Privacy Policy

Effective Date: January 1, 2020

1. The Scope of this Policy

This privacy policy ("Policy") describes how Takl, Inc. and our affiliates and subsidiaries ("Takl" or "we" or "us" or "our") treats information collected or provided in connection with transactions, activities, and data gathered when a User ("you" or "User") visits or uses the Takl Platform, including your access and use of Takl's websites located at www.takl.comwww.taklplus.com, and www.shutterforce.com (the "Websites"). This Policy is incorporated by reference into the Terms of Use. Any capitalized terms used and not defined in this Policy shall have the meaning given to them in the Terms of Use.

Please note that the use of the Takl Platform constitutes your acceptance of this Policy. If you do not agree with how we have determined to handle your information, please do not visit or use the Takl Platform.

2. Effective Date and Changes

This Policy applies to all information collected by or provided to us on or after the Effective Date. Takl will periodically review and revise this Policy and update the Policy modification date below. If we materially change this Policy in a way that affects how we use or disclose your Personal Information, we will notify you of such changes before your next use of the platform and by stating the effective date of the changes. We will treat your continued use of the Takl Platform following such changes as your acceptance of them. We encourage you to periodically review this Policy.

If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than those policies in effect at the time we collected the information, we will make reasonable efforts to provide notice and to obtain consent to any such uses as may be required by law, but we will not be liable for any failure to do so.

3. Personal Information Collected on the Takl Platform

The Takl Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”).

By using the Takl Platform, you are authorizing us to collect, parse, and retain data related to the provision of the Takl Platform. However, we also provide Users with options and choices regarding how we use and disclose some or all of your Personal Information, as set forth specifically below, including how to access, correct, and/or remove it. You may avoid further said data collection by uninstalling the App from your mobile device and not otherwise using the Takl Platform.

When you visit or use the Takl Platform, we collect information about you in the following general manners:

  • A. Information Your Provide Us

    When Users engage in the Takl Platform, information is gathered in forms completed, images uploaded, or products and services you purchase.

    Account Registration: When Users of the Takl Platform create an account, we collect the information you provide including your name, email address, and phone number. When jobs are created, we also collect your address(es) and payment information. Customers have the option of uploading a profile picture and bio line during registration, as well.

    Provider Registration and Payment: To register as a Provider, you may need to provide additional Personal Information, including your profile picture and ID for verification purposes, payment information, and Social Security number; in some jurisdictions we may collect additional business or contractor licenses. Providers are required to create a bio line during the registration process which may or may not include Personal Information.

    Transaction Information: We collect transaction details related to your use of the Takl Platform, such as type of service requested, date and time of service, amount charged, distance traveled, intra-User communications, ratings and reviews, and other related transaction details.

    Customer Support: We may collect Personal Information such as your name, email address, phone number, and photographs through your communications with our Customer Support team.

    Information to be published or displayed (“User Contributions”): Your User Contributions are posted on and transmitted to others at your own risk. Taklcannot control the actions of other Users of the Website or Platforms with whom you share your User Contributions. For additional information on User Contributions, please see our Terms of Use.

  • B. Information We Collect When You Use the Takl Platform

    Takl gathers information indirectly from Users by observing actions on our Platform.

    Location Information: We collect precise location data through the App when it is used by Customers and Providers if the Customers’ or Providers' devices permit such information collection. We may collect this information when certain functionalities are used, such as selecting “my location” or navigating to a location to provide the Services, and we may also collect the precise location of a Provider’s device when the App is running in the foreground or background. Wemay derive a Provider’s approximate location from the Provider’s IP address.TheTakl Platform utilizes geo-location features to connect Customers to Providers, to update Customers on the status of Providers en route to perform Services, to confirm that a Provider performed Services, and to improve the services on the Takl Platform.

    We also may use and disclose geo-location we collect through the Takl Platform for other business purposes, including for legal purposes (such as to enforce our agreements) and in the event of a proposed or actual merger, sale, or other business asset transfers. The geo-location information obtained about a User willbe retained in an identifiable manner, along with geo-location data about job sites where Providers performed Services on initial and/or follow-up jobs.

    Device Information: We may collect information about your mobile device, including the following examples: the hardware model, operating system/version, software names/versions, file names/versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

    Usage and Preference Information: We collect information that is generated automatically about how you and visitors interact with the Takl Platform, preferences expressed, and settings chosen.When we associate such information with specific personal information, we will treat the combination as Personal Information, as set forth herein.

    Communications Between Users: As an enhanced privacy feature, we use a third-party service called Twilio to mask the telephone numbers used during callsor texts (SMS) between Users (See additional provisions regarding Twilio herein below). We do not reveal telephone numbers submitted on file, although we store any call data, including associated date, time, and content.

