We are Tatum and our services are provided by some or all of the following entities (the term "We" or "Our Company" means all or some of the entities listed below, depending on which is relevant to the person receiving or viewing this document). The relevant Tatum entity is the entity that (i) sent or otherwise made this document available to you, (ii) displays this document on its website, or (iii) with which you enter into a legal relationship.
Tatum's entities:
We are the controller of your personal data and are responsible for its processing.
You may contact us via this contact information:
Email: privacy@tatum.io
This Personal Data Processing Policy (hereafter the “Policy”) was created in compliance with the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter “GDPR”) and it stipulates the manner in which we process and protect your personal data.
When we offer and provide our services, we come into contact with individuals and their personal data. In order to be able to provide you with our services at a high standard, we need to acquire some of your personal data. In order for you to be able to better understand the extent of processing of your personal data, but also the sense behind their processing, we divide this data into the following categories:
E.g. your name, surname, business name, ID No., date of birth, delivery address, invoicing address, address of registered office, permanent residence address etc.
E.g. the date of conclusion of the Agreement, the duration of the Agreement, the date and reason for termination, the date of payment of the price for the Service (hereinafter referred to as the "Subscription"), the amount of the Subscription, the number of credits, order history, customer number, data provided when communicating with us, data necessary for the proper performance of the Agreement.
E.g. device IP/Mac address, cookies, device location data, authentication certificates.
E.g. device IP address, authentication certificates, cookies, device localization data, public keys, API keys
E.g. e-mail address, telephone number, IM identifiers, data mailbox ID etc.
E.g. Identification, address and contact data of the client (see above), type, number of the ID card and the state or authority that issued it, its validity period of the ID card, copy of the ID card, political exposure, data about the Ultimate Beneficial Owner of the client, country of origin, principal business activities, including primary source of income, type of transaction etc.
Your personal data can get to us in the following manner:
In the charts below you may find the purposes and legal grounds (titles) for processing your personal data, and also for how long this data is stored with us.
The purpose of processing according to this Policy is understood as any activity which we perform while selling our products or providing our services and for which we need to work with your personal data (this concerns in particular concluding and performing the Agreement, fulfillment of our statutory obligations, sending newsletters etc.).
Legal grounds for processing according to this Policy is understood as one of the four legal bases for processing personal data under the GDPR:
We process your personal data in particular so that we can provide our services to you. The legal basis for the processing is performance of the Agreement. You have no obligation to provide your data to us for this purpose. However, without this data we would not be able to provide our services to you, resulting in the inability to enter into the Agreement.
Furthermore, we process your personal data when managing your inquiries, handling incentives or complaints. If you decide to use any social network for communication with us, you need to remember that processing of such provided personal data is also governed by the terms and conditions of such social networks, over which we have no control.
Processing of personal data for this purpose is justified by our legitimate interest to communicate with our customers, or by your consent, depending on which Party initiates the communication. Provision of personal data in this case is not a statutory or contractual requirement. As such you are not obliged to provide your personal data to us for this purpose.
If you decide to publish a review, you do so voluntarily and we process your personal data based on your consent. You may withdraw your consent at any time. Provision of personal data in this case is not a statutory or contractual requirement. As such you are not obliged to provide your personal data to us for this purpose.
We process some of your personal data also in order to comply with our statutory obligations, in particular tax and accounting and AML/CTF obligations. Processing of the personal data for this purpose is justified by compliance with statutory obligations. We are obliged to process this information about you.
We process some of your personal data (in particular e-mail address or telephone number) also in order to send you business notifications (newsletters and offers of our services). We send business notifications to our customers based on our legitimate interest or to those persons who granted their consent therewith (e.g. via the web-based form).
The personal data processing for the purpose of sending business notifications is justified by your consent, or as the case may be, our legitimate interest on direct marketing, provided that you are our customer. Provision of personal data based on your consent is voluntary in this case, however, without it we would not be able to send you business notifications. You may withdraw your consent at any time. You may also object against sending the notifications based on our legitimate interest. If you let us know that you no longer wish to receive business notifications, we will immediately stop sending them. For this purpose please use the contact information above.
Provision of personal data in this case is not a statutory or contractual requirement. As such you are not obliged to provide your personal data to us for this purpose.
After termination of our contractual relationship, we continue to store your data for a reasonable period of time implied by the statutory period of limitation in order to protect our rights, property or security, or the rights, property or security of other persons. Processing of your personal data for this purpose is justified by our legitimate interest to protect our rights, property or security, or the rights, property or security of other persons.
Provision of personal data in this case is not a statutory or contractual requirement. As such you are not obliged to provide us your personal data for this purpose, nevertheless, we process your personal data for this purpose in situations where you have already provided your personal data to us.
Certain of our websites allow you to register and create a customer account to manage your plans, Subscriptions, and use our Platform. For this purpose, we typically process your name, surname, email address, and default region for API keys. You may also choose to provide your address, telephone number, and other billing information. This data is used to facilitate the ordering of our services and to provide customer-related functionalities and benefits.
Processing of your personal data for this purpose is justified by the performance of the Agreement and our legitimate interest in operating, maintaining, and improving the Platform and customer account functionality. Provision of personal data is voluntary; however, without such data it would not be possible to create and maintain your customer account or provide access to certain features of the Platform. You may request deletion of your account at any time via the Platform or by contacting us using the contact details above. If you close your account, we will deactivate it without undue delay, subject to any legal retention obligations.
You can also log in to your customer account using your social network login credentials (e.g. Google or Facebook login). The first time you log in using such a service, you will be asked to consent to the provision of your email address and certain data from your public profile (such as your name and other profile information in accordance with your social network settings). If you do not wish the social network to provide us with such data, you may instead create and access your customer account using standard login credentials.
