Privacy Policy

Effective Date: May 1, 2024

Teluul and its subsidiaries and affiliates (collectively, “ Teluul,” “ we,” “ us,” or “ our”) respect your privacy. Consistent with our commitment to handling your personal information in an open and transparent manner, this Privacy Policy describes our information handling and privacy practices and your choices with respect to your personal information.

Please carefully review this Privacy Policy to learn more about our information handling and privacy practices. You can also jump to a particular topic by clicking the following links:

SCOPE

This Privacy Policy describes how we use, disclose, and protect the personal information collected:

Collectively, we refer to our online and offline interactions with you as the “ Services.”

In this Privacy Policy, “ personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. Personal information includes information that is defined as “personal data” in applicable data protection and privacy legislation in any relevant jurisdiction.

Please note that this Privacy Policy describes how we handle personal information as a “controller” or “business” (as these terms are defined in applicable data protection and privacy legislation) only.

This Privacy Policy does not apply to the personal information that we receive from or collect on behalf of our customers for processing on their behalf in connection with the delivery of our products and services to them (“ Customer Personal Information”). Our processing of Customer Personal Information is subject to our customer agreements. Additionally, this Privacy Policy does not apply to the personal information that we collect from and about: (i) applicants and candidates for a position with Teluul; or (ii) Teluul employees, contractors, and other personnel.

Individuals in the EEA, Switzerland, and the UK: If you are located in the EEA, Switzerland, or the UK, please review the “Supplemental Notice for Individuals in the EEA, Switzerland, and UK” which includes additional information about our information handling practices and your legal rights.

California Residents: If you are a California resident, please review the “Supplemental Notice for California Residents”, which includes additional information about our information handling practices and your legal rights.

Other U.S. State Residents: Depending on your U.S. state residency, under applicable law, you may have certain rights in relation to your personal information. Please review the “Supplemental Notice for Other U.S. State Residents”, which includes additional information about our information handling practices and the legal rights you may be entitled to exercise.

COLLECTION OF PERSONAL INFORMATION

Depending on your use of the Services and how you otherwise interact with us, we may collect or obtain information from and about you in several ways, including: (1) directly from you; (2) automatically when you visit and interact with the Site; and (3) from third parties. Additional details regarding our collection of your personal information are included below.

Information collected automatically

When you visit and interact with the Site, we (and our service providers and partners) may use cookies, pixels, and other similar technologies to automatically collect certain information from your browser and/or device.

The specific types of information we (and our service providers and partners) may collect include:

We (and our service providers and partners) may also use cookies or other similar technologies to collect information about your behavior on the Site (e.g., how you move and scroll through the Site, your keystrokes, how you interact with webforms, etc.) and the actions that you take upon receipt of an email from us.

Analytics

We use third-party analytics and tracking tools and services to better understand who is using the Site, how the Site is used, and how to improve the effectiveness of the Site and related content. We may also use the information collected to draw inferences. 

Interest-based advertising

We use third-party tools and services to serve interest-based advertisements to you across the internet. These tools may include cookies, pixels, web beacons, and/or other similar technologies that automatically collect, store, and/or transmit certain information about your interaction(s) with the Site and other websites and mobile apps that you interact with and use across devices. Our third-party service providers and partners use the collected information to serve advertisements to you and measure the performance of our advertising campaigns.

You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Please refer to your device’s settings or your browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or adjust your tracking preferences. 

Information collected from other sources

We may obtain your personal information from other sources, including our customers, our service providers, our business partners, and social media platforms.

The information that we receive from other sources may include contact information and internet or other electronic network activity information.

We may use the personal information that we receive from other sources to help us maintain the accuracy of or supplement the information we collect; personalize your experience with the Services; conduct internal business analysis; and fulfill other business or commercial purposes described in this Privacy Policy.

Combination of information

We may combine the personal information that we receive from and about you, including information you provide to us, information we automatically collect through the Site, and information we receive from third-party sources. Where applicable, we will use, disclose, and protect the combined information as described in this Privacy Policy.

USE OF PERSONAL INFORMATION

We use the personal information we collect for the following purposes:

We will also use your personal information as described to you at the point of information collection or with your consent. Additionally, we will use your personal information as we believe necessary or appropriate to protect our rights, privacy, safety, property, and/or those of others.

DISCLOSURES OF PERSONAL INFORMATION

We may disclose each of the categories of personal information we collect from and about you with the following categories of recipients:

We may disclose your personal information for other reasons that we will describe at the time of information collection or prior to disclosing your information. Additionally, we will disclose your personal information with your consent or when you direct us to do so.

