Effective Date: July 25, 2018
This policy describes what information we collect from you and how we use it to accomplish that mission.
We take your privacy as seriously as you do, and because of that we take great care to collect only the information necessary to provide you with the best possible Tile experience.
As you review our policy, keep in mind that it applies to Supply Chain Resources Group Inc.’s (“Supply Chain Resources Group”, “We”, “Us”) website, mobile app, help center, and all other associated services that we provide (“Services”).
i. Contact Information
When you place an order on our website, you’ll need to provide an email address, a first and last name, and a shipping address. In some cases, we may also require your phone number.
ii. Payment Information
In order to complete your order on our website, you’ll need to provide payment information, such as your credit card or PayPal account. This information is needed in order to process your order and is not stored on our servers.
You’ll need to use a valid email address and create a password to create an account for Services on the Tile app. You can choose whether or not you’d like to provide your first and last name.
We do not identify you personally to other users or make your account information available to any third parties in any way that could identify you without your prior consent.
When you create a Tile account, you may choose to connect and interact with a third-party social networking service (“Social Network”). If you decide to interact with a Social Network when using our Services, we are permitted to collect Personal Information that you have already made public on your Social Network account. You can manage this information in the privacy settings of each Social Network.
i. Tile ID, Name, and Photograph
When you activate a Tile using the Tile app, that Tile’s unique identifier (or Tile ID) will be associated with your account. If you choose to name your Tile or add a photo of it, this information will also be associated with your account.
ii. Location Information
Tile is designed to tell you where your items are. In order to do that, it’s necessary to collect data about your location. We use the term “Location Information” to refer to the combined location data of your phone or device, and your Tiles.
While the app is running on your device, it periodically transmits your Location Information. This allows us to show you, on your map, the last place your Tile was seen by your device (“Last Place Seen”). It is one of the primary ways Tile helps you find your lost items.
Tile normally only records the latest Location Information update for each of your Tiles, to provide the Last Place Seen. For Tile Premium users, Location Information for each Tile is stored for up to 30 days, to support the Location History feature. In both cases, Tile does this so you can find the most recent Location Information for your Tiles, in case you lose them.
Location Information is archived in a way that cannot be associated with you using a process called pseudonymization, where data will be untraceable to a specific Tile user. Tile keeps this archival data so we can answer general questions unrelated to any person, such as “How many Tiles were in London in 2016 versus 2017?”
We may also collect and update Location Information for your Tile(s) anonymously from other Tile users who are running the Tile app or from other third parties that are using an app or device that has integrated the Tile functionality (each, a “Tile Finder”) within Bluetooth range of your device. We do this to provide you with the most recent and accurate location of your Tiles, even if they are out of your devices’ Bluetooth range. These updates are fundamental to the Tile Community, which allows Tile Finders to help either other find their lost Tiles. The Location Information is reported anonymously and does not identify the owner of a Tile to others.
If you use a computer, phone, or other device to visit our website or help center, we use the IP address of that computer or device to determine an approximate location. We do this so that we can provide you with a better, more personal customer service experience.
We use your Location Information to provide the Services and may use your Location Information to promote the Services or provide you with offers. However, your Location Information is never shared with other users unless you choose to share it through our Services.
iii. Mobile Application Usage Information
We track how, and how often you use our Services. We also collect certain information that your mobile device sends when you use them for Services. This includes information such as your device’s model, operating system type and version, and the dates and times of your requests. We use this information to provide you with optimal services and support, and to collect anonymous statistics that help us understand our user base.
We provide support services via live chat on our website, email request submissions, recorded outbound telephone calls and direct email. We collect any Personal Information you may choose to provide to our customer care team in the process. This includes, but is not limited to: your name, email address, phone number, and mailing address. We may use and process your Personal Information, including Location Information, to handle your support request and provide you with the best support possible.
Tile collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including: workflow management, including assigning, managing and administering projects; human Resources administration and communication; payroll and the provision of benefits; compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs; job grading activities; performance and employee development management; organizational development and succession planning; benefits and personnel administration; absence management; helpdesk and IT support services; regulatory compliance; internal and/or external or governmental compliance investigations; internal or external audits; litigation evaluation, prosecution, and defense; diversity and inclusion initiatives; restructuring and relocation; emergency contacts and services; employee safety; compliance with statutory requirements; processing of employee expenses and travel charges; and acquisitions, divestitures, and integrations.
