Tango Technology, Inc.

1. Purpose of Policy

We are committed to protecting your privacy as you use our Service! We created this Privacy Policy (“Policy”) to give you confidence as you use our website, tango.us (the “Website”), our software (“Software”), as well as any other related services provided by us (collectively, the “Service”). This Policy covers how we collect, use, store, and share various information that, on its own or in combination with other information, may be used to identify individuals (“Personal Data”). All references to “we”, “us”, “our”, or “Tango” refer to Tango Technology, Inc., a Delaware corporation. All references to “Company” refer to your employer in such cases where Tango has entered into a contract with such Company to provide the Service to the Company’s employees and other personnel. All references to “you”, “your”, or “Authorized User” refer to the individual agreeing to this Policy, and if applicable, to whom the Company has granted administrative access to the Service. In situations where you are engaging the Service in your individual capacity and not through your employer (an “Individual Customer”), responsibilities of the Customer described herein are your responsibilities. Individual Customers and Company are each referred to as “Customer.” Do not hesitate to contact us at privacy@tango.us if you have any questions or want to discuss this Policy.

This Policy also describes our practices related to information of individuals with whom we communicate for marketing or promotional purposes but who may not otherwise be users of the Software (“Marketing Recipients”). By using the Software and agreeing to this Policy, or by agreeing to this Policy as a Marketing Recipient, you consent to the privacy practices described in this Policy.

2. Software

The Software is a proprietary software that helps the Customer and users develop training and documentation materials for the Customer's employees (the “Employees”), partners, customers, and other parties.

3. Information We Collect and How We Use It

Required Information You Voluntarily Provide Us.

When you begin using the Software, you will be required to provide us with various information that, on its own or in combination with other information, can used to identify you as an individual (“Personal Data”) for the purposes of creation an account on the Software (your “Account”). Such Personal Data includes your first and last name, your email address and phone number, and your physical address, as well as information about the Customer, your role there and how you work.

Personal Data We Collect from Marketing Recipients.

In addition to the Personal Data we collect from users of the Service, we collect Personal Data from Marketing Recipients who are interested in learning more about our products and services. This Personal Data consists of basic contact information such as the Marketing Recipient’s name and email address. This Personal Data is collected by us when Marketing Recipients sign up for commercial emails from us via online or offline sign-up forms, and through other means such as email. For Marketing Recipients who are not otherwise users of the Service, we only use your Personal Data to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with that are related to the Service.

‍Optional Information You Voluntarily Provide Us.

In addition to the required information that you provide to us in order to use the Service, there are various pieces of information you can, or may in the future be able to, choose to provide as part of your use of the Service. Further, now or in the future, we may allow you to provide us with access to additional information and data through integrations with third party goods and services. The various categories of information in this subsection is, or may be, considered Personal Data, and is used for the purpose of providing you with the Service’s functionality. While all of the information described here may not be required to use the Service, some aspects of the Service may not be available if you choose not to provide us with such information.

Tango may also have help forums, message boards and/or chat areas, where users can exchange ideas and communicate with one another. When posting to a help forum, message board or chat area, please be aware that the information is being made publicly available online and the user does so at his or her own risk.

‍Information Collected Automatically As You Use The Service; Special Information.

In addition to the information that you provide to us voluntarily, Tango may, now or in the future, automatically collect information through the Service about how you use and interact with the Service and other similar activities in order to better understand our users and how they use the Service, and to improve the Service.

And, due to the nature of our Service, which records screen activity during capture and guidance sessions, Tango may inadvertently collect information while you use the Service. This information may include your physical address, email address, phone number, information related to or derived from your address book and contacts, photos, videos, web browsing history and any other information visible on your screen during a session recording using the Service. This could also include Special Information, which means your Personal Data, if you are an Individual Customer, or the Personal Data of Employees, including, without limitation, Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning a natural person's sex life or sexual orientation.

To be clear, Tango does not want or need your Special Information. It’s our view that using your Special Information in any manner would be unethical and inconsistent with Tango’s values. We encourage all Individual Customers and Authorized Users to take care to close out any information displayed on their screens before initiating a Tango capture or guidance session. Still, Personal Data, including Special Information, may from time to time be recorded during a session. To the extent your Special Information is recorded during a Tango session, it will be stored, secured and accessible only in the manner described in this Privacy Policy. We encourage you to review our data storage and security protocols described in Section 6, and we welcome your questions.

