Effective Date: September 18, 2015
Reasons Tumbleweed Collects Personal Information
We collect your personal information because it helps us deliver a superior level of customer service. It enables us to give you convenient access to our products and services and focus on categories of greatest interest to you. In addition, your personal information helps us keep you posted on the latest product announcements, special offers, and events that you might like to hear about.
PII We Collect
We collect the following Personally Identifiable Information (PII) from users who buy our products or services: name, e-mail address, telephone number, address, and credit card number.
The categories of personally identifiable information that we collect:
(a) Free Items: Email – Name – Address are required for you to receive any FREE goods such as our Catalog, some Study Plans and other downloads of FREE items. When you want FREE items you will be asked for your PII, Company, Suite or Apartment number and phone are optional. You will click on Payment Method but when you get there we say: “Your order is free. No payment is required.” We do it this way for the Free downloads to give you an Order Number so that if you have trouble, you can call us and we can help you. If no purchase is made, this information does not go through our credit card processors.
(b) To Purchase Items: In addition to (a), if you want to buy things from our web site, we will collect your credit card information including your card account number, CSS code number and expiry date so that you can pay for things and services that you order from the Web Site, including Plans, books, videos, how-to guides and our fully built products.
(c) Our third party credit card processors use The Payment Card Industry Data Security Standard (PCI DSS) information security standard for organizations that handle credit card and debit card information. Defined by the Payment Card Industry Security Standards Council, the standard was created to increase controls around credit card data to reduce credit card fraud via its exposure. Our website takes these measures to protect your credit and debit data: Maintain a Secure Network, Protect Cardholder Data, Maintain a Vulnerability Management Program, Implement Strong Access Control Measures, Regularly Monitor and Test Networks, and Maintain an Information Security Policy.
(d) When we send you emails, we may include a web beacon to allow us to determine the number of people who open our emails. When you click on a link in an email, we may record this individual response to allow us to customize our offerings to you. Web beacons collect only limited information, such as a cookie identifier, time and date of a page being viewed, and a description of the page on which the Web Beacon resides (the URL).
Web Beacons can be refused when delivered via email. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
Our Use of PII – No Onward Transfer Except for Needed Services – Consumer Control
(a) Because you Asked us to use it: We use your Personally Identifiable Information to create your account, to communicate with you about products and services you’ve purchased, to offer you additional products and services, and to bill you. We also use that information to the extent necessary to enforce our Website terms of service and to prevent imminent harm to persons or property. We also use your information to enable delivery or items ordered by you to your place of receipt.
(b) Why did you receive a mailing from us? Our email marketing is permission based. If you received a mailing from us, our records indicate that (a) you have expressly shared this address for the purpose of receiving information in the future (“opt-in”), or (b) you have registered or purchased or otherwise have an existing relationship with us, or that you may have obtain a free item from our web site. We respect your time and attention by controlling the frequency of our mailings.
(c) How can you stop receiving emails from us? Each email sent contains a link at the bottom of any of the emails to unsubscribe. Simply click on the link and we will stop sending you emails.
(d) How You can review and request changes or deletion of your PII? You can request changes or deletion of your PII that is collected through the Web site, by sending an email to firstname.lastname@example.org.
There are also times when it may be advantageous for Tumbleweed to make certain personal information about you available to companies that Tumbleweed has a strategic relationship with or that perform work for Tumbleweed to provide products and services to you on our behalf. These companies may help us process information, extend credit, fulfill customer orders, deliver products to you, manage and enhance customer data, provide customer service, assess your interest in our products and services, or conduct customer research or satisfaction surveys. In such situation these companies are prohibited from using your personal information for any unauthorized purposes and are also obligated to protect your information in accordance with Tumbleweed’s policies, except if we inform you otherwise at the time of collection. Without such information being made available, it would be difficult for you to purchase products, have products delivered to you, receive customer service, provide us feedback to improve our products and services, or access certain services, offers, and content on our web site.
Tumbleweed may take the personal information we receive from individuals responding to our customer surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). Tumbleweed then uses the aggregated information to improve the quality of its services to you, and to develop new services and products. This aggregated nonpersonally identifying information may be shared with third parties.
We also reserve the right to disclose your personal information for any reason if, in our sole discretion, we believe that it is reasonable to do so, including credit agencies, collection agencies, merchant database agencies, law enforcement, litigation or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information. We may also disclose personal information that is necessary to identify, contact, or bring legal action against someone who may be violating our contracts, policies and procedures. Finally we may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary.
We also may disclose PII to attorneys, collection agencies, or law enforcement authorities to address potential AUP violations, other contract violations, or illegal behavior. And we disclose any information demanded in a court order or otherwise required by law or to prevent imminent harm to persons or property. Finally, we may share PII in connection with a corporate transaction, like a merger or sale of our company, or a sale of all or substantially all of our assets or of the product or service line you received from us, or a bankruptcy.
As noted above, we compile Website usage statistics from data collected through cookies. We may publish those statistics or share them with third parties, but they don’t include PII.
Protection of PII We employ the following data security tools to protect Personally Identifiable Information: Our web sites use Secure Sockets Layer (SSL) encryption on all web pages where personal information is required and to make online purchases you must use an SSL-enabled browser in order to protect the confidentiality of your personal and credit card information while it’s transmitted over the Internet. You can help us by also taking precautions to protect your personal data when you are on the Internet.
NOTE: Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser. Unfortunately, even with these measures, we cannot guarantee the security of PII from “hackers” and others. By using our Website, you acknowledge and agree that we make no such guarantee, and that you use our Website at your own risk.
Publicly Displayed Information is Public If you use the Blog or any bulletin board or chat room on our web site you should be aware that any information you share is visible to other users. Personally identifiable information you submit to one of these forums can be read, collected, or used by other individuals to send you unsolicited messages. Tumbleweed is not responsible for the personally identifiable information you choose to submit in these forums. For example, if you choose to make information, which was previously nonpublic, available by enabling certain user features, Tumbleweed will collect that information from your interaction and the information will become publicly available.
Integrity of Your Personal Information Tumbleweed has safeguards in place to keep your personal information accurate, complete, and up to date for the purposes for which it is used. You always have the right to access and correct the personal information you have provided and can help us ensure that your contact information and preferences are accurate, complete, and up to date by checking at
[web site address]. In addition, you can request a copy of your personal information, your product registration history, and your interactions with our sales and support agents by contacting us at the email address below.
International Users Tumbleweed abides by the safe harbor framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information collected from the European Union. We are not however, Certified by FTC or any other Data verification service.
Links to Sites of Other Companies Our web site has links to the sites of other companies. We are not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.
Notice of Compliance to California Residents
See Section 2 above entitled “ Our Use of PII – No Onward Transfer Except for Needed Services – Consumer Control” for a description of the process maintained by the Company for an individual consumer who uses or visits our web site to review and request changes to any of his or her personally identifiable information that is collected through our web site.