    Log Information: When you interact with the Takl Platform, we collect server logs, which may include device IP addresses, access dates and times, app features or pages viewed, app crashes and other system activity, browser type, and the third-party site/service accessed immediately prior to interacting with the Takl Platform.

    Cookies, Analytics, and Third-Party Technologies: Like most online servicesand mobile applications, we and our third-party service providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Takl Platform. A cookie is a file saved on a User’s hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our services.

  • C. Information We Collect from Third Parties and Service Providers

    Takl engages with third-party service providers that provide information that makes it possible to run elemental aspects of the Takl Platform, as well as additional services such as loyalty programs and promotions.

    Some of the things these service providers allow for are background checks, payment processing, insurance, marketing, and other businesses. Information we receive from these third parties includes:

    • Safety and Security Information, such as background checks;
    • Third party program participation information, such as transactions and fraud detection; and
    • Operational information for loyalty and promotional programs, such as your use of such programs.

    Referral Programs: Your endorsement is a valued compliment. We collect information when Users of the Takl Platform refer us to others including the use of your Share Code.

    Third-Party Site Account Access: If you log in to the Takl Platform through a social networking site, such as Google or Facebook, we may collect your authentication token, registration information, and account identification numberand use that information to provide you with access to your account on the Takl Platform.

    Other Uses and Sources: At times, other users and sources such as the media,insurance companies, and law enforcement may provide information about you or prior activities during incident research.

4. How We Use Your Information

We only use your Personal Information for Takl Platform related purposes. (This includes the information collected by our third-party service providers, set forth herein; however, this does not include our use of photographs, which is governed separately).

Use of your information allows us to:

  • Meet or fulfill the reason you provided the information. For example, if you shareyour name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase or provide a product or service, we will use that information to communicate Service requests from you to other Users, and/or suggest potential Customers for your Services as well as process your payment and facilitate delivery. We may also save your information to facilitate new service orders or address disputes;

  • Provide, support, personalize, and develop our Website, products, and services. We may use your phone number or email address to contact you in connection with your Takl-related activities (including, but not limited to, confirmation emails, account verification text messages, push notification alerts, or important alerts that could affect your relationship with Takl);

  • Create, maintain, customize, and secure your account with us;

  • Process your requests, purchases, transactions, and payment and prevent transaction fraud;

  • Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;

  • Personalize your platform experience and deliver content and product and service offering relevant to your interests, including targeted offers and ads through our platform, third-party sites, and via email or text message (with yourconsent, where required by law);

  • Help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business. Examples include using your information for identification and authentication, security andfraud prevention, performing background checks, or investigating potential unauthorized use of your information;

  • Enable testing, research, analysis, and product development, including to develop and improve our Platform, products, and services. For instance, to continuously evaluate and improve the online and mobile user experience. We use platform analytics and marketing to advertise, promote and market Takl services and products;

  • Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; or

  • Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Takl’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Takl about Users of the Takl Platform is among the assets transferred.

Takl will not collect additional categories of information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

5. How We Share Your Information

As set forth herein, we do not rent, sell, or share Personal Information (as defined by California Civil Code § 1798.83) about you with other people or nonaffiliated companies for their direct marketing purposes unless we have your permission. We may allow access to other data collected by the Takl Platform to enable the delivery of our online advertising on the Takl Platform and on other websites and online services, or to send you information we think may be useful or relevant to you.

Before we disclose Personal Information with service providers for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

The following are examples of how we share your information with third-party service providers.

  • A. Sharing Between Takl Platform Users

    When you agree to provide Services as a Provider, we will display certain information about you to the Customer who requested the work, including your name, photograph, geo-location, and rating, and such information may also be visible to users of our Platform Partners’ websites. When you submit a Service request as a Customer, we will display certain information about you to Providers, including your name, address, photograph (if any), rating, and photographs of the job site. The Customer’s full address is disclosed only to the selected Provider. Takl discourages the sharing of any additional contact information between Users of the Takl Platform.

  • B. Sharing with Service Providers for a Business Purpose

    Categories of Information We Share: To operate the Takl Platform, including processing your transactions and supporting your activities on the Takl Platform, we may have disclosed the following categories of your Personal Information with vendors, agents, and third-party service providers for a business purpose (as we have done in the preceding 12 months:

    • Category A: Identifiers: A real name, alias, postal address, unique personal identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license, passport number, or other similar identifiers.
    • Category B: Personal information categories listed in the California Consumer Records Statute §(Cal. Civ. Code 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
    • Category D: Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    • Category E: Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
    • Category F: Geolocation Data: Physical location or movements.
    • Category G: Inferences drawn from other personal information: reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    Business Purposes for Disclosing Information: We may use or disclose the Personal Information we collect for one or more of the following business purposes:

    • To fulfill or meet the reason you provided the information. If you provide your Personal Information to purchase or provide a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new service orders or address disputes.