Please note that we may de-identify, anonymize, or aggregate personal information and disclose such information to third parties for various purposes as permitted by law.

YOUR CHOICES

We respect your privacy and provide you with the ability to make certain choices about how we use your personal information, as described below.

Marketing and Promotional Communications: You can opt out of receiving marketing and promotional communications from us at any time by following the instructions included in any marketing or promotional email that you receive from us. Please note that even if you opt out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquires/requests.

Cookies: As noted above, we (and our third-party service providers and partners) use cookies on the Site for various purposes, including for analytics and advertising purposes. You can customize or change your Cookie Preferences at any time. You may also be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Please refer to your device’s settings or your browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or adjust your tracking preferences.

Access and Correct Personal Information: Through your account settings, you may access and, in some cases, edit or delete the information you have provided to us. If you want to request access to and/or correction of the personal information that we maintain relating to you, you can do so by emailing us at privacy@teluul.com.

INFORMATION SECURITY

We implement and maintain reasonable administrative, organizational, and technical security measures designed to protect the personal information under our control.

However, no information transmission or storage system can be 100% secure. As a result, we cannot guarantee the security of your personal information. We have procedures in place to manage security incidents and breaches and will notify you and any applicable regulator where we are legally required to do so.

INFORMATION RETENTION

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Privacy Policy, including to satisfy our legal or reporting requirements, unless a longer retention period is required or allowed under law.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk from unauthorized use or disclosure of the personal information; the purpose(s) for which we use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Teluul operates globally and engages service providers located around the world to help us deliver the Services. Accordingly, your personal information may be transferred outside of the country or region in which you reside, including to the United States (where Teluul is headquartered) and other countries where our data centers, affiliates and subsidiaries, service providers, and business partners are located. Where we transfer your personal information internationally, we do so in accordance with applicable law.

By using the Services, you acknowledge that your personal information may be transferred outside of your country of residence. You also understand that your personal information may be stored in the United States and may be subject to lawful requests by the courts or law enforcement authorities in the United States.

If you are situated in the European Economic Area, Switzerland, or the United Kingdom, please note that whenever we transfer your personal information to countries or regions that have not been recognized by the European Commission, the Swiss government, and/or the UK government as providing an adequate level of protection for personal information, we ensure that appropriate and suitable safeguards are in place to protect your information. In particular, we may use government-approved contracts (e.g., Standard Contractual Clauses) that provide appropriate safeguards for personal information that is transferred to countries that have not been recognized as providing an adequate level of protection. For more information about how we lawfully transfer your personal information internationally, please contact us as specified below.

THIRD-PARTY SERVICES

The Site contains links to websites and services provided by third parties, which are not governed by this Privacy Policy. Any personal information you provide to the owner or operator of another website or third-party service is provided directly to the owner or operator and is subject to its privacy policy, even if accessed through the Site. We strongly recommend that you review the privacy policy of each website or service that you access prior to providing any personal information to make sure you understand what information is collected and how such information is used by third parties.

CHILDREN’S PRIVACY

The Services are not intended for or directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under the age of 18.

CHANGES TO THIS PRIVACY POLICY

We occasionally update this Privacy Policy to reflect changes in our products and services and customer feedback and/or changes in applicable law.

The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised. If we make changes, we will revise the date at the top of this page and, in the case of material changes, we will provide you with additional notice (in accordance with applicable law).

Unless otherwise stated, the current version of this Privacy Policy applies to all personal information under our control. We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices.

CONTACT US

If you have any questions or comments about this Privacy Policy or our information handling and privacy practices, or if you would like to submit a privacy-related request, please email us at privacy@teluul.com.

SUPPLEMENTAL NOTICE FOR EEA, SWITZERLAND, AND UK RESIDENTS

The EU General Data Protection Regulation (“ GDPR”) and other applicable data protection legislation provides individuals located in the European Economic Area (“ EEA”), Switzerland, and the United Kingdom (“ UK”) with certain rights with respect to their personal information.

Pursuant to applicable legislation, this section provides additional details regarding our processing of personal information relating to individuals located in the EEA, Switzerland, and the UK. This section also describes the legal rights available to individuals in the EEA, Switzerland, and the UK in relation to their personal information and how they can exercise their rights.

Legal basis for processing

Applicable law in certain jurisdictions requires us to set out the “legal basis” on which we rely to collect and use your personal information. Where applicable, the legal bases that we rely on to collect and use your personal information are as follows:

Your legal rights

Under applicable law, you may have certain rights in relation to your personal information, including the right to:

If you are interested in exercising any of the above-listed rights, you can do so by emailing us at privacy@teluul.com with the subject line “EEA, Switzerland, and UK Resident Privacy Rights Request.”

