Tallo’s Commitment to Privacy
Effective as of August 8th, 2023.
Welcome to Tallo, a platform of Tallo LLC helping high school students and adult learners to discover and explore career options, be educated, trained, certification-prepared for in-demand careers, and explore related internship and career opportunities with employers; additional features and use cases will be added.
This Privacy Policy describes our practices regarding the information we collect through our Services (defined below), as well as any information we collect offline and combine in our databases. Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time.
PLEASE READ THE ENTIRE PRIVACY POLICY VERY CAREFULLY. BY USING ANY SERVICE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY.
Note about Children Under 13: Children under the age of 13 in the U.S. are not currently permitted to participate in Tallo as required by applicable law.
1. What definitions apply to the Tallo Platform Privacy Policy?
3. What information does Tallo collect and how does Tallo use or share your information?
4. How does Tallo work with third parties?
5. What happens if I access Tallo’s services through a mobile device?
6. How does Tallo protect information about children under 13 years old?
7. How does Tallo protect and store my information?
8. How can I access and manage my personal information?
9. What communications will I receive from Tallo and how do I limit them?
10. How do I close my account?
11. How long does Tallo keep my information?
12. How will Tallo notify me of changes to this policy?
13. What if I do not live in the U.S.?
14. What are my additional privacy rights if I’m a resident of certain states?
1. What definitions apply to the Tallo Platform Privacy Policy?
“Device” means anything, such as a computer or mobile phone, that connects to the internet that you use to access the Services.
“Device Identifier” is a sequence of numbers and/or letters, such as an IP address, that is automatically assigned to your Device used to access the Services.
“Personal Information” (or “PI”) means information that can reasonably be used alone or in combination with other reasonably available information, to identify or contact a specific individual.
“Services” means our websites, including www.tallo.com (“Site”), mobile applications and any other interactive features or services owned or controlled by Tallo that post a link to this Privacy Policy.
“Tallo” (and “we,” “us” and “our”) means Tallo LLC.
“Usage Information” includes, without limitation, the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit, and the time of day you used the Services, among other information
“User Content” means any text, audio, or visual data uploaded to the Tallo Platform by the User but does not include Usage Information or content created by us.
2. What is this policy?
WE FULLY DESCRIBE OUR PRIVACY PRACTICES BELOW IN THIS PRIVACY POLICY. THE SUMMARY IN THIS QUESTION PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF YOUR INFORMATION.
3. What information does Tallo collect and how does Tallo use or share your information?
What non-personally identifiable information does Tallo collect?
We automatically receive non-personally identifiable information (“Non-PI”) from your web browser or device connected to the Internet. That includes your IP address (the string of numbers that identifies the device), the name of the Web page you visited immediately before visiting ours, the page or pages you visit on our Site, and how much time you spend on each page. Please review the What personally identifiable information does Tallo collect? section of this Privacy Policy for a complete description of the Personal Information we collect.
How does Tallo use non-personally identifiable information?
We use this information to monitor and improve our Site. We also use it to study Internet traffic trends, administer the Site, gather information, and provide services. Please review the How does Tallo use personally identifiable information? section of this Privacy Policy for a complete description of how we use your PI.
When does Tallo share non-personally identifiable information?
We may also share non-PI, such as aggregate or de-identified user statistics, demographic information, and Usage Information with third parties. Please review the How does Tallo share personally identifiable information? section of this Privacy Policy for a complete description of how we may share your PI.
How does Tallo’s Site use “cookies”?
When you visit our Site, the server creates a piece of text known as a “cookie” to put on your device. The cookie is unique to your browser. It lets the server remember information about your visit. Cookies do not collect PI. We use cookies to follow how you use the Site to adapt Web content to your interests.
We may use cookies from other companies to provide relevant information to you. These cookies may record that you visited our Site and the websites you visited immediately before visiting our Site. These cookies can be used to provide relevant information to you on other websites.
You can accept or decline cookies. Most web browsers automatically accept cookies, but you can usually change your browser setting to decline cookies. If you decline cookies, you may not be able to see or use the interactive features of our Site and some products or services on our Site may not function the way they should.
You can opt out of the use of third-party cookies for marketing messages on other websites by visiting the Digital Advertising Alliance Consumer Choice Page and the Network Advertising Initiative Opt Out page and opting out with companies that participate in those choices. On this Privacy Policy’s effective date, those sites were at http://www.aboutads.info/choices and http://www.networkadvertising.org/choices. Opting out will not prevent you from seeing ads on the Internet; it will only affect ads that use cookies to serve messaging on the specific networks. We are not responsible for the activities of the third parties.