      • Takl Payment Method: When you add a credit card or payment method to your Takl account, a third party that handles payments for us will receive your card information. To keep your financial data secure, we do not store full credit card information on our servers.

    • To provide, support, personalize, and develop our Website, products, and services.

      • Operating Systems and Platforms. We use Amazon Web Services to host the cloud architecture for the Takl Platform. We use Google Drive, Gmail, One Drive, Stitch Data, and Slack in the daily course of business operations. Files and data stored in those systems may include customer name, postal address, telephone number, email address, personal identifier/account ID, device ID, IP address, IDFA, and date of birth.

    • To create, maintain, customize, and secure your account with us.

      • Platform Features. We use Twilio for registration of new Users to make sure your contact information is accurate and that every new User account in our system is an actual person we can serve. We also use Twilio to mask your telephone number when you call or text (SMS) message another User using the telephone number provided by Takl through the App. You can find information about Twilio's privacy practice at: https://www.twilio.com/legal/privacy. We also use the Google Maps service, and you agree to the Google Maps/Google Earth Additional Terms of Service located at https://maps.google.com/help/terms_maps.html and Google's privacy policy located at http://www.google.com/policies/privacy.

    • To process your requests, purchases, transactions, and payment and prevent transaction fraud.

      • Payment Processors. We use Stripe to process any billing information between Users and between Users and us, including credit card information Users submit. You can find information about Stripe's privacy practice at https://stripe.com/us/privacy.

    • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

      • Customer Relationship Management Platform Hosts. We use Zendesk for Customer engagement via email and live chat. Information collected in correspondence through Zendesk includes name, email address, Device ID, and IP address as well as any information you share in correspondence such as pictures, addresses, or biographical information.

      • Order Fulfillment Platforms. We may occasionally share the name and address of Users to order fulfillment platforms in order for them to ship items to Users.

    • To personalize your Platform experience and to deliver content and products and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law).

      • Charitable Donation Programs: We may offer opportunities within the Takl Platform for Users to donate to charitable organizations. If you voluntarily agree to donate to a charitable organization by taking affirmative steps within the Takl Platform, then you hereby authorize Takl to provide your Information to such charitable organization to facilitate your donation to their charitable campaign.

    • To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.

      • Background Check Processors. We use Checkr and Evident for purposes of performing background checks on Providers that register to perform Services for Customers on the Takl Platform. During the registration process, the information you provide to Checkr is transmitted using SSL encryption, which is a primary tool in protecting sensitive operations with web servers during data transport of information that allows for a secure connection between the two parties. You can find information about Checkr's privacy practice at: https://checkr.com/privacy-policy/ and Evident's privacy practice at https://www.evidentid.com/privacy-policy/.

    Application and Data Security Entities.We use Viperline for security consulting and testing. Viperline may on occasion have temporary access to contact information including names, aliases, addresses, email addresses, and phone numbers; account names or ID numbers; IP addresses or IDFAs; government ID cards; consumer history on the Platform including purchases, browsing history, physical location or movements; current or past history or performance evaluations; audio, electronic, visual, thermal, olfactory, or similar information; or profiles. Sqreen is a real-time Application Security Management Platform which receives partial postal address, email address, physical location or movements, and IP addresses. You can find information about Sqreen’s privacy practices at: https://www.sqreen.com/privacy

    • Insurance providers. In the event of an insurance claim, we would provide the information necessary for reporting and documentation, including name and address.

    • External mediators. We use a third-party mediator to resolve disputes between Customers and Providers when necessary. Takl shares the name, address, phone number, and email address of Users with such third-party mediator service providers.

    • For testing, research, analysis, and product development, including to develop and improve our platform, products, and services. We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

      • Data analytics providers. We retain third-party service providers to help us perform data analytics regarding your interactions with the Takl Platform. For example, we use Google Analytics Service for purposes of analyzing usage of the Takl Platform. You can find information about Google's privacy practice at: https://www.google.com/policies/privacy/partners. We also use Braze and Mixpanel to collect and provide reports to us showing your interaction with the Takl Platform, and to assist Takl with its marketing and transactional communications. You can find information about Braze's privacy policy at: https://www.braze.com/privacy/ and Mixpanel's privacy policy at: https://mixpanel.com/legal/privacy-policy.

