy policies.  We may supplement the information that you provide with information that we obtain from these sources, including both online and offline data providers. 

c.            Personal Data We Automatically Collect

When you interact with our Site and Services, we may automatically collect data regarding your online behavior, including your header information, referred information, browsing and usage history, Internet Protocol (“IP”) address, device identification number, device and browser information, and geolocation (“Usage Data”). 

This data is collected using various technologies, including cookies, pixels, and similar tracking technologies, that may be administered by us or by third parties.  Please review our Cookie Policy[A2]   for more information regarding the use of these technologies. 

Our Site uses various analytics tools in order to maintain and improve our web-based services, including Adobe Analytics and Google Analytics.  These tools may automatically collect personal data about you, such as your IP address, in order to track and report website traffic.  Adobe and Google uses the collected data to monitor and analyze the use of our Sites and Services solely for our benefit.  If you have already consented to the Adobe Analytics and/or Google Analytics tracker, you can choose to block or delete those trackers by referring to your browser’s settings and instructions.  For more information on Adobe’s and Google’s privacy practices, please visit the Adobe Privacy Policy[A3] and Google Privacy Terms[A4]  web pages.

Your browser or device may include “Do Not Track” functionality.  At this time, the Sites do not respond to browser “Do Not Track” signals.

d.           Anonymized and De-identified Information

We may create anonymous or de-identified data from personal data by removing data components that make the data personally identifiable to you or through obfuscation or other means.  Our use of anonymized and de-identified data, data which no longer can be used to identify you or any other particular individual, is not subject to this Privacy Policy.

2. Our Use of Personal Data

a.   Our Products and Services

We use the personal information we collect to provide, maintain and improve our Services.  This includes:

·      To provide you with requested Sites and Services;

·      To customize your experience on our Sites and Services according to your behavior and preferences;

·      To provide you and others with marketing and promotional information that we believe may be of interest to you, whether offered by us or our third-party partners, and to personalize, measure, and improve such offers;

·      To process payments;

·      To facilitate any promotions we may offer;

·      To verify your identity before using certain Sites and Services;

·      To provide you with customer service and support, and to facilitate other communications that you request or that are required to render Services to you;

·      To perform analytics for new and existing Sites and Services;

·      To maintain and improve the quality of our Sites and Services;

·      To protect ourselves, you, and others; prevent fraud; and create and maintain a trusted, secure, and reliable online environment; and

·      To comply with our legal obligations; respond to subpoenas, court orders, or legal process; or to establish or exercise our legal rights or defense against legal claims.

b.  Digital Marketing Communications

We may send you promotional email communications about our Sites and Services or other products and services that we believe may be of interest to you, invite you to participate in events or promotions, or otherwise communicate with you for marketing purposes, as allowed by applicable law.  Your receipt of these communications will be consistent with your prior opt-in or subscription to those types of communications.  You may opt out of receiving any, or all, of these communications from us via the unsubscribe link provided in such emails or by contacting us.

3. Our Sharing of Personal Data

We may share your personal data with the trusted third party entities described below:

·      Our service providers, as necessary for them to provide services on our behalf, such as website hosting, payment processing, data analysis, marketing, email delivery, technical support, and customer service.  These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use the information for any other purpose. 

·      Our affiliates, both with and among them, for the purposes identified in Section 2 above and in accordance with the circumstances in which you provided your personal data.

·      Third-party platform advertising.  We may share your information with third-party platform providers who assist us in serving advertising regarding the Services to others who may be interested.  We also partner with third parties (such as Facebook and Google) who use cookies and other tracking technologies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests. 

·      In connection with a business transaction, subject to applicable law, in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.  If any such transaction occurs, the purchaser will be entitled to use and disclose the personal data collected by us in the same manner that we are able to use it, and the purchaser will assume the rights and obligations regarding personal data as described in this Privacy Policy.

