Overview

This Privacy Policy (“Privacy Policy”) describes how we (Tipp, together with its affiliated companies – “Tipp”, “we” or “us”) collect and use information pertaining to each of our unregistered visitors and registered users (each, a “Visitor” or “User” (respectively), or “you”), in connection with their access to and use of Tipp’s websites (including www.tipp.i.ng and any of its subdomains, the “Website”), web applications (“Tipp Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”).

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why and how we collect and use your personal information, as well as an explanation of your statutory rights.  This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.

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Read this policy and make sure you fully understand our practices in relation to your personal information, before you access or use any of our Services.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave this website, application or service, and avoid or discontinue all use of any of our Services.  If you have any questions or concerns regarding this policy, please contact us at privacy@composir.com.

Visitor and User Information

We collect two types of information regarding our Visitors and Users:

1. Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

2. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

How we collect such information

There are two main methods we use:

1. We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website, register a User Account, and upload information, and/or download and use any Tipp Apps and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies.

2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you place purchases and/or register domain names; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel.

Why we collect such information

We collect such Non-personal and Personal Information for the following purposes:

1. To provide and operate the Services;

2. To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;

3. To provide our Users with ongoing customer assistance and technical support;

4. To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;

5. To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits; 

6. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services; 

7. To enhance our data security and fraud prevention capabilities; 

8. To comply with any applicable laws and regulations.

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We will only use your Personal Information where we are satisfied that:

1. our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with our services, to provide you with our customer assistance and technical support), or

2. our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or

3. our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our services by identifying user trends and the effectiveness of Tipp campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.

Where we store your information

Tipp Visitors’, Tipp Users’ and Users-of-Users’ Personal Information are currently stored in data centers located in the United States of America.

Tipp affiliates and service providers that store or process your Personal Information on Tipp’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

Sharing personal information with third parties

Tipp may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

Third Party Services

Tipp has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”). 

Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. 

Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third-party websites and services.

Tipp is accountable for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, Tipp remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless Tipp proves that it is not responsible for the event giving rise to the damage.

Law Enforcement, Legal Requests and Duties

Where permitted by local data protection laws, Tipp may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.

Protecting Rights and Safety

Tipp may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Tipp, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

Use of cookies and other tracking technology

Tipp uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users and their Users-of-Users with a better experience. 

Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them. 

Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences, connection stability, monitoring performance of our services and marketing campaigns, and generally providing and improving our services.

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. 

Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

Questions and Complaints

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.

Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.

We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly.  Our target response time is 30 days.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.

You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

Contacting us

If you have any questions about this Privacy Policy or wish to exercise any of your rights, please contact the Data Protection Officer team at privacy@composir. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.