  • C. Legal Obligations and Protecting the Takl Platform

    We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate in the following situations: to comply with law enforcement requests and legal process, such as a court order or subpoena; to respond to your requests; or to protect your, our, or others' rights, property, or safety. We may also disclose your Personal Information as part of a dispute among Users or between Users and Takl as well as to an attorney in the process of obtaining legal advice.

  • D. In Connection with a Merger, Sale, or Other Asset Transfers

    If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of Takl assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

  • E. With Your Permission

    We may also disclose your Personal Information with your permission as set forthherein.

    Social Networking and Other Websites: The Takl Platform may allow you to share information, including Personal Information, with social networking websites, such as Facebook, Google, etc. Except for our marketing and advertising purposes, we do not share your Personal Information with them unless you specifically authorize it. If you choose to log in to the Takl Platform through social networking websites, we may share information about your account with the social networking site. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.

  • F. With Platform Partners

    Some third-party sites link to the Takl Platform and share information with Takl. For example, in some cases, you can schedule services through the Takl Platform with one of our partners (“Platform Partner”). In that case, you might provide the job information, such as your name, telephone number, email address, and service address, to the Platform Partner. The Platform Partner might then share the necessary booking information with us. Conversely, we share your Personal Information with Platform Partners. Upon request, we provide our Platform Partner with information about the services you booked or provided, as applicable, through the Takl Platform.

How We Store and Protect Your Information

  • A. Information Retention

    To preserve the integrity of our databases, standard procedure calls for us to retain information submitted by members for an indefinite length of time. You agree that we may store the information we collect for this indefinite length of time.

  • B. Our Security Precautions

    Your Takl profile is password-protected so that only you and authorized Takl employees have access to your account information. In order to maintain this protection, do not give your password to anyone. Takl staff will never proactively reach out to you and ask for any personal account information, including your password. If you share a computer or mobile device, in order to protect your information entered on public terminals from disclosure to third parties, you should sign out of your Takl account and close the browser window before someone else logs on. Takl has security measures in place intended to help protect against the loss, misuse, and alteration of the information under our control.

    International. Your information may be transferred to and maintained on computer networks which may be located outside of the state, province, or other governmental jurisdiction in which you reside; and the privacy laws governing the country/jurisdiction of these computer networks may be less protective.

    Takl takes steps to ensure that your information is secure on its system. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Takl cannot guarantee the security of any information you transmit to us, and you do so at your own risk. TAKL EXPRESSLY DISCLAIMS ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESSED OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION OR USAGE INFORMATION AND FURTHER DISCLAIMS ANY LIABILITY THAT MAY ARISE SHOULD ANY OTHER INDIVIDUALS OBTAIN THE INFORMATION YOU SUBMIT TO THE TAKL PLATFORM

7.Your Rights and Choices Regarding Your Data

  • A. All Users

    Email Subscriptions. Takl provides Users the opportunity to unsubscribe from email marketing communications from us and our partners and gives Users the option to remove their information from our database, to not receive future emailmarketing communications, or to no longer receive our service. If you receive an unsolicited marketing email from a Takl email address, please contactprivacy@takl.com.

    SMS Messages. You can adjust the SMS messages that you receive through Settings in the Platform. This may result in not receiving important updates regarding your appointments and account activity.

    Push Notifications. You can deactivate push notifications for marketing. Push notifications for important updates regarding your appointments and account activity are required for proper functioning of the Platform.

    Profile Information. Takl provides you with the ability to access and edit your Personal Information: Sign into the App, access the Settings menu, and then view and update/correct your account information. So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. Please contact us at support@takl.com to change information you cannot access through your account.

    Location Information. You can stop your device from sharing location information via the system settings, although this could impact the full range of services and features available through the Platform.

    Cookies, Web Beacons, and Other Technologies. Like most online services and mobile applications, we and our third-party service providers may use cookies, web beacons, and similar tracking technologies to collect information about your activity from the computer or devices you use to access the Takl Platform. A cookie is a file saved on a User’s hard drive that stores certain information about User activity. Users must agree to let cookies be saved for them, and most web browsers are set to accept cookies by default. Although you can modify your browser/device settings to reject cookies if desired, this could potentially affect the availability and functionality of our services.

    Any third party with whom we are allowed to share your Personal Information is authorized to use your Personal Information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control. You agree that we are not responsible or liable for any of their actions or omissions. Those who contact you will need to be instructed directly by you regarding your preferences for the use of your Personal Information by them.

    Do Not Track. You may be able to activate the “Do Not Track” option through your web browser.