In order to protect your privacy and confirm that you are entitled to exercise the abovelisted rights, we may need to request specific information from you to help us confirm your identity. Where applicable, we will use the requested information for verification purposes only.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “ CCPA”) provides California residents with certain rights with respect to their personal information. Pursuant to the CCPA, this section provides details regarding the categories of personal information relating to California residents that we collect, use, and disclose. This section also describes the legal rights available to California residents in relation to their personal information and how they can exercise their rights.

Personal information collection and disclosure

The following chart details which categories of personal information we have collected from and about California residents in the past twelve (12) months, the source(s) of each category of information, the categories of third parties to whom we have disclosed each category of information for a business purpose, and the categories of third parties with whom we have “shared” (as defined in the CCPA) each category of information (where applicable).

Please note that the first column in the chart lists by category the types of information described in the “Collection of Personal Information” section of our Privacy Policy, as required by the CCPA.

Category of Personal Information

Categories of Sources

Disclosures of Personal Information for a Business Purpose

Sale or Sharing of Personal Information

Identifiers, including names, postal addresses, email addresses, online identifiers, IP addresses, account names, and other similar identifiers

Directly from individuals

Through automated means

Third-party sources

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

  • Our analytics providers

We have sold or shared this category of information in the past 12 months with the following categories of third parties:

  • Our analytics providers

  • Our marketing and advertising partners (including social media platforms)

Personal information categories listed in the California Customer Records statute, including names, telephone numbers, and employment related information.

Directly from individuals

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

Commercial information , including products or services purchased, obtained, or considered.

Directly from individuals

Through automated means

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

  • Our analytics providers

We have sold or shared this category of information in the past 12 months with the following categories of third parties:

  • Our analytics providers

  • Our marketing and advertising partners (including social media platforms)

Internet or other electronic network activity information , including information about interactions with the Site and advertisements

Through automated means

Third-party sources

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

  • Our analytics providers

We have sold or shared this category of information in the past 12 months with the following categories of third parties:

  • Our analytics providers

  • Our marketing and advertising partners (including social media platforms)

Geolocation data, such as IP location

Through automated means

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

  • Our analytics providers

We have sold or shared this category of information in the past 12 months with the following categories of third parties:

  • Our analytics providers

  • Our marketing and advertising partners (including social media platforms)

Audio, electronic, visual, or similar information , including phone call recordings

Directly from individuals

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

Professional or employment related information, including employer names and job roles/titles

Directly from individuals

Third-party sources

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

Inferences, meaning inferences drawn from any of the information in the above-listed categories of information

Directly from individuals

Third-party sources

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

Sensitive personal information , including log-in information for accounts in combination with passwords allowing access to the accounts

Directly from individuals

We have disclosed this category of information for a business purpose in the past 12 months to the following categories of third parties:

  • Our affiliates and subsidiaries

  • Our service providers

Purposes for collecting personal information

As described in more detail in the “Use of Personal Information” section of our Privacy Policy, we collect personal information to manage the Site, conduct and improve our business and provide you with the Services, and as otherwise necessary or appropriate in connection with the fulfillment of other legitimate business or commercial purposes.

Disclosures of personal information

As described in more detail in the “Disclosures of Personal Information” section of our Privacy Policy, we disclose personal information to fulfill the purposes described above. We may also disclose certain categories of personal information to competent governmental and public authorities and other third parties as necessary or appropriate, including when we have a legal or contractual obligation to disclose the information.

Sale and sharing of personal information

As detailed in the chart above, we “sell” and “share” (as such terms are defined in the CCPA), certain categories of personal information to and with third parties and have “sold” and “shared” certain categories of personal information in the past twelve (12) months. Please refer to the chart above for additional details.

We do not have actual knowledge that we “sell” or “share” the personal information of individuals under 16 years of age.

Use and disclosure of sensitive personal information

As detailed in the chart above, we collect certain “ sensitive personal information” (as defined in the CCPA). However, we do not use or disclose sensitive personal information for any purpose other than those expressly permitted under the CCPA. These purposes include providing the Services and preventing, detecting, and investigating security incidents.

Retention of personal information

We will retain your personal information as long as necessary to fulfill the purpose(s) for which it was collected, unless a longer retention period is required or allowed under law. Additional details regarding our information retention practices can be found in the “Information Retention” section of our Privacy Policy.

Your legal rights

As a California resident, you have the right to request that we:

We will not discriminate against you if you decide to exercise your rights under the CCPA.

