DATA PRIVACY POLICY: TILT and Time Machine
Last Updated and Effective July 5, 2024
What is a Data Privacy Policy and Why Should You Care?
TILT's approach to privacy and privacy language: A common complaint of data privacy policies is that they are too complex, too long, too dense and with wording that makes them hard to understand. To avoid this, we keep explanations short, use plain language, put information in intuitive sections, and keep legalistic explanations to a minimum.
In this Privacy Policy, we use action verbs like gather, use, process, keep, maintain, share and delete to refer to how your data will be acted on. We want to make clear from the start that how your data is acted on depends on how you are interacting with the website or apps and what feature you are using. We go over this in detail below.. In general terms, TILT has made a commitment to minimize gathering, keeping and sharing your data. But we do engage in all three. We tend to use the word “process” as a default for all three actions throughout this policy. We prefer “process” because if your data is gathered it will be processed even if at a minimal level, just by you using the app at all. In very rare occasions, TILT will share your data in a manner that benefits both you and TILT, but we will only do this with your prior consent. TILT never sells your data.
Why should you care about the treatment of your personal data? This may sound obvious, but we all share private information all the time — our addresses, credit card numbers and other account numbers, social security numbers, birthdays, and more. But when we share any of these with an organization, data privacy policies come into play. A good data privacy policy will be transparent and tell users exactly how their information will be gathered, used, protected and removed. There should be no surprises.
At TILT and Time Machine, due to the nature of our work, we store and use people's personal stories as a tool for improved mental and emotional well-being. These personal stories are likely far more precious than digital identification data, so we take data privacy extremely seriously and believe that you should as well. Our websites and apps are designed to protect the confidentiality of any audio or video messages you may choose to record for your future use. If you have any questions while reading this policy, please don't hesitate to reach out to help@loveandtime.org.
What do we mean by data?
For purposes of this Data Privacy Policy and unless otherwise specified, “data” includes information that is linked to one person or a household including things like name, email address, login ID, third party identifiers, and contact information. Some jurisdictions might consider this to be “personal data,” “personally identifiable information,” or “sensitive personal data” in certain circumstances. We use Personally Identifiable Information (PII) or “user data” or “your data.” When you use and access our app or website, you accept and agree at each data interaction point to both this Data Privacy Policy and the Terms and Conditions, including that we will at times, and upon obtaining prior consent, share certain data with third party service providers (see below).
Opt-In (and case-by-case) Consent versus Global Consent
At TILT, we have chosen an Opt-in (case-by-case) approach to obtaining user consent. At each user interaction when user personal data (PII) is gathered, we will request consent from you, the user. While this means you may be asked more than once to confirm you're OK with sharing your data, we view this approach as transparent and respectful..
This Document will be Updated Periodically
We will update this Data Privacy Policy from time to time. When we do, we will notify you through our website or app when you log in to your account. We encourage you to periodically review this page for the latest information. The date of the most recent update will be visible at the beginning of the Privacy Policy.
Global Data Privacy Policy
This privacy policy serves as a global data privacy policy for TILT, Time Machine and any other websites or application tools that may be developed by TILT. For each application developed by TILT, this data privacy policy will be referenced and updated as necessary.
The Specifics on Gathering, Storing, or Processing Your Data
We process data to do things like operate the app platform and make sure you are able to use our services effectively. We may also process data to send you periodic newsletters. In all cases, the primary purpose of any communication is to help provide services to you. Infrequently, we may use communications to provide marketing for a service or event provided by TILT in which we reasonably believe you may have interest. But mostly, collecting data allows us to be more effective and to better assist more users who may be looking for mental health support. In addition, you can opt out of receiving texts or marketing communications at any time. Finally, if you opt-in, we may share some of your data with third parties that help us provide our services. TILT never sells data, and we carefully select the parties with whom we might share data. If you do not opt-in, we will not share your data with third parties.
What specific data is TILT gathering and processing?
Which data we process depends on how you're using our website or apps, and if you opt-in to data sharing. We explain in the section below the specific data we collect and process and the categories of information that can be shared with third party providers and the result, purpose, and, if you consent, the benefit of doing so.
Information Shared with Third Party Providers if You Choose to Use Our Tools
TILT utilizes the following Third Party integrations:
- YouTube
- Virtuous
- Stripe
- Fly.io
- Webflow
- Vimeo
We will inform you and request your consent prior to your use of these integrations.
