Last Modified: August 1, 2024
Tiger’s Eye Ventures, LLC (“we,” “us,” “Data Processor,” the “Company”), doing business as Tiger’s Eye, offers creative services including but not limited to branding, campaign development, content creation, product strategy and design, public relation communications, marketing and AI consultation to its clients; collectively, these are COMPANY’s “Services.” This Privacy Policy applies to all our clients as well as any potential data subjects whose information may be included in the data provided by our clients in the use of our Services.
Privacy Policy as a Data Processor
This Privacy Policy describes how the Company as a Data Processor (“Processor”) collects, uses, discloses, and protects personal data on behalf of its Clients. We acknowledge the importance of privacy and is committed to ensuring the security and confidentiality of personally identifiable information (PII) in accordance with applicable data protection laws and regulations.
Contents
- Definitions
- Legal Basis for Collection and Use of Personal Data
- Disclosure of Personal Data
- Data Security
- Data Retention
- Data Subject Rights
- International Data Transfers
- Applicable Regulatory Requirements
- Data Protection Officer
- Changes to this Privacy Policy
- Contact Information
1. Definitions
“Artificial Intelligence” or “AI” refers to a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations, or decisions influencing real or virtual environments.
“Data Controller” refers to an individual or organization that determines the purposes for which and means by which data is processed. The Company is not a Data Controller for the purposes of this Data Policy.
“Data Subject” refers to an identified or identifiable living individual to whom Personal Data directly or indirectly relates.
"Data Processor" refers to the Company acting as the data processor, providing services to its Clients involving any operation or set of operations performed on Personal Data on behalf of a Data Controller.
"Client" refers to the business, individual, or organization that subscribes to and utilizes Processor’s Services whereby personal data may be processed on its behalf. Client may be a Data Controller for the purposes of this Privacy Policy.
"Personal data" refers to any information relating to an identified or identifiable individual as defined by applicable data protection laws. Personal data may be provided to us via a visitor’s interactions with its website or from a Client using COMPANY’s Services.
“Usage data” refers to any information relating solely to the operation and use of applications, platforms, or other provider’s services in the provision of our Services to our Clients.
Scope of the Policy
Tiger’s Eye Ventures LLC is committed to the protection of Personal Data in accordance with United States (“US”), European Union (“EU”), Latin America (“LATAM”) and Asia-Pacific (“APAC”) regulations, including but not limited to the California Consumer Privacy Rights Act (“CCPA”) and the General Data Protection Regulation (“GDPR”).
This Privacy Policy supplements the Terms of Use (“ToU”) Agreement. It covers the use of:
- The Company’s web platform and the contact form used solely for the purposes of answering potential client inquiries; and
- The Company’s’ Services, which involve the processing of data, including any Personal Data, entirely provided and controlled by its Clients.
2. Legal Basis for Collection and Use of Personal Data
Via our Website
We collect minimal Personal Data from visitors when viewing or interacting with its website, www.tigers-eye.com, via third-party application (“HubSpot”). The Company only asks for a visitor’s name, title, email address, and a phone number; only the email address is a required field, and the visitor need not provide any other information. There is no passive collection of data, and visitors are free to explore the website without providing any Personal Data. We only use this information in responding to visitor’s potential interest in its Services.
Via our Clients
The Company (aka Data Processor) offers a Service to its Clients and does not modify, alter, manipulate, or determine the usage of any Client data. The collection and use of Personal Data are solely determined and controlled by the Client, in accordance with its own terms of service/use or privacy policy. As a Data Processor, we only processes and store Client data in the provision of our Services to the Client, that may or may not include any Personal Data, in accordance with the Terms of Use (ToU) and does not use this data for any other purpose.
Data provided by Clients is provided to the Company an aggregated, anonymized format that does not identify any individual Data Subject. We do not perform any operation or set of operations to de-anonymize any information received from its Clients for use of its Services. Data is used only as
The Client, in its role as a Data Controller, determines the purposes and means of processing the Personal Data. We do not control the content of our Clients’ applications or the types of Personal Data that Clients may choose to collect or manage when using our Services. We process any Personal Data per the written instructions provided by and agreed to with the Client acting as the Data Controller, and the Company does not use any sub processors for the provision of its Services.
