Privacy Policy

Last Updated: September 29, 2022

Tilia Inc. and its affiliates (collectively “Tilia”, “we”, “us”, “our”) respect the privacy of its online visitors and users of its websites, apps, products and services, including the services accessible within third-Party Platforms and Publishers (each term as defined in our Terms of Services) (collectively, the “Services”).  

We recognize the importance of protecting information collected from our users and have adopted this Privacy Policy to inform you about how we gather, use, store, disclose, and otherwise process your information, including personal information (also known as personal data), in conjunction with your access and use of our Services.  Please read this Privacy Policy carefully to understand our views and practices regarding your personal information and how we will treat it.  You can click on any of the following headers for more information or read the full policy.

  1. Types of Information We Collect and How We Collect It
  2. Use of Your Information by Tilia
  3. Sharing Your Information with Third Parties
  4. Children’s Privacy
  5. Additional Information for Individuals Located in the U.S.
  6. Additional Information for Individuals Located in the EU or the UK
  7. Additional Information for Individuals Located outside the U.S., the EU or the UK
  8. Your Controls, Rights and Choices
  9. Security 
  10. Data Transfers
  11. Third-Party Links
  12. Changes to this Privacy Policy
  13. Comments and Questions

1. TYPES OF INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect two types of information – “personal information” and “anonymous information” – which we may use to create a third type of information, “aggregate information”.  

  • Personal Information”, also often referred to as “Personal Data”, means information that identifies (whether directly or indirectly) a particular individual, household, or device, such as the individual’s first and last name, postal address, e-mail address, telephone number, username, and/or image.  
  • Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, household, or device.  
  • Aggregate Information” means information about groups or categories of individuals which does not identify, and cannot reasonably be used, to identify an individual, household, or device.  We may share Aggregate and Anonymous Information with other parties without restriction.

Information You Provide

We collect the information which you provide us which may include:

  • Registration or Account Information. Information you provide when you register to use our Services or create an account such as: your first name and last name, country of residence, date of birth, e-mail address, username and password.  

    Not all information will be mandatory to create the account or register to use the Services, for example we do not ask you to provide sensitive information or special category data (such as that regarding your race, ethnicity, religious beliefs or sexual orientation).  However, if you opt to provide more information, please note that this may become publicly available depending on its nature and why it was provided (e.g. your image for your account profile photo).  
  • Identity and KYC Information. When you use certain of our Services, including when accessed through a Publisher’s Platform, we will need to confirm your identity to comply with applicable laws.  To do this, we require that you provide us with information commonly referred to as “KYC” or “Know Your Client” information.  Which KYC information is required differs depending on which law applies but generally, the information that may be required includes your name, date of birth, social security number, address, email address, phone number, photo of an ID document (such as a passport or government-issued photo identification), and card details.      
  • Purchase and Transaction Information. When using our Services to conduct transactions, including through a Publisher’s Platform, we may collect and retain some or all of the information related to these transactions, including payment details, transaction amount(s), parties involved, time and manner of exchange, the IP address of where the transaction is originating, and other transaction circumstances, such as payment method and names or emails of external third-party accounts (for example, PayPal or Skrill).
  • Your Marketing Preferences. We like to keep in touch with our users and future users through different communications such as emails.  To ensure you find these communications useful, we ask you for your marketing preferences which may include your personal information.     
  • Surveys, Contests and Promotions. As part of our Services, we sometimes offer or ask you to take part in surveys, contests, or promotions.  Depending on the nature of the survey, contest, or promotion, we may ask you, or you may volunteer, to provide certain personal information, such as your name, address or opinion. 
  • When you do Business with us. If you are a vendor, service provider, or business partner (or a prospective vendor, service provider or business partner) of us, we may collect information about you and the services you provide, including your or your employees’ business contact information and other information you or your employees provide to us as part of the services you may provide and our agreement with you.
  • Communications. We collect information you provide when you contact us, for example regarding customer support inquiries or other inquiries related to your account, or to provide us with feedback on the Services.  

Information We Collect Automatically

When using our Services, in addition to the information you provide us, there is also some information we may collect automatically that identifies you or the device you are using to access the Service, such as your computer or mobile device.  Generally, this information relates to your use of the Services and your preferences, such as the types of Services you view or engage with, the features you use, the actions you take, the people or accounts you interact with, and the time, frequency and duration of your activities.  In addition, we may also collect location information when you use the Services, including geolocation information or your internet protocol (IP) address.

For more information on this, please see our Cookies Policy.

Information We Receive From Third Parties

  • Publishers can also create accounts on your behalf if you use one of our Services on their Platform and when they do this, they will provide certain information to us such as your first name and last name, country of residence, date of birth, e-mail address, username and password.  You will know when this happens as you will be prompted to review our Terms of Service and this Privacy Policy. 
  • When verifying your identity, we may use the services of third parties for all or part of the process.  As part of doing so, the third party may provide information about you such as credit history and credit information.  
  • We may also receive information about you from Publishers who make our Services available to you through their Platforms.