YouTube (Video creation and hosting)
At TILT, in keeping with our commitment to value your PII, when we use links to YouTube videos, we use a privacy-conscious YouTube “no cookie” integration which means that you aren't tracked by YouTube when you load a YouTube video on our website. Typically, by interacting with YouTube videos, YouTube would send a cookie but by using the “no cookie” integration, you are not tracked.
To be extra careful, we still feel that you should review the Data Privacy Policy of YouTube: (https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/).
Virtuous (CRM software)
At TILT, we use Virtuous as our Customer Relationship Management Software (CRM).Virtuous helps us to manage our newsletter signups as well as donations made to TILT. There is no personal data shared with Virtuous when a linked form is loaded, but data is passed to Virtuous when you hit “Send” to sign up for the newsletter or to donate. For the newsletter, we save your email address and name to send personalized emails. Prior to agreeing to receive our newsletter, we will ask for specific consent to process user information in order to receive our newsletter. This is an example of sharing data with a partner in order for proper functioning of our services, and this is what we mean by “opt-in”
The sharing process is governed by this policy and the Virtuous privacy policy (https://virtuous.org/software/gdpr-compliance/). It is our understanding that Virtuous only uses your information as an agent of TILT but in order to be fully comfortable, you should review the Virtuous privacy policy.
Stripe (TILT payment processing component integration)
TILT uses Stripe as the actual payment processor for donations. Given the seriousness of sharing financial information in general, payment processing is a highly regulated industry since a great deal more sensitive data is processed than, say, for a newsletter sign-up. TILT only uses the Stripe integration on the donations page, but the Stripe donations page does request and process sensitive financial data, primarily for fraud-prevention purposes. TILT does not send any PII information related to TILT well-being tools. But given that this is the payment processing software, Stripe will request name, credit card number and the like in order to process donations and all of your data linked to donations will be transferred to Stripe. This information will only be used to process the donation.
TILT requests explicit consent before loading the Stripe integration on the donation page. This is another example of “opt-in.”
Once again, out of an abundance of caution, we still feel that you should review the Data Privacy Policy of Stripe: (https://stripe.com/privacy).
Fly.io (Time Machine Application Cloud Provider)
The TILT Time Machine application is hosted on Fly.io. It is the cloud computing provider where the Time Machine application is stored.All information including application codes are stored here. Fly.io safeguards (encrypts) all application information and no information is shared by Fly.io with third parties.
Fly.io clearly states that it “does not sell, share, rent, or trade user PII.” Please see Fly.io data privacy policy here: (https://fly.io/legal/privacy-policy/).
Webflow.com (Time Machine website host)
The Time Machine website is hosted on Webflow.com. It is similar to numerous other website creation and hosting locations. As a website host, no user PII data is stored with Webflow.com.
Webflow.com safeguards (encrypts) all information required to create and host websites and no information is shared with third parties by Webflow.com.
Webflow.com clearly states that it “will not give, sell, rent, or loan any Personal Information to any third party.”Please see Webflow.com data privacy policy here: (https://webflow.com/legal/privacy).
Vimeo (Video hosting and sharing)
Vimeo is similar to YouTube, however, unlike YouTube, Vimeo does not track you through the Vimeo video player. This means that by interacting with the Vimeo videos on TILT, you are not tracked.
To be extra careful, we still feel that users should review the Data Privacy Policy of Vimeo, found here: (https://vimeo.com/privacy).
Opting Out and Removing Your Personal Data
You can opt-out (request deletion an opt-out) of any and all TILT services simply by sending a deletion request to:team@loveandtime.org.
When TILT receives a deletion request from you, you will receive a general acknowledgement within two weeks. At TILT, it will generally take six weeks for us to thoroughly run through the deletion process. This is mainly due to the fact that certain third party providers only have periodic purging. If you do not opt-out, information may be stored indefinitely.
Clarification for California Users
As we have indicated above, we do not sell user data. In California, however, the laws define “sale” broadly to include the sharing of personal information in exchange for anything of value. If you opt-in to or use any of our services with third party providers, this use may be considered a “sale” of personal information under California law. For specific information on your data rights as a resident of California, see the California Consumer Privacy Act (CCPA), here https://oag.ca.gov/privacy/ccpa and here https://cppa.ca.gov/faq, and the California Privacy Rights Act (CPRA) here https://www.caprivacy.org/cpra-resource-center/.
The CCPA and the CPRA are California laws that provide its residents with certain rights over information about them, including notice about the categories of personal information we have collected from them in the preceding twelve (12) months and the purposes for which the information is used or disclosed. We have indicated above the user data that is processed by TILT, as well as the purpose for collection.