Note that the Customer is responsible for obtaining all legally required consent to collect, input, and transmit Personal Data, including, without limitation, all Special Information, into and through the Software.

‍Cookies.

A cookie is a small text file that can be stored on and accessed from your device when you visit and use our Service. Cookies enable us to “personalize” the Service for users by remembering information about our users. The Service uses cookies to store your preferences, display content based upon what users view to personalize your visit, analyze trends, administer the Website, and track users' movements around the site. We use cookies on our Website and our Software.

Please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. In addition, please note that third parties such as advertisers or analytics providers may also use cookies and similar technologies while you are browsing or using the Service. We unfortunately have no control over such third parties’ use of these technologies.

Cookies can be categorized in different ways:

• First-Party vs. Third-Party Cookies:  As the name implies, first-party cookies are put on your device by Tango. Third party cookies are placed on your device not by Tango, but by a third party. The Service uses both first-party and third-party cookies.

• Purpose:

1. Necessary - These cookies are necessary to allow us to operate Service so you may access it as you have requested. These cookies, for example, enable us to remember your previous actions within the same browsing session and secure our Service.
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2. Analytical - These cookies are used by third party service providers (i.e. third party cookies) to analyze how the Service is used and how the Service is performing. These cookies include, for example, Google Analytics cookies.
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3. Functionality – these cookies let us operate the Service in accordance with the choices you make. These cookies permit us to “remember” you in between visits. For instance, we will recognize your username and remember how you customized the Service, and these cookies allow us to provide you with the same customizations during future visits.
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4. Third Party Advertising – These third-party cookies collect information about your activities to provide you targeted advertising and to measure the effectiveness of our marketing campaigns. The third-party service providers that generate these Cookies, such as Facebook, have their own privacy policies, and may use their Cookies to target advertising to you on other websites, based on your visit to our Service.

First-Party Cookies

We use our cookies for security purposes of customizing your experience with our Service, improving our Service, and tailoring our messaging. Below are some examples of how we use first-party cookies.

• Log & Device Data – These cookies help us determine what type of devices you use, so that we know which environments to prioritize building features and workflows for.
• Analytics Data – These cookies help us understand how you use the Service so that we can improve the Service.
• Security Data – These cookies help us determine whether to log you out of inactive sessions, which devices you are logged into, and from where.

Third-Party Cookies

• Google Analytics Cookies - We use Google Analytics to analyze our web traffic and improve user experience. Google Analytics uses cookies to generate statistical information about how our Website is being used. For more information on these cookies, please see here.

Web Beacons.

A web beacon is an unobtrusive feature on web pages or emails that enables us to check whether a user has accessed some content. We may use web beacons to better understand how you and other users interact with the Service.

Other Collection.

We also may use, now or in the future, certain other features in the Service that help us better understand your use of the Service and improve the Service for everybody. These features include session replays, which permit us to review your interaction with the Service; error reporting, through which we may collect information about bugs in the Service; and event analytics, which enable us to understand your activity while you use the Service. Our workflow capture and workflow guidance products, core components of the Service, record your screen while you have the features enabled.

Other Anonymous Data We Collect.

When you use and visit the Service, we may also use third-party services, such as Google Analytics and others, which use cookies to collect generic, anonymous information that does not identify you (see above for more information on cookies). We use this information to better understand how users interact with the Service and to improve your user experience while using the Service.

Do Not Track Signals.

We do not track you or collect your information across third-party websites or online services. Thus, we do not receive Do-Not-Track signals, or other similar signals. To the extent that we do receive any such signals, we will not comply with them as it is not an aspect of the functionality of our Service.

4. Purposes of Collection and Legal Bases for Use

We use the Personal Data described above primarily for providing you with the core aspects of the Service, namely to provide you with the Software and its functionality.

