We, Tail (the “Tail” or “we”) are a data platform for audience segmentation and insights into the digital environment and are committed to safeguarding your privacy and protecting your personal data. The purpose of this document is to clarify what data is collected from users of our site and our Customer sites (“You”), where we provide audience segmentation services.
It is part of Tail’s missions to fight for a market based on data protection of users in a digital environment. We are the biggest enthusiasts about the regulation of this market in Brazil and we follow the best practices applied today in the most advanced markets in this subject both nationally and internationally. Thus, Tail respects and defends regulations on the protection of personal data and seeks always to comply with the best practices in the world on this subject. We are affiliated to IAB-Brazil (Internet Advertising Bureau), which recommends good practices and ethical principles to be followed by the market in line with the Internet Civil Code and the International Network Advertising Initiative (NAI) Code.
Acceptance of our Policy will be made when You register on our platform to enjoy our services, even for free. Such acceptance shall occur upon the moment You affirmatively agree to the use of your data for each of the purposes described by us. This will indicate that You are aware and in total agreement with how we will use your information and your data. If you do not agree to this Policy, please do not continue your registration procedure and do not use our services. However, please inform us of your disagreement so that we can improve them.
This document has been written in a simple and accessible way, with several examples of data collection and use, so that you can read and understand how we use your data to offer you a safe and comfortable experience during the use of our data services.
This Policy is divided as follows to facilitate its understanding:
- What kind of data does Tail collect?
- With whom does Tail share your data?
- International data transfer
- What are the rights of data subjects?
- How long will the data be stored?
- How Information Security Works in Thailand
- How to talk to Tail DPO
- Policy Changes
1. What kind of data does Tail collect?
The amount and type of information collected by Tail varies according to your use of our services. We will collect different data if You are visiting our site, using our software, using the services of clients of our software. And to make these definitions and differences more accessible, we segment the collection of user data into 3 parts so that You can understand what specifically applies to You.
It should also be mentioned that we store information about all contacts already made with our users, regardless of the type of user who made the contact. Such information includes content downloaded from our pages and interactions via email.
By clicking on the content sharing buttons on the social networks available on our pages, the user will be publishing the content through his / her profile on the selected network. Tail does not have access to users’ login and password on those networks, nor will it publish content on behalf of the user without it performing this action.
It is worth mentioning that all the data we collect are used to provide our services. Therefore, all data and information about You is treated as confidential, and we will only use it for the purposes described and authorized by You, mainly so that You can use our services in a full way, always aiming to improve your experience as a user. In this sense, see below that applies to You:
1.1. Visitors of Tail’s website
If you just access our site, we will collect your browsing data. In case, when you visit our website a cookie is inserted in your browser through the software “Google Analytics” and “TailDMP”. The first one is used to identify how many times you return to our address and how you navigate our site, while the second is used to verify your profile and inferred preferences, based on your browsing behavior.
Cookies are identifiers that we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when the pages and resources in our Services are visited and how many people access them.
Considering this, in addition to cookies, the following data are also collected during the navigation of the site: IP, date and time of access, geographical location, reference source, browser type, duration of the visit and pages visited.
The legal basis for collecting such data is the legitimate interest, since we use this data to operationalize our systems, develop analytics, and tailor and customize the navigation of the site to You.
1.2. Tail Customers
If you use any of our services and / or products, we will collect, in addition to your browsing data mentioned in the Visitor Users part, other information from you and the data owners that you submit in our platform. In this case, when you register to access any of our services and / or products, we will collect the following categories and types of personal data: registration data (name, email, password, address), location data (name, bank, agency, account, swift, IBAN, ABA and address), data for marketing purposes (your preferences marketing and CRM information).
In order to provide our services, we will cross-track the data we collect with others we have on the same owner in our databases, including the data of visitors to the sites that you register on our platforms. In particular, we will use the data to monitor visitors’ actions on the pages that You sign up to create profiles of these people based on their behavior data and to check what their interests are, to rank and qualify these people according to that profile, and to create dynamic lists of these people to perform targeted marketing actions, which are performed automatically according to the ranking of visitors to your site.
All data listed above is collected and processed for the purpose of providing services and some may be used for fraud prevention. The legal basis for the collection of such data may be consent, legitimate interest and protection of credit, so, whenever it is appropriate, we will request your consent to be able to collect your personal data. And in relation to the personal data of other holders submitted by You, You must guarantee that you have obtained the consent of the holders or used another legitimate legal basis to make the collection of such data.