If you are interested in exercising any of the above-listed rights, you can do so by sending an email to privacy@teluul.com with the subject line “CA Resident Privacy Rights Request.”

You are not required to create an account with Teluul to exercise your rights. However, in order to protect your privacy, we may require the matching of up to three pieces of personal information provided with your request with information we maintain in order to verify that it is you making the request. Where applicable, we will use the requested information for verification purposes only. Please note that we may decline a request where we are unable to verify your identity and confirm that the personal information we maintain relates to you.

Authorized agents

You may authorize someone to submit a privacy rights request on your behalf (an “ authorized agent”). An authorized agent will need to demonstrate that you have authorized them to act on your behalf, unless you have provided the agent with power of attorney pursuant to applicable law. Depending on the evidence provided, we may also contact you to verify your identity with us or request confirmation from you that the agent is authorized to submit the request on your behalf.

Exercising your sale and sharing opt-out right

As detailed in the chart above, we sell and share certain categories of personal information to and with third parties. If you are 16 years of age or older, in addition to the rights described above, you have the right to direct us to not sell or share your personal information at any time. To exercise your opt-out right, you may submit a request to us by:

Alternatively, where available, you can use certain preference signals to exercise your sharing opt-out right automatically with all businesses that you interact with online, including Teluul. If you enable a browser-based opt-out preference signal that complies with the CCPA, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use.

An authorized agent may also use the methods described above to submit an opt-out request on your behalf if you provide the agent with signed permission to do so. Please note that we may request from the agent documentation demonstrating that they have your authority to act on your behalf.

SUPPLEMENTAL NOTICE FOR OTHER U.S. STATE RESIDENTS

Applicable law in Colorado, Connecticut, Utah, and Virginia provides residents with certain rights with respect to their personal information. This section provides additional details regarding our handling of personal information relating to individuals residing in these states. This section also describes the legal rights available to individuals residing in these states in relation to their personal information and how they can exercise their rights.

Personal information collection and use

Depending on the nature of our relationship with you, we may collect a variety of personal information from and about you. The “Collection of Personal Information” section of our Privacy Policy describes in detail the categories of personal information we collect.

As described in the “Use of Personal Information” section of our Privacy Policy, we collect personal information to manage the Site, conduct and improve our business and provide you with the Services, and as otherwise necessary or appropriate in connection with the fulfillment of other legitimate business or commercial purposes.

Disclosures of personal information

As described in more detail in the “Disclosures of Personal Information” section of our Privacy Policy, we disclose personal information to fulfill the purposes described above. We will also disclose certain categories of personal information to government and public authorities and other third parties as necessary or appropriate, including when we have a legal or contractual obligation to disclose the information.

Targeted advertising

As described in the “Use of Personal Information” section of our Privacy Policy, we (and our partners) use cookies and other similar technologies to collect and transfer personal information that is used to display advertisements to you. The use of your personal information to display certain advertisements to you constitutes “ targeted advertising” under applicable law. Details on how you can opt out of our use and disclosure of your personal information for “targeted advertising” purposes can be found below.

Your legal rights

If you reside in Colorado, Connecticut, Utah, or Virginia, under applicable law, you may have certain rights in relation to your personal information, including the right to:

To exercise the rights listed above, please send an email to privacy@teluul.com with the subject line “U.S. State Privacy Rights Request” and specify in the email which right(s) you wish to exercise.

If you are interested in opting out of the sale of your personal information or our use and disclosure of your personal information for “targeted advertising” purposes, you may also be able to submit a request by clicking the “Your Privacy Choices” link located in the footer of the Site and following the instructions.

Upon receipt of your request, we will endeavor to honor it based on the information that we collect and maintain.

We will not discriminate against you if you decide to exercise your rights under applicable law.

You are not required to create an account with us to exercise your rights. However, in order to protect your privacy, we may require proof of your identity before acting on your request. Where applicable, we will use the requested information for verification purposes only. Please note that we may decline certain requests if we cannot verify your identity and confirm that the personal information we maintain relates to you.

Authorized agents

If you reside in Colorado or Connecticut, you may authorize someone to submit an opt out request on your behalf using the submission methods outlined above. Where appropriate, we will request information or documentation to verify your identity as well as the agent's authority to act on your behalf.

Appealing privacy rights requests decisions

If you reside in Colorado, Connecticut, or Virginia, in the event that we do not take action on your request, you also have the right to appeal our decision. To appeal our decision, please send an email to privacy@teluul.com with the subject line “U.S. State Privacy Rights Request Appeal.” If you are unsatisfied with the way that we have handled your appeal, you have the right to complain to your state's Attorney General.