Does Tallo share information collected from cookies?
If permitted by law, Tallo may share information collected from cookies for marketing purposes, including product and service offerings, with its parent, subsidiaries and affiliates and with companies that are not connected to Tallo but want to send you information about their products or services and to offer our products and services. You can ask that your Personal Information collected from cookies not be shared with third parties by writing to privacy@tallo.com or by calling 855-765-7836. You may also opt-out, by clicking the Do Not Sell or Share My Personal Information link. Tallo may also share information collected from cookies if required by law or if permitted to do so for law enforcement purposes.
How We Respond to Do Not Track Signals?
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.
Third-Party Services and Information Third Parties Provide About You
The Services may permit interactions between the Services and a third-party feature or service. These third parties may provide us with information about you. Similarly, if you publicly post information on a third-party platform, such as a social media site, that references Tallo or one of the Services, your post may be published on our Services in accordance with that third party’s terms. These features may collect your IP address or other unique identifier, which page you are visiting on our website, and may set a cookie to enable the third-party feature to function properly. When you use a third-party feature through the Services, the third party may also have access to information about you and your use of our Services. Your interactions with third-party links and features are governed by the privacy policies of the third parties.
The information we collect is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website and service. The third party may allow you to remove the application or feature. If you do so we will no longer collect information about you through the application or feature, but we may retain the information previously collected in compliance with all applicable laws.
Information We Collect Automatically
Like other websites and online services, we and our analytics providers, vendors and other third-party service providers may automatically collect certain “Usage Information” whenever you access and use the Services. For example, we may collect information regarding how often a user accesses certain features.
We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products.
In addition, we may automatically collect your Device Identifiers so that our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
What personally identifiable information does Tallo collect?
You can use parts of our Site without providing PI. We may collect PI from you directly. The PI you provide, for example when creating an account profile, may include first and last name; postal zip code; telephone number; the name your child; payment information (through use of a third-party provider), User Content, the services you request; an e-mail address where We can contact you; and other information.
Does Tallo share personally identifiable information?
There are third-party service providers that provide us with online services and provide us with information regarding traffic on the Site, including the frequency of use and the actions users take when visiting the Site and to provide us with information regarding the use of the Site. These third-party service providers are given the least information needed to do their work for Tallo, as required by law. They have no other rights to the information and have agreed to keep the data private, to use it only to perform the work they provide for Tallo, and to keep the data safe. Tallo may also share your information for academic research purposes, when permitted by law.
We may also use or share information about you, including Personal Information, User Content, and Usage Information for the following purposes:
To provide the Services. We use your Personal Information to verify your registration, allow you to participate in features we offer, contact you regarding the Services, and to allow other users to contact you. As part of the Services, Tallo may release Personal Information to potential employers, career preparedness and career readiness providers, workforce development, and community organizations utilized for the Tallo Platform (“Tallo Platform Partners”). You understand and agree that such information sharing is an essential feature of the Services.
To market our products or services. If allowed by law, Tallo may share your information for commercial and/or marketing purposes (may include direct/targeted marketing), including product and service offerings, with companies that are not connected to Tallo but want to send you information about their products or services. If permitted by state and federal law, Tallo may share your information to offer services to you or give you information about services of third parties. You can ask that your Personal Information not be shared with third parties for commercial or targeted marketing purposes by writing to privacy@tallo.com, by calling 855-765-7836, or by clicking the Do Not Sell or Share My Personal Information link.
To operate the websites. Your Personal Information may be used to tailor content, recommendations and offers we display to you, both on the Services and elsewhere online, as well as to maintain or improve our Services.
Service Providers
We will share your Personal Information with third parties to provide services to us or you in connection with the Services. For example, we may provide your Personal Information to companies that provide services to help us with our business activities.
To create anonymous data for analytics. We may make information anonymous by excluding information that makes it personally identifiable to you, and use that anonymous data for our lawful business purposes.
For compliance, fraud prevention, and safety. We use your Personal Information as we believe is necessary or appropriate to (a) enforce our Terms of Use ; (b) protect our rights, privacy, safety or property, and that of you or others; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
For Administrative and Legal Reasons.