We store our Clients' information on our service providers' infrastructure and process in accordance with our Terms of Use (ToU), which prohibits us from using the Client data only to meet contractual obligations and except as necessary to troubleshoot technical issue and provide and improve our Services.
We engage third-party services to collect and process usage data. For more information about how the Company protects personal information with these service providers, please see Section 4 "Data Security."
3. Disclosure of Personal Data
Via its Website
We do not disclose a visitor’s Personal Data provided through its website to any third parties except as necessary to troubleshoot technical issues, to comply with legal requirements, or to improve its Services.
Via its Clients
We do not disclose Personal Data to any third parties unless instructed to do so by the Client. The Processor may share personal data with sub-processors, subcontractors, or other third parties who assist in providing the Services to the Client. Any such disclosure is done in accordance with the Terms of Services (ToU).
Processor may disclose your personal information if required to do so by law.
4. Data Security
We take reasonable technical and organizational measures to protect Personal Data from unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to, encryption, access controls, regular security assessments, and employee/subcontractor training. Processor also requires its sub-processors to implement appropriate security measures to protect personal data.
As a Data Processor, we adhere to the standards set forth in Article 32 of the GDPR, implementing appropriate technical and organizational measures to ensure the appropriate levels of security.
In event of a data breach, the Company will immediately notify the impacted parties, including our Clients and appropriate authorities where applicable, within 48 hours from when we first become aware of the breach.
5. Data Retention
Processor retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations. Upon the termination of the Client’s contract with the Company, the data will be removed in accordance with the Terms of Use (ToU).
6. Data Subject Rights
Our Clients control and are responsible for correcting, deleting or updating the information they intake and provide to COMPANY for its Services. Clients are responsible for compliance with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to COMPANY for processing purposes.
Any consumer privacy requests should be directed to the Client, who has control over the Personal Data. The Processor may assist the Client in fulfilling its obligations to respond to any requests in accordance with Terms of Use (ToU).
7. International Data Transfers
We intend to keep the Client data in the same region the Customer operates in. In some cases, the Processor may transfer personal data to countries or host services in countries outside of the European Economic Area (EEA) or any other jurisdiction where the data protection laws may differ from those of the country where the data was originally collected. In such cases, Data Controllers or relevant 3rd party service providers will ensure that appropriate safeguards, such as data security controls, standard contractual clauses (SCC’s) or appropriate certification, are in place to protect the personal data in accordance with applicable data protection laws.
8. Applicable Regulatory Requirements
Tiger’s Eye Ventures, LLC (as a Data Processor) asserts that this Privacy Policy is sufficient to address any U.S. and international privacy regulations including California Consumer Privacy Act (CCPA) and General Data Protection Regulation (GDPR). If there are any questions, please contact us at the information provided below.
9. Data Protection Officer
The Privacy Office at Tiger’s Eye Ventures, LLC is led by the Head of Security, Privacy, and Systems who will be the point of contact (acts as a Data Protection Officer, or “DPO”) for any EU Clients or Data Subjects for any privacy-related matters. Please note that a DPO requirement (under article 37 of GDPR) does not fully apply to the Company as we are not involved in the systematic monitoring of any Data Subject, via of our website or the Client’s Data, on a large scale. Additionally, the Company enables its Clients to be the owner and custodian of its data.
The Privacy Officer can be contacted at: privacy@tigers-eye.com
10. Changes to this Privacy Policy
We may update this Privacy Policy periodically to reflect changes in the Company’s data processing practices or legal requirements. The most current version of the Privacy Policy will be posted on Tiger’s Eye Ventures, LLC’s websites or provided directly to the Client. It is the Client's responsibility to review this Privacy Policy periodically.
11. Contact InformationIf you have any questions or concerns about this Privacy Policy or the processing of personal data by Tiger’s Eye Ventures, LLC, please contact the Client directly, as we act on the Client's instructions and do not have the means or capacity to directly interact with individual Data Subjects.
Clients may directly reach COMPANY through their Account Manager or at privacy@tigers-eye.com.