·      For compliance and harm prevention, including to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.  We also may provide information in order to investigate, prevent, or take action regarding illegal activities or wrongdoing; to protect the rights, property, or safety of Tetra, its users, and others; to enforce our agreements; or as otherwise required by law.

4. Your Rights and Choices

a.            Marketing Communications 

If you would like to stop receiving a Tetra newsletter or other marketing or promotional messages, notifications, or updates sent via email, you may do so by following the unsubscribe instructions that appear in those email communications.  You may also opt-out of these messages by contacting us[A5] .  Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us.

b.           Other Rights Regarding Your Data

For more information on the rights that you may be entitled to regarding your personal data based on your location, please review Sections 10 and 11 below.

5. Cookie Policy

The Sites may use cookies and similar technologies to improve user experience, for performance and analytics, and to improve our content, products, and services.  A “cookie” is a small text file that a web server stores in browser software.  A browser sends cookies to a server when the browser makes a connection to that server (for example, when requesting a web page from the same domain that created the cookie). 

The general purpose of cookies is to remember a browser over time and distinguish one browser instance (or user) from all others.  Some cookies and other technologies may track the personal data users provide when they interact with a site, and may store such personal data.  We use first-party and third-party cookies to ensure that our Sites and Services function properly, to understand how individuals use and engage with our Sites and Services, to analyze and improve our Sites and Services, and to facilitate targeted advertisements across websites and platforms.  For example, we use third-party cookies to analyze and improve our Sites and Services so that we can report on usage activities and trends.

We use cookies for the following purposes:

Necessity.  To enable features that are necessary for providing you the services on our Sites, such as keeping you signed in, improving security, and preventing and detecting fraud.

Preference.  To allow us to remember your preferences and identify you when you return to our Sites.

Analytics.  To allow us to understand how our Sites are being used, track site performance and content views, and make improvements to the content, products or services.

Advertising.  To deliver targeted advertising based on your preferences, location, and/or interests across different services and devices and measuring effectiveness of ads.

Social Media.  To enable the sharing of content from our Sites through social networking and other sites.

Most browsers are initially set up to accept cookies, but you can reset your browser to block or delete all cookies in your browser’s settings using the links provided below.  Please note that if you block essential cookies, certain parts of the Site may not function properly. 

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Opera: https://help.opera.com/en/latest/web-preferences/#cookies

If you wish to opt out of our sharing of the data that is gathered when you visit our Sites, we may present you with various preferences options in a cookie banner upon first accessing our Sites.

In addition, if you wish to opt out of such sharing for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative [A6] or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising [A7] for more information about opting out of seeing targeted digital advertisements.  Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings.  You may also visit these websites for more information on how you can opt back in to the sharing of data.  Please note that Tetra does not maintain this web tracking data in an identifiable manner. 

Opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Services or on other websites.

We do not support Do Not Track functionality.  Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.  You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

6. Data Security and Retention

We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, misuse or disclosure.  Your personal data is accessible to only a limited number of personnel who need access to the information to perform their duties.  Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy.  We retain and use personal data to the extent necessary for our legitimate business purposes, to comply with our contractual obligations and to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), as well as resolve disputes, and enforce our legal agreements and policies.

7. International Data Transfers

We may transfer personal data, including sensitive data, to the United States or other countries from which the personal data was collected for storage, processing, and use by Tetra.  Those countries may have data protection rules that are different from those of your country.  We will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this Privacy Policy.  Personal data transferred to another country may be subject to lawful access requests by courts, law enforcement agencies, or other government authorities in those other countries.  If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we comply with any applicable laws to provide an adequate level of data protection to the U.S., as described further in Section 10 below.  Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use EU Standard Contractual Clauses with data recipients located outside the EEA or the UK as well as other appropriate measures and safeguards.

8. Children’s Privacy

Our Sites and Services are not intended for or directed to children.  We do not knowingly collect personal data from individuals under the age of 18 years without parental consent.  No personal data should be submitted to our Sites by individuals under the age of 18.  If we learn we have collected or received personal data from a child under the age of 18 without parental consent, we will delete that personal data as permitted by law.  If you believe we may have any collected personal data from a child under the age of 18 without parental consent, please submit a written request via the email to contact@tetra.house.