1.3. Users of the Tail Customer sites
If you are using a client application on a mobile terminal (such as a smartphone or a tablet), we can obtain data from our SDK using your device’s Advertising ID (“Advertising ID” for the operating system, such as Android Advertising ID - AAID and Apple ID for Advertising - IDFA). In these cases, in addition to navigation data and use of the application of our Customers, we can also collect:
Data about your device: model, manufacturer, operating system, telecom operator, mobile browser, type and speed of internet connection being used, Internet connection IP address, GMT time zone and list of installed applications; and
Device sensor data: Data from WiFi, GPS, Bluetooth, accelerometer, magnetometer, gyroscope, and proximity sensors when these accesses are available in the partner application.
We may also collect data from your participation in advertising campaigns on the website or application of Customers. In these cases, we may use the techniques listed above to obtain data on the type of advertising you are visiting and information about your interaction with the campaign.
In our activities, we do not collect or collect personal data from users. However, we may receive anonymized data from our Customers using encryption techniques that do not allow us to identify You in the real world.
Likewise, we do not collect data or receive “sensitive” data from our Clients and Partners - that is, those that reveal your religious, political or sexual orientation, philosophical conviction, racial or ethnic origin, as well as information about your health.
However, it is important to note that Tail does not control the information collected by third parties using its system. These data belong to Tail’s Customers, who use, disclose and protect them in accordance with their respective privacy policies. They are also responsible for obtaining the consent of the users directly and with this power to collect, manage and process the confidential information.
As a way to minimize incidents involving personal data, since Tail does not control the data that is collected directly by its Customers, Tail adopts the best practices of information security (see item 6) in the market, as well as develops its products in the concept of privacy by design, so that its Customers can use a secure tool for the management of their personal data. If you have any questions about how your data is being managed, we recommend that You contact the company that is offering services to You.
2. With whom does Tail share your data?
As an online platform, Tail will be able to operate jointly with other companies in a wide range of activities, including to provide location features, advertisers and business partners, as well as dissemination and performance analysis tools. In this way, we reserve the right to share your information, including location, registration and interests data, with the following companies, whenever possible, anonymously, in order to preserve your privacy as much as possible.
We do not rent, sell or transfer your personal data to anyone except the companies listed below. We may share your personal data with the following companies:
Advertisers, or Agencies acting on behalf of Advertisers: Tail allows other companies and ad networks to use our platform to serve ads through different technologies. Therefore, You may eventually receive directly displayed ads, content and links in a personalized way, according to your interests and behaviors in our platform or in other services with which You interact. To that end, data can be shared between Tail and these other companies, primarily unique identifiers, IP addresses and cookies, which can be used to measure the effectiveness of online advertising. You can always object to this advertising by contacting us through the form available at https://tail.digital/privacy-form or modifying your data through our privacy dashboard https://tail.digital/profile.
Our Partners: We employ other companies to perform work on our behalf and we need to share your personal data with them to provide you with products and services. For example, we use data hosting services to store our database, we also use media services to process the billing data of our products purchased by You. Our Partners are only authorized to use the personal data for the specific purposes they have been hired, so they will not use your personal data for other purposes, in addition to the provision of contractually provided services.
Analytics: The data stored by Tail may be used for analytics purposes, in order to understand who the people who visit your website are and who consumers of your products and services are. These data are pseudomizable and do not seek to identify or make identifiable personal data holders, but only to better understand how they access on Tail platforms, in order to improve service delivery and customize products more targeted to the interests of users.
3. International Data Transfer
Tail collects and transfers personal data collected in Brazil to countries located in the European Union and the United States. This transfer occurs to Tail’s Partners who operate in the processing of personal data, and such transfers involve only Tail’s partner companies that have demonstrated to be in compliance with or conforming to GDPR and Brazilian data protection laws (“LGPD” – Lei Geral de Proteção de Dados), which can be identified from this list: https://tail.digital/data-partners.
Tail is headquartered in Brazil and the data we collect is governed by Brazilian law. By accessing or using Tail Services or providing personal data to us, You agree to the processing and transfer of such data to Brazil and to other countries, mentioned above.
4. What are the rights of data subjects?
You may always choose not to disclose your data to us, but keep in mind that some of this data may be required to register on our platforms or use some of our features and products that we offer to You. Regardless, You will always have rights privacy and the protection of your personal data, and we, in addition to being concerned about the security of such data, also care that You have access to and knowledge of all your rights regarding personal data.
In this way, we summarize below all the rights that You have under Brazilian data protection laws and General Data Protection Regulation (GDPR), which are:
i. Right of access; ii. Right of rectification; iii. Right of exclusion; iv. Right to restrict processing; v. Right of objection to processing; saw. Right to explain the logic behind the collection of your data; vii. Right to data portability; and viii. Right to withdraw your consent.