Provision of personal data in this case is not a statutory or contractual requirement. However, certain data is necessary for the creation and operation of your customer account and access to Platform features.
The technology used to create personalized content and advertisements allows us to display our advertisements on partner websites to visitors who have shown interest in our website, products, or services. We strive to display only advertisements that are relevant to you and to avoid showing advertisements that are unrelated to your interests. Based on your order history, interests, and behavior on websites, personalized content and offers may be displayed to you on our website and on third-party websites and applications (including social networks). This activity is enabled in particular through cookies. You can read more about the management of your cookie preferences in the Cookie Policy.
For the purposes of direct marketing and the creation of personalized content and advertisements, we may also process email addresses and telephone numbers, always on the basis of your prior consent. You may withdraw your consent at any time via your account settings or by contacting us using the contact details above.
Processing of personal data for this purpose is based on your consent. Provision of personal data is voluntary; however, without such consent we would not be able to provide personalized content, marketing communications, or targeted advertisements to you. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.
Provision of personal data in this case is not a statutory or contractual requirement. As such, you are not obliged to provide your personal data to us for this purpose.
When you visit our website and use the Platform, we automatically process personal data about you based on so called cookie files. You can find more information about what cookies are, what cookies do we use and for what purpose, in the Cookie Policy.
We process this data, in particular if we are an obliged person under the AML-CFT regulations or if these or similar practices comply with our internal policy.
In order to ensure the security of your personal data and also to be able to offer and sell our products and provide our services to you, there are the following groups of recipients and processors helping us with personal data processing:
The personal data we collect about you is stored and processed in Germany, Poland, the US and the Czech Republic, or wherever we or our partners, affiliates and third-party service providers have servers and other facilities.
However, if we transfer your personal data for processing to a third country (outside the European Economic Area, which includes the countries outside the European Union - Iceland, Liechtenstein and Norway) or an international organisation, we do so only if the European Commission has determined that the third country or international organisation provides an adequate level of protection or if the recipient of the personal data has provided appropriate safeguards for the protection of the personal data and there are enforceable data subject rights and effective legal protection for data subjects in the destination country. We can also transfer data to the US under the data privacy framework.
In what manner is your personal data being processed?
Personal data may be processed both manually and automatically. We keep due records about all processing activities in compliance with the applicable legislation.
Contact us with realization of your rights at our contact information stated in the introduction of this Policy. We reserve the right to verify the identity of the person asserting such rights in a suitable manner. In case of repeated requests or clearly unfounded or unreasonable requests we may charge a reasonable fee or refuse to execute the request.
If you want to know whether we process your personal data, you have the right to obtain information from us about whether your personal data is being processed, and if so, you have the right to access your personal data. In case of repeated requests, we are entitled to charge a reasonable fee for a copy of the provided personal data based on the incurred administrative costs.
If you believe that we process inaccurate or untrue data about you, you have the right to request rectification thereof. You also have the right to completion of incomplete data. We will perform the rectification or completion without undue delay, however in each case according to our technical possibilities and available time.
You have the right to request erasure of personal data that we process about you in the following cases:
In case you are not interested in complete erasure of, but only in temporary restriction of processing of your personal data, you can request us to restrict the processing of your personal data.
In case you want us to transfer your personal data to a third party, you may exercise your right to data portability. However, in case exercising of this right could have adverse effects on the rights and freedoms of third parties, we would be unable to grant your request.
You have the right to object at any time against the processing of personal data, which is being processed in order to complete a task performed in public interest or when exercising public authority or for the purpose of our legitimate interests. In case we are unable to prove that there are serious legitimate grounds for the processing that outweigh your interests or rights and freedoms, we will terminate the processing on the basis of your objection without undue delay.
If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
As far as processing of your personal data for the purpose of sending business notifications is concerned, you may withdraw your consent with processing personal data and sending of business notifications simply by replying “No” to the e-mail or by expressing your disagreement in your reply in any other way, or by clicking the relevant link, if it is provided at the end of the business notification.
You are not a subject to any decision making based exclusively on automated processing, including profiling, that may have legal effects or any other significant impact on you.
You may also file a complaint at any time with the supervisory authority, which is the Office for Personal Data Protection, with a registered office at Pplk. Sochora 27, 170 00 Prague 7, tel.: 234 665 111. Complaints may be filed via the contact information stated here.
Where personal data is processed pursuant to Article 3(2) of the GDPR, those Tatum entities that are not established in the European Union are represented pursuant to Article 27 of the GDPR by Tatum Technology s.r.o., for the purposes of (i) dealing with the supervisory authority, (ii) making a request, and (iii) exercising the rights of data subjects. If the controller or processor of the personal data is a Tatum entity located outside the European Union (cf. the introduction to this document) and the processing of personal data pursuant to Article 3(2) GDPR occurs, you may exercise your rights through Tatum Technology s.r.o. and file a complaint with the aforementioned supervisory authority.
Our products, services or website are not primarily designated for persons under the age of 16. As such we do not intentionally collect their personal data. If we provide our products or services to a person under the age of 16, we request the consent of the person exercising parental responsibility for the child. If we find that we have accidentally collected personal data of a person under the age of 16 without the relevant consent, we will take steps towards erasing this data as soon as possible, with the exception of cases, where the applicable law obliges us to keep it.
Personal data protection in the Czech Republic is governed in particular by the following legislation:
Legislation as well as our business strategy and the associated manner of processing of your personal data may change. If we decide to update this Policy, we will publish the changes on our website and we will notify you about these changes. In cases where any more significant change of this Policy is to take place, or in case we are required to do so by the law, we will notify you in advance.
We would like to ask you to carefully read this Policy and to review it regularly when you communicate with us in the future or use the website.