Last Updated: October 7, 2024
This “Privacy Notice” describes the privacy practices of Agora Intelligence Inc. (d/b/a Tilt) and/or its wholly-owned subsidiaries (collectively, the “Company”, ”we”, or ”us”) in connection with the Tilt website (the “Site”) and any other website that we own or control and which posts or links to this Privacy Notice, our mobile application (“App”) and our related products and services (collectively, the “Services”). This Privacy Notice also explains the rights and choices available to individuals with respect to their information. We refer to all of the websites and our APP as the “Platform.”
Please read this Privacy Notice carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to use the Site and Services. By accessing or using the Site and Services, you acknowledge this Privacy Notice.
We may update this Privacy Notice based upon evolving laws, regulations and industry standards, or as we may make changes to our Platform. We will post changes to our Privacy Notice on this page and encourage you to review our Privacy Notice when you use our Site to stay informed. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes. If you disagree with the changes to this Privacy Notice, you should discontinue your use of the Site and Services.
Our Site and Services are not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, please contact us. We will delete such information from our files as soon as reasonably practicable. By requesting any Services from us, you agree and acknowledge that you are not under the age of 18.
The term “Personal Data” as used in this policy, describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified. A Personal Data controller is a person or organization who controls the collection, holding, processing or use of Personal Data, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.
The types of Personal Data that we may collect from you or through third parties will depend on our interactions with you and may include:
We may also collect Personal Data about you from third parties and other sources such as publicly available sources of information, or related entities, companies and businesses of the Company.
We collect this information from you when you freely provide it on the Site or when you use our Services. We may also collect your Personal Data from third parties or publicly available sources as noted above.
Unless specified otherwise, all Personal Data requested by our Services is mandatory and failure to provide this Personal Data may make it impossible for you to use our Services. In cases where our Site and Services specifically state that some Personal Data is not mandatory, users are free not to communicate this Personal Data without consequences to the availability or the functioning of the Site and Services. Users who are uncertain about which Personal Data is mandatory may contact us for clarification.
When you visit the Site or our App, we may automatically collect certain information about your device, including information about your web browser, IP address and/or domain name, IMEI or other device information, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating systems and platforms, location information, and details about the cookies installed on your device using cookies and similar technologies. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.
We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide you with certain functions on our Site and help collect data. This section explains how we use Cookies to collect information about the way you use our Site and how you can control them.
We use Cookies to track how you use our Site by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based on your browsing history and previous visits to the Site. Information supplied to us using Cookies helps us to provide a better online experience and marketing communications to them, as the case may be. We may combine the information we collect from Cookies with Personal Data that we have collected from you to learn more about how you use our Site to improve it.
We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:
To enhance our content and to deliver a better online experience for our users, we sometimes embed articles, images and videos from other websites on the Site. We currently use, and may in the future use, content from websites such as YouTube, Facebook, LinkedIn, and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties. You should consult and review the relevant third-party privacy statement or policy for information on how these Cookies are used and how you can control them.
We also embed social sharing icons throughout our Site. These sharing options are designed to enable users to easily share content from our Site with others using a variety of different social networks. The Site may collect information such as the web pages you visited and IP addresses, and may set Cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access.
Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments.
Find out how to manage Cookies on popular browsers:
If you are using a mobile device to access the Site, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.
Please note that if you restrict, disable or block any or all Cookies in your browser or device, the Site may not operate properly, and you may not have access to our services available through the Site. We will not be responsible for your inability to use our Site or any degraded function you may experience that may be caused by your settings and choices regarding Cookies.
We may use Google Analytics to help analyze how you use our Services. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Site. Google will store this information.
If you do not want your Site visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
Any feedback, content, suggestions, data, inputs or other information that you provide while interacting with our AI Technologies (including, but not limited to, text inputs, corrections, responses, or suggestions) may be used by us to improve, refine, and enhance our AI Technologies and Services. This may include using aggregated, anonymized data from your interactions to train, develop, and enhance the capabilities of our AI Technologies. By providing feedback or interacting with our AI Technologies, you agree that any input or data you provide may be used for improving our services, and you will not be entitled to any compensation or financial benefit from the use of this data. We are committed to protecting your personal information. Any feedback or interaction data used for our AI Technologies will be anonymized and aggregated to ensure your privacy.
Some of the open-source projects used on our Site or Tilt App are AI Technologies and your use of those open-sourced AI Technologies, such as the AI generation of images for your Tilts, may result in data being shared with those open-source AI projects to help improve, train and refine AI models for the benefit of a broader community. We do not claim ownership of your data, but by using these features, you grant us the right to share non-personal, anonymized, and aggregated data with open-source AI projects, subject to applicable laws.
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
Personal Data is processed using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. Data may be accessible by us and in some cases, certain personnel involved with the operation of our Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. You may request a list of these parties at any time.
We may process your Personal Data if one of the following applies:
Data we collect about you is collected to:
We may share your Personal Data with our service providers and vendors to assist us in providing you with our Services. We do not share your Personal Data with third parties without your consent, except as described in this Privacy Notice or as otherwise required or permitted by applicable law. We may share your Personal Data with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Notice.
We may share your Personal Data with third party companies and individuals that provide services on our behalf or help us operate the Site or our business (such as affiliates, professional advisors, customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your Personal Data only as directed or authorized by us and in a manner consistent with this Privacy Notice, and are prohibited from using or disclosing your information for any other purpose. We may also share your Personal Data for compliance purposes.
We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Subject to applicable law, by providing your Personal Data to us you consent to us using your Personal Data for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. We may send you such information via direct mail, email, SMS, and MMS.
If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:
We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We determine data retention based on the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from an unauthorized user, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.
We will retain Personal Data related to contractual obligations until such obligations are fully performed. Personal Data collected for our legitimate interests will be retained as long as needed to fulfil such purposes.
We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data will be deleted (or, where permitted under applicable law, may be de-identified instead). Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability (where relevant under applicable law) cannot be enforced after expiration of the retention period.
However not all your Personal Data can be deleted or de-identified; see the section of this Privacy Notice on "Blockchain transactions", below.
The Site may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Data. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
The security of your Personal Data is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the Personal Data we collect. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. Any transmission of Personal Data is at your own risk.
For purposes of relevant data protection legislation, the Company is the Personal Data controller. We are a global company, with operations throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Any such transfer of Personal Data shall take place under applicable law and will be protected through international data transfer agreements where necessary that have been recognized by relevant data protection authorities as providing an adequate level of protection to the Personal Data we process. By using our Site and Services you understand that your Personal Data may be processed in the United States and in places outside of the United States, the EEA and the UK.
Residents of the EEA and the UK are granted certain rights over their Personal Data, which include:
Complaints: If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Notice, please contact us at legal@tilt.io and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint. We will notify you of the outcome of our investigation.
If you would like to exercise any of the rights listed above, or if you would like to contact us about any questions you may have regarding your Personal Data, please contact us at legal@tilt.io and provide (a) enough information to identify you and (b) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.