We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an App Store or Social Network, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through App Stores or Social Network accounts may include your name, your Social Network user identification number, your Social Network user name, location, sex, birth date, email, profile picture, and your contacts on the Social Network. This supplemental information allows us to verify information that you have provided to Tile and to enhance our ability to provide you with information about our business, products, and Services.
Cookies are small text files that are placed on your computer’s hard drive or onto your mobile device’s memory -- if your browser is set to accept cookies. Like many other online services, cookies and other tools like them help us collect and understand how you use our services.
The cookies we use expire after they have fulfilled their purpose. Some cookies expire when you close your browser (i.e., session cookies) or after a set period of time (i.e., persistent cookies). The expiration time of cookies that are placed by third parties (explained below) is determined by the third-party, not us.
Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on web pages (or in an e-mail).
While our website and the Tile app at this time do not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser, as indicated above.
We utilize Google Analytics, a service provided by Google, Inc. to gather information about how users and visitors engage with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can choose not to be included in Google Analytics at https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.
These outside services may also collect information about your use of other websites over time. Since we do not link any Personal Information that you provide to us within the app to the information we store within the third-party analytics software, this additional information is only analyzed in a way that cannot identify you.
We may use social plugins, widgets and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your name and personal Social Network account.
If you do not wish to associate any information collected via the plugins, widgets and/or other features with your personal Social Network account information, you should refrain from using these Social Features and logout from your Social Network account before visiting our Services.
When you purchase a Tile, we process your payments through a third-party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and Social Networks such as Facebook. The third-party application may collect certain financial information from you to process a payment on behalf of Tile, including your name, email address, address and other billing information.
We may use your Personal Information and Location Information to provide you with a better service, improve the quality of our products and Services, and promote our Services. We use and process your Personal Information and Location Information to create anonymous, statistical and aggregated data reports where individual users are not identified. The specific purposes for our acquisition, hold, use, and processing of your Personal Information include:
i. To Provide Products, Services, or Information Requested
Tile may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to: generally manage individual information and accounts; respond to questions, comments, and other requests; provide access to certain areas, functionalities, and features of Tile’s Services; and contact you to answer requests for customer support or technical support.
ii. Administrative Purposes
Tile may use Personal Information about you for its administrative purposes, including to: measure interest in Tile’s Services; develop new products and Services; ensure internal quality control; verify individual identity; communicate about individual accounts and activities on Tile’s Services and systems, and, in Tile’s discretion, changes to any Tile policy; send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance; process payment for products or services purchased; process applications and transactions; prevent potentially prohibited or illegal activities; and enforce our Terms.
iii. Marketing Tile Products and Services
Tile may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Tile may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include: to tailor content, advertisements, and offers; to notify you about offers, products, and services that may be of interest to you; to provide Services to you and our sponsors; for other purposes disclosed at the time that individuals provide Personal Information; or otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as described in Section 9 below.
iv. Research and Development
Tile may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Tile may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
v. Direct Marketing
Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Tile’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions further below.
vi. Services via Mobile Devices
vii. Anonymous and Aggregated Information Use
Tile may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified Location Information, information about the computer or device from which you access Tile’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Tile may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Tile and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
viii. Sharing Content with Friends or Colleagues
Tile’s Services may offer various tools and functionalities. For example, Tile allows you to provide information about your friends through our referral services, such as “Refer a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Tile or any other third parties for any other purpose.
ix. Other Uses
Tile may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Tile uses third-party service providers and software solutions, including web hosting and other cloud based services, to provide you with the best possible experience. We may share your Personal Information (including your Location Information and your Tile devices' Location Information) with our third-party service providers or affiliates (e.g. cloud-based and hosting services, technical service providers, consultants, mail carriers, communication agencies and customer support providers) in order to provide, improve, and promote the Services on our behalf.
For example, we may disclose Personal Information to our service providers in order to enable them to communicate with you on our behalf. We may also disclose Personal Information to platform providers, such as Facebook, in order to permit such providers to serve ads and promote the Services on our behalf on such platforms. To the extent possible, your Personal Information will be stored in hashed or obfuscated form.
We will not share your Personal Information with any third parties other than in the circumstances discussed above without your consent.
We may share with third parties, including advertisers and service providers, anonymized, aggregated data we collect about you and other users, such as de-identified demographic information, de-identified Location Information, and information about the computer or device from which you access the Services, or the results of hashing your email address.
With respect to onward transfers to agents under Privacy Shield, Privacy Shield requires that Tile remain liable should its agents Process Personal Information in a manner inconsistent with the Privacy Shield Principles.