9. Links to Other Sites

Our Sites may contain links or otherwise provide access to other third-party sites, which may include websites, mobile applications, or Internet locations.  Please note that we have no control over and are not responsible for third-party sites, their content, or any products or services available through the third-party sites.  Our Privacy Policy does not apply to third-party sites.  We encourage you to read the privacy policies of any third-party sites with which you choose to interact.

10. European Privacy Notice

For the purposes of this European Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person. 

We rely on one or more legal bases to process your personal data under applicable law.  We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our Terms of Service; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligation such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you. 

Legitimate business interests.  We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below.  To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others.

·      Provide, improve, and develop our Sites and Services, including to deliver your requested Services, send you messages and provide user support, customize the Sites and Services to better fit your needs as a user, develop new Sites and Services, and perform internal analytics and research and development.  This also includes sharing personal data with our trusted service providers that provide services on our behalf.

·      Protect you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable Sites and Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property.  In connection with the activities above, we may conduct internal research and profiling based on your interactions as a participant in various Sites and Services, content you submit to the Site and Services, and information obtained from third parties.  

·      Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent.  We may also use personal data to understand our user base and the effectiveness of our marketing.  This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you. 

In certain circumstances, individuals located within the EEA, UK, and Switzerland are entitled to the following data protection rights regarding their personal data:

·      Right to access.  You have the right to request confirmation of whether Tetra processes personal data relating to you, and if so, to request a copy of that personal data.

·      Right to rectification.  You have the right to request that Tetra correct or update your personal data that is inaccurate, incomplete or outdated.

·      Right to deletion.  You have the right to request that Tetra erase your personal data in certain circumstances provided by law.

·      Right to restrict processing.  You have the right to request that Tetra restrict the use of your personal data in certain circumstances.

·      Right to object to processing.  You have the right to object to Tetra’s processing of your personal data, under certain conditions.

·      Right to data portability.  You have the right to request that Tetra export the data that we have collected to you or another company, under certain conditions.

Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time.  If you would like to exercise any of these rights, please submit a written request to contact@tetra.house.

You also have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority.  You can view the contact information for your data protection authority here[A8] .

11. Other Privacy Notices

Individuals located in various other locations may have specific rights applicable to the Sites and Services. 

a.            Your California Privacy Rights

Tetra does not disclose personal information to third parties for their own direct marketing purposes unless you first affirmatively agree to that disclosure, such as in the context of our rewards program.  However, California residents additionally have the right to request information regarding such practices under California’s “Shine the Light” law.  If you are a California resident and would like to inquire further, please email contact@tetra.house.

b.           Your Nevada Privacy Rights

Nevada residents have the right to request to opt out of any sale of their personal information under Nevada SB 220.  We do not currently sell personal information under Nevada law; however, you may still request to opt out of the future sale of your personal information.  If you are a Nevada resident and would like to make such a request, please submit a written request written request to contact@tetra.house. You must include in your email or mail request your full name, email address and postal address so that we can verify your Nevada residence and respond.  In the event we begin to sell personal information after the receipt of your request, we will make reasonable efforts to comply with your request as to your personal information.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time.  The date this Privacy Policy was last updated is identified at the top of this page.  Any changes are effective when we post the revised Privacy Policy on the Sites.  If we make material changes to this Privacy Policy that expand our rights to collect new personal data or to use differently any personal data that we have previously collected about you, we will notify you and provide you with the disclosure by posting it on our Sites and/or via email.  We encourage you to review this Privacy Policy often to stay informed of how we may process your personal data.

13. Contact Us

If you would like to submit a privacy rights request as detailed above, please submit a written request by emailing us at contact@tetra.house. If you have any questions or concerns about this Privacy Policy or our privacy practices, please email us at contact@tetra.house.