In this sense, the following is a brief explanation and examples of some of these rights:
Requesting access to your personal data. This right allows You to request and receive a copy of your personal data that we hold about You.
Request for rectification of your personal data in Tail. This right allows You at any time to request the correction and / or rectification of your personal data, if You identify that some of them are incorrect. However, in order to this correction take effect, we will have to check the validity of the data that you provide to us. You can directly rectify some of your personal data in our privacy dashboard: https://tail.digital/profile.
Request for the exclusion of your personal data. This right allows You to ask us to exclude your personal data from our platform. All data collected will be deleted from our servers when You request it or when it is no longer necessary or relevant to offer you our services, unless there is any other reason for its maintenance, such as a legal obligation to retain data or need for the preservation of rights of Tail. To change your personal information or delete it from our database, simply go to https://tail.digital/privacy-form.
Right of objection to data processing. When we are relying on a legitimate (or third party) interest and there is something about your specific situation that causes You to oppose processing in that field as you believe this impacts your fundamental rights and freedoms. You also have the right to contest where we are processing your personal data for direct marketing purposes. In some cases, we can demonstrate that we have legitimate grounds for processing your data, which overlap your rights, as in such cases it may be essential to provide the product and / or service.
Restrict the processing of your personal data. This right allows You to ask us to suspend the processing of your personal data in the following scenarios: (a) if You want us to establish the accuracy of the data; (b) when You require us to hold the data even if we no longer need them, as necessary, to establish, exercise or defend legal claims; or (c) You objected to the use of your data, but we need to verify that we have legitimate reasons to use them.
Request the transfer of your personal data to You or to a third party. We will provide You, or any third party You have chosen, with your personal data in a structured and interoperable format. Please note that this right applies only to the automated information that You initially provided for our use or where we use the information to enter into a contract with You.
Right to withdraw consent at any time. You have the right to withdraw your consent, however, this will not affect the legality of any processing performed before You withdraw your consent. If You withdraw your consent, we may not be able to provide certain products. And if this is the case, we will notify you as soon as this occurs.
You may need to request specific information from us to help us confirm your identity and ensure your right to access your personal information (or exercise your other rights). This is a security measure to ensure that personal data are not disclosed to anyone who does not have the right to receive them. We may also contact you for more information regarding your request in order to expedite our response. We try to respond to all legitimate requests within 48 business hours. Occasionally, it may take more than 48 business hours if your request is particularly complex or if you have made multiple requests. In this case, we will notify you and keep you updated on the progress of your request.
Should you have any questions about these issues and how you can exercise these rights, feel free to contact us at firstname.lastname@example.org.
5. How long will Tail retain the data?
We will maintain your personal data only for as long as necessary to fulfill the purposes for which we collect them, including for the purpose of complying with any legal, contractual, accountability or request of competent authorities.
To determine the appropriate retention period for personal data, we consider the quantity, nature and sensitivity of personal data, the potential risk of damage arising from unauthorized use or disclosure of your personal data, the purpose of processing your personal data and if we can achieve those purposes by other means, and the applicable legal requirements.
And if You have registered a Tail account, your account information will be kept as long as You keep this account active. Your account and information relating to it will be deleted if You request the deletion of your data and / or your account, in which case Tail will keep the data for 60 days after your request for deletion.
6. How Information Security works in Tail
Your account is password protected for your privacy and security. If You access your account through a third-party site or service, you may have additional or different sign-in protections through that site or service. You must prevent and prevent unauthorized third party access to your account and personal data by selecting and protecting your password and / or other connection mechanism in an appropriate manner and by limiting access to your computer or device and browser by logging out after completing access to your account.
In order to guarantee your privacy and the protection of your personal data, we develop products and services based on the concept of privacy by design, that is, we design products and services that promote the protection of your data and in which you can manage your data. information directly. And in addition to this concept, we have adopted best-in-class encryption practices and “SHA-256” hashing algorithms to pseudonymize and protect personal data identifiers.
We strive to protect the privacy of your account and other personal data that we keep in our records, but unfortunately we can not guarantee total security. Unauthorized entry or use of account, hardware or software failure and other factors may compromise the security of your personal data at any time, so please help us to maintain a safe environment for everyone. In addition to adopting good security practices regarding your account and your data, should you identify or become aware of anything that compromises the security of your data, please contact us.
7. How to talk to Tail
Address: Av. Pedroso de Morais, 1553, 5th floor, Alto de Pinheiros, São Paulo - Brazil