However, we may also use your Personal Data, or aggregated and/or anonymized Personal Data (but not Personal Data that can be used to identify users), for our own purposes of understanding our users and how they use the Service, as well as improving the Service over time. We may also use your Personal Data to better understand how you and users like you may be better served by Tango, and to offer you opportunities to try out various aspects of the Service, including new features that we may from time to time introduce. By using the Service, you consent to these additional uses.

The legal grounds for our processing your Personal Data for the purposes above are:

• first and foremost, you provided your consent by agreeing to this Policy, which you may withdraw at any time by emailing us at privacy@tango.us;
• it is necessary for our contractual relationship;
• the processing is necessary for us to comply with our legal or regulatory obligations; and/or
• the processing is in our legitimate interest as a provider of the Service (for example, to protect the security and integrity of our systems and to provide you with customer service and the core functionality of the Service).

5. How we share your information

We do not sell or share your Personal Data with advertisers. We also do not share your Personal Data with other third parties except to the extent that it is in furtherance of the Service.

Information Shared By You Through The Service.

You may, now or in the future, be able to choose to voluntarily share information collected through the Service through email, or other means of communication.

Unless you are an Individual Customer, your Company may have access to your Personal Data. Tango acts at the direction of your Company (if applicable) with regard to sharing your Personal Data with your Company.

Our Personnel and Vendors.

To be able to effectively provide you with the Service, and to improve the functionality of the Service, we may disclose your Personal Data to our employees, contractors, agents, vendors, and other similar persons or entities to the extent that such persons or entities have a need-to-know such Personal Data in furtherance of the Service. Our third-party vendors (“Third-Party Vendors”) provide us with various types of services, including without limitation, hosting services, payment services, marketing software services, and customer relationship management software services to name a few. We may share your Personal Data, including Employees’ Special Information, with our Third-Party Vendors.  

Your Employer.

If you are an Individual Customer and you register your Account with an email address on a domain owned by your employer, we may let your employer know about your Account when we offer our Service to your employer. In these instances, we will only share your name and email address with your employer.

‍Sale of Company or Assets.

In the event that we sell all or substantially all of our company or its assets, including the Personal Data collected through the Service, we may transfer your information, upon reasonable notice to you, to the acquiring company.

Other Third Parties.

In addition to our practices described above, we may share your Personal Data  if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend the rights or property of Tango, or (3) prevent an emergency involving danger of death or serious physical injury to any person. We will only share your Personal Data for the foregoing reasons to the extent permitted by EU General Data Protection Regulation (“GDPR”).

6. Storing Your Information

Duration of Storage of Personal Data.

We will store your Personal Data for as long as it is needed to provide the Service, however, we may not know if you have stopped using the Service so we encourage you to contact us if you are no longer using the Service. However, if required by applicable law, we may retain your Personal Data for such period as may be required by such law. To continue to provide an effective service, we may store non-Personal Data perpetually and may anonymize your Personal Data and store that anonymized information perpetually.

Additionally, as described in this Policy, we use third parties to provide the Service and do not have full control over their practices related to storage and retention of your Personal Data. However, we will work with such third parties to delete or modify your Personal Data to the extent required by GDPR and the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses pursuant to Decision 2010/87/EU) (the “SCCs”).

Security.

We use reasonable efforts to secure your Personal Data and to attempt to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we require our personnel to sign confidentiality agreements that extend to your Personal Data; we informally review the privacy practices of new products and services that we integrate into our Service; and we restrict access to your Personal Data to individuals within and outside of Tango who need access to such information to provide the Service. We also use SSL/TLS protocol technology to encrypt user connections to our systems. Your Personal Data is also encrypted while stored within our databases. In addition, we rely on the technical safeguards provided by the Third-Party Vendors we use to host, store, and process your Personal Data. However, you acknowledge and agree that loss, misuse, and alteration may occur despite our efforts to protect your Personal Data. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration, except to the extent required by GDPR, the SCCs, or other applicable law.

7. California Users

For purposes of this Section 7 only, the terms “personal information,” “collection,” “sell,” “business purpose” and “commercial purpose” have the meaning given to them under the California Consumer Privacy Act of 2018 (the “CCPA”).