2. USE OF YOUR INFORMATION BY TILIA

 Tilia may use your personal information, subject to and at all times in compliance with applicable laws and your choices and controls, for the following purposes:

  • Services. To provide you with the Services you request, including to create and manage your account, create your Tilia wallet, process payments and transactions, and provide you with customized Services and experiences based on your preferences.
  • Conduct KYC Checks. As explained above, we are required by law to verify your identity in certain countries before we are allowed to provide you with certain of our Services.  Therefore, to do so, we must process the information required by the relevant applicable law in order to be able to verify your identity. 
  • Service Communications. Communicate with you about your account or transactions with us, or other Service-related announcements such as regarding features on our Services and applications or changes to our policies or terms.
  • Marketing Communications. Send you offers and promotions for our Services or, as permitted, third-party products and services, via email, or text.
  • Other Communications. If you submit a question, inquiry or concern to us, we will use your personal information to respond to you.
  • Advertising. Provide you or serve you with advertising or information based on your activity on our Services and on third-party sites and applications
  • Surveys, Contests or Promotions. If we administer a survey, contest, or promotion, we will need to process certain personal information to do so.  This will vary depending on the nature of the survey, contest, or promotion. 
  • Improve Our Services. Develop and test our Services and operations to optimize and improve our Services and operations.
  • Violations, Illegal Acts or Fraud. Detect, investigate and prevent activities on our Services that may violate our policies (including any applicable terms of service or terms of use) or may be illegal or harmful in any way to us, our Services users, our property, or any other third party.  This includes any potential or actual act(s) of fraud or fraudulent behaviour using or related to our Services.
  • Verification and Monitoring. Verify accounts and monitor activities within our Services to promote safety and security of our Services, our users and our properties, and to detect any potential or actual act(s) of fraud or fraudulent behaviour related to our Services.
  • Compliance. Comply with applicable laws and regulations and any lawful requests from regulators, governmental bodies or other authorities.

3. SHARING YOUR INFORMATION WITH THIRD PARTIES

We will not share your personal information with any third party except in limited circumstances and where permitted by applicable law, including:

  • When you are accessing our Services through a Publisher’s Platform, we will share some of the information we collect or process about you with the Publisher.  This is to ensure the relevant task or action is performed, e.g. the Publisher provides the item purchased within the Platform; 
  • When you consent to us sharing your personal information with another company;          
  • When companies perform services on our behalf, including those who help us provide the best services to you and others (such as hosting/storage, anti-fraud functions, billing, collections, registration, customer support, e-mail delivery, age verification, or other operations).  These companies are prohibited from using your personal information for purposes other than those requested by us or required by law;
  • With our business partners that we perform joint campaigns with; 
  • With our business partners that may include partners in our ad network (see section “Your Controls, Rights and Choices” for more information on these partners);
  • In connection with the sale of any of our Services, assets and/or businesses, or when the ownership or control of all or part of our Services changes;
  • To enforce our Terms of Service or other rules or policies, to ensure the safety and security of our users and third parties, to identify and prevent potential or actual fraud or fraudulent activities, to respond to requests from law enforcement, officials, regulatory agencies and other lawful requests or legal processes, or to comply with a legal obligation to which we are subject, or other legal process or in other cases if we believe in good faith that disclosure is required by law; and
  • To effectively perform our Services, we may share your personal information with our affiliates.  

4. CHILDREN’S PRIVACY

As stated in our Terms of Service, we do not make our Services available to anyone under the age of 18. Therefore, we do not intend to collect or otherwise process personal information of anyone under the age of 18. If you have reason to believe we are processing personal information of anyone under 18, please get in touch with us as soon as possible using the contact details in section “Comments and Questions”.

5. ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE U.S.

U.S. GLBA Notice

Personal information relating to U.S. users that we collect in connection with the solicitation and provision of our payment and stored value services is subject to our U.S. GLBA Notice.  In the event of conflict or inconsistency between this Privacy Policy and our U.S. GLBA Notice, the U.S. GLBA Notice will apply that information.

Other information we collect from U.S. persons will be subject to the provisions of this Privacy Policy.

CCPA

If you are a California resident in accordance with the California Consumer Privacy Act (CCPA), the following information applies to you.

Personal Information We May Collect

During the past twelve (12) months, we may have collected the following categories of personal information about you:

Why We Collect Personal Information and How We Use It

The purposes for which we collect and use your personal information (described in detail above) depends on how you engage with us and our Services.  The table below lists the purposes for which we may collect and use your personal information: