Privacy Policy

Tacombi Holding N.A. LLC (“Tacombi”, “our”, “us” or “we”) grants you access to our website located at https://www.tacombi.com (the “Website”) conditioned on your acceptance of these terms (“Terms of Use”).

‍PLEASE READ THESE TERMS OF USE CAREFULLY. THESE TERMS OF USE CONSTITUTE A LEGALLY BINDING AGREEMENT BETWEEN YOU AND US, AND BY USING THE WEBSITE, YOU AGREE TO BE BOUND AND ABIDE BY THESE TERMS OF USE. IF YOU DO NOT AGREE TO THESE TERMS OF USE, YOU MUST CEASE USING THE WEBSITE IMMEDIATELY.

This Privacy Policy applies to personal information processed by us, including on our website, mobile application, and other online or offline offerings. To make this Privacy Policy easier to read, our website, mobile application, and other offerings are collectively called the “Services.”  

‍Changes to our Privacy Policy.
We may revise this Privacy Policy occasionally at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as applicable law requires. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
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Our website implements the ARIA attributes (Accessible Rich Internet Applications) technique, alongside various different behavioral changes, to ensure blind users visiting with screen-readers are able to read, comprehend, and enjoy the website’s functions. As soon as a user with a screen-reader enters your site, they immediately receive a prompt to enter the Screen-Reader Profile so they can browse and operate your site effectively. Here’s how our website covers some of the most important screen-reader requirements, alongside console screenshots of code examples:

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information you provide us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below.  For residents of certain states, additional disclosures about the information we collect are available in our supplemental disclosure below.

A. Personal Information You Provide to Us Directly

• Account Creation. We may collect personal information when you create an account, such as name, email address, and mailing address.
• Purchases. We may collect personal information and details associated with your purchases, including payment information. Third-party payment processors process any payments made via our Services. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Your Communications with Us. We may collect personal information, such as email address, telephone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect your personal information regarding the survey.

B. Personal Information Collected Automatically

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during, and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
• Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
  Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  ‍Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. Using a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a specific advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  
  Our uses of these Technologies fall into the following general categories:
• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below).
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.
• Advertising- or Targeting-Related. We may use first-party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or third-party digital properties.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to understand better how our digital Services are used and to improve and personalize our Services continually. Some of our analytics partners include:
  
  Greenhouse
  Lunchbox.io
  Stripe.com
  Toast
  Mailchimp
  Google Analytics
• Social Media Platforms. Our Services may contain social media buttons or hyperlinks, such as Instagram, which might include widgets such as the “share this” button or other interactive mini-programs. These features may collect personal information such as your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the entity providing them.
  
  ‍See “Your Privacy Choices & Rights” below to understand your choices regarding these Technologies
• Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, suppose you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site. In that case, we may collect personal information about you from that third-party application you have made available via your privacy settings.

We use your personal information for various business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

‍A. Provide Our Services
We use your information to fulfill our obligations to you and provide you with our Services, such as:

• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Content highlighting – users can choose to emphasize important elements such as links and titles. They can also choose to highlight focused or hovered elements only.
• Communicating with you about your account, activities on our Services, and policy changes; and
• Processing your financial information and other payment methods for products or Services purchased through our third-party vendors.

B. Administrative Purposes
We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

We may use your information for other legitimate business purposes as the law permits.
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C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some ways we market to you include telephone, text, and email campaigns, as well as customary audience advertising. We will obtain your express consent when required by law before contacting you by telephone or text. If you have any questions about our marketing practices or would like to opt out of using your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

• Telephone Marketing. Tacombi maintains a list of telephone number(s) and name(s) (if provided) for consumers who do not wish to receive marketing messages or phone calls. Upon a written request, consumers’ telephone number(s) will be added to our internal Do Not Call list within 30 days of receipt of such request. This record will be retained for at least five years. This list will be regularly updated, but if a telephone number changes, another request must be submitted to have the new number added to our list.  Upon an individual’s request to opt out of using your telephone number for marketing purposes, we will not make solicitations to:
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  i. Any person who has requested that we not make such calls to their residential or wireless telephone lines.
  
  ii. Any person who has put their residential or wireless phone number on a national or state Do Not Call Registry, except as otherwise permitted by law.

D. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes
We also use your personal information for other purposes as you request or as permitted by applicable law.
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De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.

We disclose your personal information to third parties for various business purposes, including to provide our Services, to protect us or others, or in the event of a significant business transaction such as a merger, sale, or asset transfer, as described below.

‍A. Disclosures to Provide Our Services
The categories of third parties with whom we may disclose your personal information are described below.

• Service Providers. We may disclose your personal information to our third-party service providers and vendors who assist us in providing our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
• Business Partners. We may disclose your personal information with business partners to provide you with a product or service you have requested. We may also disclose your personal information with business partners with whom we offer products or services jointly.
• Affiliates. We may disclose your personal information with our Tacombi affiliates, for example, for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
• Other Users or Third Parties You Disclose or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with third parties.
• Advertising Partners. We may share your personal information with third-party advertising partners through our Services. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) to deliver personalized advertisements when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “cross-context behavioral advertising,” or “personalized advertising.”
• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as outlined in “Contact Us” below.

We may also share your information with third parties as appropriate and legally permitted. The privacy choices you may have about your personal information are determined by applicable law and are described in Section 5 below.

B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, partnership, joint venture, investment, due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be licensed, sold or transferred as part of such a transaction.

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you cannot opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Use or this Privacy Policy).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out of receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• Telephone calls. If you receive an unwanted telephone call from us, you may opt out of receiving future telephone calls by following the instructions that may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
• California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. California residents may direct requests by contacting us as described in “Contact Us” below.Please note you must separately opt out in each browser and on each device.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of information, including personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by emailing you.

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data.  Additionally, we endeavor to retain all such personal information in accordance with applicable law.

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information concerning our Services without your consent, wish to review information collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it and terminate the child’s account if applicable.

Third-Party Websites/Applications. The Services may contain links to other websites/applications, and other websites/applications may reference or link to our Services. We do not control these third-party services. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, or are not responsible for, other websites or applications' privacy practices or content. Providing personal information to third-party websites or applications is at your own risk.

Tacombi is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Tacombi Holding N.A.
262 Bowery
New York, NY 10012
info@tacombi.com