Privacy Policy

Last revised and effective as of: January 6, 2024

This Privacy Policy applies to information collected by Tiny Management, Inc. (Tiny Management we or us or our) through your use of the Tiny Management website at https://www.tinymanagement.com/ and any subdomains thereof and the services, features, and information available on the Site now and in the future (collectively, the Site). As used herein, you and your mean a user of the Site. As used in this Privacy Policy (a) GDPR means the General Data Protection Regulation (EU) 2016/679; (b) UK Data Protection Laws means the UK GDPR and the UK's Data Protection Act 2018 (UK DPA 2018); (c) UK GDPR means the UK equivalent of the GDPR, as defined in section 3(10) (and as supplemented by section 205(4)) of the UK DPA 2018; and (d) European Data Protection Laws means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.

As used in this Privacy Policy, the terms using and processing information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within Tiny Management or among our affiliates within the United States or internationally.

This Privacy Policy serves to notify you of the following:

In connection with your use of the Site, we may collect information about you which may include your name, address, and email address. Additionally, our Outside Contractor (as defined below) that is responsible for billing and payment processing services (the Payment Services Provider) may collect your billing and credit card information (which may include, without limitation, name, payment details, country, and postal code) from you directly. We may also collect demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Site. To the extent any such information can be used to identify you or can be tied to you in identifiable manner, such information amounts to personal data for the purposes of and as defined in the European Data Protection Laws (to the extent applicable).

We will collect information that you submit to us. We may also receive information about you from third parties providing credit and debit card authorization and fraud screening services as part of your use of the Site.

Cookies and Action Tags.

We may collect information passively using cookies and action tags.

Cookies are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Site and other websites. Cookies can be used to personalize your experience on the Site, to assist you in using the Site, to allow us to statistically monitor how you are using the Site to help us improve our offerings, or to determine the popularity of certain content.

In particular, we would like you to be aware that, when you make a payment through the Site and interact with our Payment Services Provider, the Payment Services Provider may place cookies on your computer or mobile device in connection with the provision of its services, including for fraud prevention purposes. Please see https://stripe.com/cookie-settings for more information.

You do not have to accept cookies to use the Site. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the Help section of the toolbar. However, if you reject cookies, certain features or resources of the Site may not work properly or at all and you may experience some loss of convenience.

Action tags, also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Site, including email sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Site and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete.

Log Files.

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Site. This information may be used to analyze trends, to administer the Site, to monitor the use of the Site, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Site and evaluating the Site in general.

We are committed to protecting the privacy of children. The Site is not designed for or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13.

We will only use your information to the extent that the law allows us to do so. Pursuant to the European Data Protection Laws, legal bases for our processing your information may include (without limitation):

  1. where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
  2. where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Site or otherwise);
  3. where it is necessary for us to comply with a legal obligation to which we are subject; and/or
  4. where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing, improving, or marketing the Site and your interests or fundamental rights and freedoms do not override those legitimate interests.

We use the information collected to provide the Site to you, process your transactions, and to provide our software services to you at your request, to help us understand who uses the Site, for internal operations such as operating and improving the Site, to contact you for customer service and billing purposes, and if you opt in, so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you.

If you opt in, we and third parties acting on our behalf may subsequently send you electronic newsletters, contact you about the Site, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: privacy@tinymanagement.com.

If you identify yourself to us by sending us an email with questions or comments, we may use your information to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information collected to send announcements and updates regarding the Site or, if applicable, about your billing account status. You will not be able to unsubscribe from these Site announcements and updates as they contain important information relevant to your use of the Site and are necessary for the performance of our contract with you.

We generally disclose information we gather from you through the Site to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

Laws and Legal Rights.

We may disclose your information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Site or the general public.

Professional Advisors.

We may provide your information to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, Outside Contractors) to provide specific services and products related to the Site, such as hosting and maintaining the Site, providing credit card processing and fraud screening, including the Payment Services Provider, and developing applications for the Site. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Site, including your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

Sale of Business.

We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of Tiny Management or any of its Corporate Affiliates (as defined below), or that portion of Tiny Management or any of its Corporate Affiliates to which the Site relates, or in connection with a strategic investment by a third party in Tiny Management, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

Affiliates.

We may disclose information about you to our Corporate Affiliates. For purposes of this Privacy Policy: Corporate Affiliate means any person or entity which directly or indirectly controls, is controlled by or is under common control with Tiny Management, whether by ownership or otherwise; and control means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

We want your information to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

Information collected on the Site may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Site may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Site and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. Without limitation of the foregoing, you hereby expressly grant consent to Tiny Management to: (a) process and disclose such information in accordance with this Privacy Policy; (b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for information (as determined by the European Commission or the UK Information Commissioner's Office, as applicable, each, an Inadequate Jurisdiction) and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent required by applicable law: whenever we transfer your personal data (as defined in the European Data Protection Laws) to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission (accessible at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or the UK Information Commissioner's Office (accessible at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/), as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction. If you are a user accessing the Site from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Site are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We generally use information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must opt in and give us permission to use your information for any other purpose. You may also change your preference and opt out of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting privacy@tinymanagement.com.

Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

Request access to your information (commonly known as subject access request). This enables you to receive a copy of the information we hold about you and to check that we are lawfully processing it;

Request correction of the information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

Request erasure of your information. This enables you to ask us to delete or remove your information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your information in certain circumstances;

Object to processing of your information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

Request the restriction of processing of your information. This enables you to ask us to suspend the processing of your information, for example, if you want us to establish its accuracy or the reason for processing it;

Request the transfer of your information to another party; and

Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact privacy@tinymanagement.com.

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Do Not Track.

The term Do Not Track refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to opt in to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Site.

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact us in any of the following ways:

By email:

privacy@tinymanagement.com

By postal mail or courier:

Attn: Privacy
Tiny Management, Inc.
805 Neponset St., Norwood, MA 02062