Privacy Policy - Tingle Software

Your privacy is important to us. This privacy statement explains the personal data Tingle Software processes, how Tingle Software processes it, and for what purposes.

Tingle Software offers a wide range of products, including products used to help operate enterprises worldwide, devices you use in your home, software that students use at school, and services developers use to create and host what’s next. References to Tingle Software products in this statement include Tingle services, websites, apps, software, and devices.

Please read the product-specific details in this privacy statement, which provide additional relevant information. This statement applies to the interactions Tingle Software has with you and the Tingle Software products listed below, as well as other Tingle Software products that display this statement.

Personal data we collect

Tingle Software collects data from you, through our interactions with you and through our products for a variety of purposes described below, including to operate effectively and provide you with the best experiences with our products. You provide some of this data directly, such as when you create a online account, administer your organization’s licensing account, register for an event, upload a document, purchase a subscription, or contact us for support. We get some of it by collecting data about your interactions, use, and experience with our products and communications.

We rely on a variety of legal reasons and permissions (sometimes called “legal bases”) to process data, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with legal obligations, for a variety of purposes described below.

We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include:

Data brokers from which we purchase demographic data to supplement the data we collect.
Services that make user-generated content from their service available to others, such as local business reviews or public social media posts.
Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
Service providers that help us determine your device’s location.
Partners with which we offer co-branded services or engage in joint marketing activities.
Developers who create experiences through or for Tingle Software products.
Third parties that deliver experiences through Tingle Software products, such as those related to Micro-Lending.
Publicly-available sources, such as open government databases.

If you represent an organization, such as a business or school, that utilizes Enterprise and Developer Products from Tingle Software, please see the Enterprise and developer products section of this privacy statement to learn how we process your data.

You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data required to operate and provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use the data will not work for you.

The data we collect depends on the context of your interactions with Tingle Software and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law.

The data we collect can include the following:

Name and contact data. Your first and last name, email address, postal address, phone number, and other similar contact data. Credentials. Passwords, password hints, and similar security information used for authentication and account access. Demographic data. Data about you such as your age, gender, country, and preferred language. Payment data. Data to process payments, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument. Subscription and licensing data. Information about your subscriptions, licenses, and other entitlements. Interactions. Data about your use of Tingle Software products. In some cases, such as search queries, this is data you provide in order to make use of the products. In other cases, such as error reports, this is data we generate. Other examples of interactions data include:

Device and usage data. Data about your device and the product and features you use, including information about your hardware and software, how our products perform, as well as your settings. For example:
- Payment and account history. Data about the items you purchase and activities associated with your account.
- Browse history. Data about the webpages you visit.
- Device, connectivity, and configuration data. Data about your device, your device configuration, and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings, and information about WLAN access points near your device.
- Error reports and performance data. Data about the performance of the products and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.
- Troubleshooting and help data. Data you provide when you contact Tingle Software for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with Tingle Software, data about the condition of your device, and the products you use related to your help inquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
Interests and favorites. Data about your interests and favorites, such as the sports teams you follow, the programming languages you prefer, the stocks you track, or cities you add to track things like weather or traffic. In addition to those you explicitly provide, your interests and favorites can also be inferred or derived from other data we collect.
Content consumption data. Information about media content (e.g., TV, video, music, audio, text books, apps, and games) you access through our products.
Searches and commands. Search queries and commands when you use Tingle Software products with search or related productivity functionality.
Voice data. Your voice data, such as the search queries or commands you speak, which may include background sounds.
Text, inking, and typing data. Text, inking, and typing data and related information. For example, when we collect inking data, we collect information about the placement of your inking instrument on your device.
Images. Images and related information, such as picture metadata.
Contacts and relationships. Data about your contacts and relationships if you use a product to share information with others, manage contacts, communicate with others, or improve your productivity.
Social data. Information about your relationships and interactions between you, other people, and organizations, such as types of engagement (e.g., likes, dislikes, events, etc.) related to people and organizations.
Location data. Data about your device’s location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postal code level.
Other input. Other inputs provided when you use our products. For example, data such as the action taken on Tingle Software hardware.