We may use and process your Personal Information including Location Information to prevent fraud, misappropriation, infringements, identity theft, and other illegal activities and misuse of our Services.
In addition, if we are acquired by a third-party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third-party, in the event we go out of business or enter bankruptcy, some or all of our assets - including any information collected from or about you - may be disclosed or transferred to a third-party acquirer in connection with the transaction.
Under Privacy Shield, you may also inquire as to whether Tile is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of the Privacy Shield Principles.
Please note that the Location Information associated with your Account is a core part of our Services and you will not be able to modify it. However, if you do not want us to use your Location Information, you can delete it by deleting your Account using the process set forth in Section 8 below.
If you want us to delete your Personal Information, Location Information and your Account, please contact us at firstname.lastname@example.org with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Please note, however, that if you delete your Personal Information, Location Information and Account, the Location Information associated with any active Tile(s) may still be collected anonymously from other Tile users who are running the app within Bluetooth range of your device. However, since your Personal Information will be deleted, any new Location Information that is collected will no longer be associated with your Personal Information. You may dispose of your Tiles at a local e-waste facility or contact customer care at email@example.com for more information.
We may periodically send you promotional newsletters and emails. You have the opportunity to opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, like billing information and Service updates are necessary for you to receive, so you will not be able to opt out of those communications.
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Tile’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting firstname.lastname@example.org. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
ii. Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
iii. Mobile devices
Tile may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Tile may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
iv. Human Resources Data
With regard to Personal Information that Tile receives in connection with the employment relationship, Tile will use such Personal Information only for employment-related purposes as more fully described above. If Tile intends to use this Personal Information for any other purpose, Tile will notify the individual and provide an opportunity to opt out of such uses.
v. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
You can also choose not to be included in Google Analytics at https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en. This opt-out must be performed on each device and browser that you wish to have opted-out.
If you choose to submit your Tile success story or comment on our blog (“Feedback”), you should know that any Personal Information you submit there can be read, collected, or used by other users of those blogs, and could be used to send you unsolicited messages.
We are not responsible for the Personal Information you choose to provide in your Feedback or for any content or communications you receive as a result of sharing such information.
To request removal of your Personal Information from our blog or Tile success story, please contact us at email@example.com.
You agree that all Personal Information collected via or by Tile may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Tile, you explicitly consent to the storage of your Personal Information in these locations.
Tile complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States. Tile is in the process of certifying to the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Tile’s certification, please visit https://www.privacyshield.gov. Additionally, Tile may protect information through other legally valid methods, including international data transfer agreements.
“Privacy Shield” means the seven (7) principles of the Privacy Shield Framework: (1) notice, (2), choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the sixteen (16) supplemental principles described in the Privacy Shield: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) the role of the data protection authorities, (6) self-certification, (7) verification, (8) access, (9) human resources data, (10) obligatory contracts for onward transfers, (11) dispute resolution and enforcement, (12) choice – timing of opt-out, (13) travel information, (14) pharmaceutical and medical products, (15) public record and publicly available information, and (16) access requests by public authorities.
If you are an EU or Swiss citizen and feel that Tile is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield Principles, please contact Tile at the contact information provided below.
In addition, Tile has agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Dispute Resolution Program and, with respect to employee and human resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding individual data to JAMS, a dispute resolution provider which has locations in the United States and EU, visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Tile’s compliance with the Privacy Shield.
We implement various systems, applications and procedures to secure your Personal Information, in order to reduce the risks of theft, damage, loss of information, or unauthorized access, disclosure, modification or use of information. Please be aware, however, that these measures cannot absolutely guarantee the security of your Personal Information. Therefore, although we take great efforts to protect your Personal Information, we cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
You are responsible for keeping the secrecy of your password at all times. We recommend using a strong password that you do not share with other services.
If you believe the security of your account has been compromised, please change your password immediately via the Tile website or through your Tile app. You can also contact us at firstname.lastname@example.org for assistance.
You are responsible for ensuring the email address associated with your account is accurate. We use that email to contact you about service updates, changes to our policies, and account activities such as requests for your information or locate attempts on your device. Tile is not responsible for personal data transmitted to a third party as a result of a user providing an incorrect email address.
Our Services are not directed to children under 13 and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13, we will take steps to delete such information from our files as soon as possible.
United States: Tile, Inc., 2121 South El Camino Real, Suite 900, San Mateo, CA 94407
United Kingdom: Tile Europe, Ltd., 11th Floor, Whitefriars, Lewins Mead, Bristol, BS1 2NT