Last updated 2020/03/01
1. The Basics
A. About Us
Thank You Small Business is a global movement which celebrates and supports small businesses globally an which is operated by Silver Lining Ltd, a company headquartered in the State of New York in the United States (“we,” “us,” “our,” and “TYSB”).
Our Service enables our Contacts and Visitors to, among other things, claim exclusive offers from TYSB corporate partners, submit their small business stories to be profiled, submit their small business to receive a Random Act of TY, get support on TY Days during May, and become a champion in their local communities. Find out more about the scope of our work on our website.
2. Privacy for Contacts
This section applies to the Personal Information we collect and process from a contact through the provision of our scope of work. In this section, “you” and “your” refer to Contact and potential Contacts.
A. Information We Collect
The Personal Information that we collect depends on the context of your interactions with TYSB, the features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:
(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you participate in any of our offerings and use the Service, consult with our customer service team, send us an email, claim one of our partner offers, submit one of our forms or communicate with us in any other way.
This information may include:
- Personal & Business contact information (such as your company name, job title, organization, location, phone number, email address, and country);
- Marketing information (such as your contact preferences);
- Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and
- Payment information (including your credit card numbers and associated identifiers and billing address).
Service Usage Data may include:
- Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection. If you are using our Mobile App, we may also collect information about the cellular network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s name and unique device ID, and information about the features of our Mobile App that you accessed.
- Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
- Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other communications you send through the Service. This information allows us to improve the content and operation of the Service, and facilitate research and analysis of the Service.
(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.
Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.
B. Use of Personal Information
We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:
- To communicate with you about your submission and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service. For example, you may submit a story and we need to notify you that it is published, nominate your business for a Random Act of TY that we wish to grant or want to send help to you for a day during TY Days.
- To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
C. Cookies and Tracking Technologies
We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf, which enable us to track certain behavior, such as whether the email sent through the Service was delivered and opened and whether links within the email were clicked. Web beacons allow us to collect information such as the recipient’s IP address, browser, email client type and other similar data as further described above details. We use this information to measure the performance of your email campaigns, to provide analytics information, enhance the effectiveness of our Service, and for other purposes described above. Reports are also available to us when we send email to you, so we may collect and review that information. For further information, please review the section below and our Cookie Statement available [HERE].
D. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- If Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
- The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.
- We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.
If you no longer want to be contacted by our team through our Service, please unsubscribe directly from our email communication or contact us directly to update or delete your data. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
3. Privacy for Visitors
This section applies to Personal Information that we collect and process when you visit the TYSB Site, and in the usual scope of our work. In this section, “you” and “your” refer to Visitors.
A. Information We Collect
(i) Information you provide to us on the TYSB Site or otherwise: Our TYSB offers various ways to contact us, such as through form submissions, to inquire about our movement and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in one offers, subscribe to marketing, or otherwise contact us. We may also collect Personal Information from you in person when you attend our gatherings or other. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.
The Personal Information we collect may include:
- Business contact information (such as your name, phone number, email address and country);
- Professional information (such as your job title, institution or company);
- Nature of your communication;
- Marketing information (such as your contact preferences); and
- Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.
- Any file attachments you choose to provide to us when completing our forms.
(ii) Information you wish to share with us through one of our submission forms: When you submit additional personal information such as images, quotes, company logo, availabilities, interest or any other information in one of our text boxes, by clicking the submit button, you are giving us the right to use this information as we intent in in the performance of our services.
The information we collect automatically includes:
- Device information: such as your IP address, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited and the web browser you used (software used to browse the internet) including its type and language)
- Usage data: such as information about how you interact with our site and live chat logs(such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage).
B. Use of Personal Information
We may use the information we collect through our TYSB Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:
- To provide, operate, optimize, and maintain the TYSB Site.
- To send you marketing information, product recommendations and non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
- To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
- To manage the TYSB Site and system administration and security.
- To manage gathering registrations and attendance, including sending related communications to you.
- To manage TY Day Submissions, including sending related communications to you.
- To manage Random Acts of TY Submissions, including sending related communications to you.
- To manage TY Story submissions, including sending related communications to you.
- To improve the navigation and content of the TYSB Site.
- To identify any server problems or other IT or network issues.
- To process transactions.
- To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
- To help us provide, improve and personalize our marketing activities.
- To facilitate the security and continued proper functioning of the TYSB Site.
- To carry out research and development to improve our TYSB Site and services.
- To conduct marketing research, advertise to you, provide personalized information about us on and off our TYSB Site, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
- To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
- To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our TYSB Site and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.
C. Public Information and Third-Party Websites
- Social media platforms and widgets. The TYSB Site includes social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
D. Cookies and Tracking Technologies
E. Other Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
- Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences (see Section 5. General Information, C. Your Choices and Opt-Outs below).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
3. General Information
A. How We Share Information
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) Any other person with your consent.
B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)
If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the “Questions and Concerns” section below.
C. Your Choices and Opt-Outs
Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the “Questions and Concerns” section below. Please note that some communications (such as purchases from our store, collaborations around TY Days, Random Acts of TY, Gathering and TY Stories) are considered transactional and necessary for account management, and you cannot opt out of these messages unless you contact our support team.
D. Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Service.
- Whether our Contacts would reasonably expect that we would retain the data until they remove it or until our relationship is terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
E. Do not Track
F. Changes to this Policy
G. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send us an email at [email protected]