Content. Content of your files and communications you input, upload, receive, create, and control. For example, photos, images, songs, movies, software, and other media or documents you store, retrieve, or otherwise process with our services.

Feedback and ratings. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.

Product-specific sections below describe data collection practices applicable to use of those products.

How we use personal data

Tingle Software uses the data we collect to provide you rich, interactive experiences. In particular, we use data to:

Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
Improve and develop our products.
Personalize our products and make recommendations.
Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

For these purposes, we combine data we collect from different contexts (for example, from your use of two Tingle Software products). However, we have built in technological and procedural safeguards designed to prevent certain data combinations where required by law. For example, where required by law, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address, or phone number.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For example, we manually review short snippets of a small sampling of voice data we have taken steps to de-identify to improve our speech services, such as recognition and translation.

When we process personal data about you, we do so with your consent and/or as required to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests of Tingle Software as described in this section and in the Reasons we share personal data section of this privacy statement. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in the Where we store and process personal data section of this privacy statement.

More on the purposes of processing:

Provide our products. We use data to operate our products and provide you with rich, interactive experiences. For example, if you enter a search query in a compatible search product, we use that query to display search results to you. Additionally, as communications are a feature of various products, programs, and activities, we use data to contact you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
Product improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features.
Personalization. Many products include personalized features, such as recommendations that enhance your productivity and enjoyment. These features use automated processes to tailor your product experiences based on the data we have about you, such as inferences we make about you and your use of the product, activities, interests, and location. Many of our products provide controls to disable personalized features.
Product activation. We use data—such as device and application type, location, and unique device, application, network, and subscription identifiers—to activate products that require activation.
Product development. We use data to develop new products. For example, we use data, often de-identified, to better understand our customers’ computing and productivity needs which can shape the development of new products.
Customer support. We use data to troubleshoot and diagnose product problems, repair customers’ devices, and provide other customer care and support services, including to help us provide, improve, and secure the quality of our products, services, and training, and to investigate security incidents.
Help secure and troubleshoot. We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, detecting malware and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
Safety. We use data to protect the safety of our products and our customers. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices.
Updates. We use data we collect to develop product updates and security patches. For example, we may use information about your device’s capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximize your experience with our products, help you protect the privacy and security of your data, provide new features, and ensure your device is ready to process such updates.
Promotional communications. We use data we collect to deliver promotional communications. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from Tingle Software by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions, and promotional communications, see the How to access and control your personal data section of this privacy statement.
Relevant offers. Tingle Software uses data to provide you with relevant and valuable information regarding our products. We analyze data from a variety of sources to predict the information that will be most interesting and relevant to you and deliver such information to you in a variety of ways.
Advertising. Tingle Software uses data we collect through our interactions with you, through some of our products, and on third-party web properties, for advertising in our products and on third-party properties. We may use automated processes to help make advertising more relevant to you. For more information about how your data is used for advertising, see the Advertising section of this privacy statement.
Prize promotions and events. We use your data to administer prize promotions. For example, if you enter into a prize promotion, we may use your data to select a winner and provide the prize to you if you win. Or, if you register for a workshop or event, we will add your name to the list of expected attendees.
Transacting commerce. We use data to carry out your transactions with us. For example, we process payment information to provide customers with product subscriptions and use contact information to deliver goods purchased from our Store.
Reporting and business operations. We use data to analyze our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
Protecting rights and property. We use data to detect and prevent fraud, resolve disputes, enforce agreements, and protect our property. For example, we use data to confirm the validity of software licenses to reduce piracy. We may use automated processes to detect and prevent activities that violate our rights and the rights of others, such as fraud.
Legal compliance. We process data to comply with law. For example, we use the age of our customers to ensure we meet our obligations to protect children’s privacy. We also process contact information and credentials to help customers exercise their data protection rights.
Research. With appropriate technical and organizational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. For example, if you use a Tingle Software product provided by an organization you are affiliated with, such as an employer or school, or use an email address provided by such organization to access Tingle Software products, we share certain data, such as interaction data and diagnostic data to enable your organization to manage the products. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among affiliates and subsidiaries controlled by Tingle Software. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will retain, access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to do any of the following:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
Protect our customers, for example, to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone.
Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
Protect the rights or property of Tingle Software, including enforcing the terms governing the use of the services—however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of Tingle Software, we will not inspect a customer's private content ourselves, but we may refer the matter to law enforcement.