    Deleting Your Account. If you would like to delete your account, please submit a request by logging into your account and submitting under Settings, or sending an email to privacy@takl.com. Once we receive and verify your consumer request, we will delete (and direct our service providers to delete as applicable) your Personal Information from our records, unless an exception applies. If we are unable to delete your account in whole or in part due to legal obligations or the certain other exceptions, we retain data in a way designed to prevent its use for other purposes.

    Advertising Opt-Out. You may be able to opt out of receiving personalized advertisements from advertisers and/or advertising networks who are either members of the Network Advertising Initiative or subscribers to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. To learn more about your choices for opting out of personalized advertising through websites and/or apps, please visit:

    You may also be able to change your mobile device settings to Opt-Out of personalized advertising through apps. For example, for iOS mobile devices, go to “Settings” from your device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” Also, for location-based ads, you may go to “Settings” from your device’s home screen; select “Privacy”; select “Location Services”; select “System Services”; and de-select “Location-Based Apple Ads.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt-Out of Interest-Based Ads.”

    Please note that when you Opt-Out of personalized advertising, you may continue to see online advertising on the Takl Platform and/or our ads on other Internet websites.

  • B. California Residents

    The California Consumer Privacy Act (CCPA) provides California consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

    Right to Know: You have the right to request that Takl disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

    • The categories of Personal Information we collected about you;
    • The categories of sources from which the information is collected;
    • The business or commercial purpose for collecting that Personal Information;
    • The categories of third parties with whom we have shared that Personal Information;
    • The specific pieces of Personal Information we have collected about you (also called a data portability request)
    • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
      • Sales, identifying the Personal Information categories that each category of recipient purchased: and
      • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained

    Right to Delete: You have the right to request that Takl delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

    We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    Right to Opt-Out: Takl does not and does not intend to sell your Personal Information with other parties or nonaffiliated companies for their direct marketing purposes without your direct consent. You have the right to direct us not to sell your Personal Information at any time (the “right to Opt-Out”). If you (or your authorized representative) would like to Opt-Out of future sale of information, should that commence, you may submit a request to us by clicking this link: “Do Not Sell my Personal Information.”;

    Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services ora different level or quality of goods and services.

    Please note: an active account is necessary to request or provide services on theTakl Platform

    Other California Privacy Rights.

    California’s “Shine the Light” law (Civil Code Section §1798.83) permits Users of our Website that are California residents to request certain information regardingour disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@takl.com.

    Exercising Your California Privacy Rights.

    To exercise the rights described above, please submit a verifiable consumer request to us by either:

    • Submitting through your password-protected account
      • Sign in to https://app.takl.com or the Takl App > open Settings
      • Select Your Data
      • Follow the Prompts to Opt-Out, Download My Data, or Request Deletion
      • Submit required information;
    • Emailing privacy@takl.comwith the subject of your request, your full name, Share Code (under Settings) and the email address that you registered your account with.

    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

    You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

    Making a verifiable consumer request does not require you to create an account with us, however we do not collect Personal Information on individuals that do not have existing Takl accounts in the system. Takl does consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

    We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    To exercise the right to Opt-Out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://takl.com/opt-out-of-sale/

    Once you make an Opt-Out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.

    Takl provides Users the opportunity to Opt-Out of receiving email marketing communications from us and our partners and gives Users the option to remove their information from our database, to not receive future email marketing communications, or to no longer receive our service. If you receive an unsolicitedmarketing email from a Takl email address, please contact privacy@takl.com.

8. Children’s Data

We do not knowingly collect information from children under 13, as the Takl Platform is not directed at Users under 18. If you are a parent and believe that your child under the age of 13 has used the Takl Platform and provided personal identifiable information to us through the Takl Platform, please contact us at privacy@takl.com or at our mailing address so we can delete that account and/or any Personal Information collected from them on the Takl Platform.

9. Links to Third-Party Websites

This Policy applies solely to information collected by the Takl Platform. The Takl Platform may contain links to other websites, charitable organizations, or online services, including our Platform Partners’ websites; and we of course are not responsible for other websites’ privacy practices. We advise Users upon leaving the Takl Platform to carefully review the privacy statements of any website that collects personally identifiable information.

Note that, as set forth herein, we do not provide your Personal Information to third parties for their own marketing purposes without your consent.

10. Changes to This Privacy Policy

Takl reserves the right to amend this privacy notice at our discretion at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s Effective Date. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.

11. Contact Us

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: legal@takl.com
Website: www.takl.com
Postal Address:
Takl, Inc.
Attn: Legal
1005 Flagpole Court
Brentwood, TN 37027

Updated: January 10, 2020