If you reside in California, may you have certain rights as set forth below. These rights are in addition to any other rights you may have under this Policy. If you have any questions about these rights or how to exercise them, please contact us as described below. Please note that we may disclose your personal information for business or commercial purposes as described in this Policy. For more information about the categories of personal information we collect, the sources from which we collect personal information and how use, disclose and share such information, please see Sections 3, 4, 5 and 6 of this Policy.

Disclosure and deletion requests.

You may have the right to request that we disclose to you what personal information about you we collect, use, disclose and sell. Subject to certain limitations in the CCPA, you also may have the right to request that we delete your personal information. You may submit such a request by contacting us as described below. If you submit a request by email, your email must include “California Request” in the subject line. We will not discriminate against you for exercising your rights under the CCPA.

In addition, you may have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. Please note that we do not disclose your personal information to any third parties for their direct marketing purposes. To make a request, please send us an email at privacy@tango.us, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

Right to opt out.

The CCPA also provides California consumers the right to opt out of the sale of their personal information. As explained in this Policy, we do not sell the personal information of our users.

Verification.

We reserve the right to verify any request made under the CCPA by asking you to provide supporting documentation that the request is submitted by you, although we are not obligated to verify a request. You may also choose to have an agent submit a request on your behalf, in which case we may, but are not obligated to, verify that the agent is authorized to act on your behalf. We assume no responsibility for responding to any consumer requests.

8. Your Choices

You can change some of your Personal Data through the account settings provided on the Service. In addition, if you wish to access, receive a copy of, change or delete the Personal Data we hold about you, you may contact us as described at the end of this Policy.

You may withdraw the consent granted in this Policy for us to use the Personal Data described in this Policy by contacting us as described at the end of this Policy. Please note that if you do so, it will not affect the lawfulness of the use of your Personal Data based on your prior consent.

In addition, you may contact us as described at the end of this Policy to request that we do not disclose your Personal Data to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors) or to request that your Personal Data not be used for a purpose that is materially different from the purposes for which it was originally collected or for purposes subsequently authorized by you.

Upon receipt of any of the above request(s), we will use reasonable efforts to reflect any changes you request in our databases to the full extent required by GDPR, the SCCs, the CCPA (if applicable), or other applicable law.

If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

9. International Visitors and Data Transfers

The Service is hosted in the United States and is intended for visitors located within the United States as well as users located outside of the United States. If you choose to use the Service from the European Economic Area (“EEA”), Switzerland, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Data outside of those regions to the United States for storage and processing. By providing any information, including Personal Data, on or to the Service, you consent to such transfer, storage, and processing.

Information collected in the EEA may be transferred, stored and processed by us or third parties (as provided in this Policy) in the United States and other countries whose data protection laws may be different than the laws of your country. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by entering into SCCs with the relevant third party.

As described in this Policy, we may share Personal Data with third parties and may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

10. Government Requests

From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of Personal Data.

11. Third-Party Services and Practices are Beyond Our Control

The Service may utilize numerous third-party services as part of the functionality of the Service, such as hosting services, analytics providers, communications services, and other vendors; and we may share your Personal Data with third parties to the extent explained in this Policy.  We have no control over such third parties, except to the extent required by GDPR and the SCCs. Thus, we make no guarantees about, and assume no responsibility for the information, services, or data/privacy practices of third parties, except to the extent required by GDPR and the SCCs. We encourage you to review the privacy practices of such third parties.

12. Changes to This Policy

Tango reserves the right to change this Policy from time to time without notice. Any changes to this Privacy Policy will become effective on the “Effective Date” indicated above. If you continue to use the Service after the Effective Date, you consent to the new Policy. Tango will always have the latest Policy posted on the Service.

Please reach out to Us with any questions or feedback

If you have any questions about this Policy or our Service, please feel free to contact us by email at privacy@tango.us or by mailing us at the following address:

Tango Technology, Inc

2261 Market Street #4999

San Francisco, CA 94114

Data Protection Officer

In addition, we have appointed a Data Protection Officer (“DPO”). Our DPO can be contacted directly by email at DPO@tango.us or by mail at:

Tango Technology, Inc.
ATTN: Data Protection Officer
Tango Technology, Inc

2261 Market Street #4999

San Francisco, CA 94114

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