For more information about data we disclose in response to requests from law enforcement and other government agencies, please see our Law Enforcement Requests Report.

Please note that some of our products include links to or otherwise enable you to access products of third parties whose privacy practices differ from those of Tingle Software. If you provide personal data to any of those products, your data is governed by their privacy policies.

How to access and control your personal data

You can also make choices about the collection and use of your data by Tingle Software. You can control your personal data that Tingle Software has obtained, and exercise your data protection rights, by contacting Tingle Software or using various tools we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which products you use. For example, you can choose whether you wish to receive promotional emails, SMS messages, telephone calls, and postal mail from Tingle Software.

Not all personal data processed by Tingle Software can be accessed or controlled via the tools available. If you want to access or control personal data processed by Tingle Software that is not available via the tools above or directly through the Tingle Software products you use, you can always contact Tingle Software at the address in the How to contact us section or by using our web form.

You can access and control your personal data that Microsoft has obtained with tools Tingle Software provides to you, which are described below, or by contacting Tingle Software. For instance:

If Tingle Software obtained your consent to use your personal data, you can withdraw that consent at any time.
You can request access to, erasure of, and updates to your personal data.
If you’d like to port your data elsewhere, you can use tools Tingle Software provides to do so, or if none are available, you can contact Tingle Software for assistance.

You can also object to or restrict the use of your personal data by Tingle Software. For example, you can object at any time to our use of your personal data:

For direct marketing purposes.
Where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.

You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.

If your organization, such as your employer, school, or service provider, provides you with access to and is administering your use of Tingle Software products, contact your organization to learn more about how to access and control your personal data.

You can access and control your personal data that Tingle Software has obtained, and exercise your data protection rights, using various tools we provide. The tools most useful to you will depend on our interactions with you and your use of our products.

Not all personal data processed by Tingle Software can be accessed or controlled via the tools above. If you want to access or control personal data processed by Tingle Software that is not available via the tools or directly through the Tingle Software products you use, you can always contact Tingle Software at the address in the How to contact us section or by using our web form. We will respond to requests to control your personal data within 30 days.

Your communications preferences

You can choose whether you wish to receive promotional communications from Tingle Software by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain Tingle Software products, programs, activities, or to surveys or other informational communications that have their own unsubscribe method.

Your advertising choices

To opt out of receiving interest-based advertising from Tingle Software, visit our opt-out page. When you opt out, your preference is stored in a cookie that is specific to the web browser you are using. The opt-out cookie has an expiration date of five years. If you delete the cookies on your device, you need to opt out again.

Because the data used for interest-based advertising is also used for other required purposes (including providing our products, analytics, and fraud detection), opting out of interest-based advertising does not stop that data collection. You will continue to get ads, although they may be less relevant to you.

You can opt out of receiving interest-based advertising from third parties we partner with by visiting their sites (see above).

Browser-based controls

When you use a browser, you can control your personal data using certain features. For example:

Cookie controls. You can control the data stored by cookies and withdraw consent to cookies by using the browser-based cookie controls described in the Cookies section of this privacy statement.
Browser controls for "Do Not Track." Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, Tingle Software services may not correctly respond to browser DNT signals. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving interest-based advertising from Tingle Software as described above.