We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; to protect and/or defend any applicable Terms of Use or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual.
We may also use Device Identifiers to identify users and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without further consent or without notice to you.
For Business Transitions.
Tallo may share Personal Information with its parent, subsidiaries, and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with the requirements of this Privacy Policy and applicable law with regard to such Personal Information. In the event that Tallo goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred.
Notice of any completed change in ownership of your Personal Information, as well as any choices you may have regarding your Personal Information will be made by one or more of a prominent notice on the Services, a press release, government filings or email to you. This Privacy Policy will become binding upon the new owner of the Personal Information until amended.
For Testimonials. We may display personal testimonials of satisfied adult users on our Services in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us as set forth in “How do I contact Tallo?
Please note that information submitted on the Services via a “Contact Us” or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise. Tallo responds to requests for information and to questions from customers and possible customers. Because we only call customers at the telephone numbers they leave us, Tallo does not call people by using random or sequential telephone numbers. Tallo may use pre-recorded messages or text messages when allowed by law to make sure that customers receive the information they requested. Customers do not have to agree to receive calls or text messages in order to receive Tallo’s Services.
4. How does Tallo work with third parties?
Certain content provided through the Services may be hosted and served by third parties. In addition, the Services may link to third party websites or content over which Tallo has no control and which are governed by the privacy policies and business practices of those third parties.
Please also note that Tallo content may be included on web pages and websites that are not associated with us and over which we have no control. These third parties may independently collect data. Tallo is not responsible or liable for the privacy practices or business practices of any third party.
5. What happens if I access Tallo’s services through a mobile device?
If you use the Services through a mobile device or our mobile application, you agree that Tallo may store and use that information for security purposes (for example, for user verification or authentication and to ensure that our APIs are being used appropriately) and for marketing purposes as disclosed in this Privacy Policy
6. How does Tallo protect information about children under 13 years old?
Protecting the privacy of young children is especially important to Tallo. Children under the age of 13 (“Child Users”) are not currently permitted to use the Services. The Children’s Online Privacy Protection Act (COPPA) protects the privacy of children under the age of 13. It requires website operators and online services to post privacy policies and obtain true parental permission before collecting information from those children. Any information received from a child under the age of 13, who does not receive parental permission within 30 days of registration shall be permanently deleted.
Tallo does not knowingly permit Child Users to use our Services. If we learn that the Personal Information of a Child User has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or legal guardian and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact Tallo as set forth in “How do I contact Tallo?” to request that we delete that child’s personal information from our systems.
7. How does Tallo protect and store my information?
Tallo takes data security very seriously. Tallo takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and upon receipt, and at rest. Such measures may vary depending on the sensitivity of the information at issue.
Please note that no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
How will Tallo handle a data breach or security incident?
In the event that Tallo becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage or elsewhere on the Service and may email you at the email address you have provided to us. Depending on where you live and the type of information impacted, you may have a legal right to receive notice of a security breach in writing.
Tallo has procedures in place that are designed to stop threats that may expose Personal Information, restore Services to full functionality, and document and take proactive steps to ensure the incident cannot be repeated. Tallo will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, Tallo will follow its internal procedures, which articulate how to report the problem to internal and external stakeholders. The notification process may include any information that can identify which users may have been impacted, the data that may have been accessed, Tallo’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.
In the unlikely event of an unauthorized disclosure of Data, Tallo has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.
8. How can I access and manage my personal information?
You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information. Note that certain accounts may have limitations regarding the ability to delete information. Even after information is deleted, we may maintain it in backup or archive form unless prohibited by law.
9. What communications will I receive from Tallo and how do I limit them?
Tallo may post notices on the homepage. Tallo may send users information by email, text, phone calls or push notifications. You may choose to stop receiving certain emails from Tallo by using the unsubscribe button that may appear at the bottom of the Tallo email. You may choose to stop receiving certain text messages by replying STOP to a text message you receive from us. You may choose to stop receiving certain phone calls from us by asking to be put on Tallo’s “do not call” list. Asking to be put on Tallo’s “do not call” list does not put you on a state or federal “do not call” list. You can turn off push notifications on your Device. Please consult the owner’s manual or manufacturer for instructions. Tallo will not be able to assist you.
We reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive this information from us, you will need to close your account for that Service.
10. How do I close my account?
If you wish to close your account with one of our Services, please contact us as set forth in “How can I contact Tallo?”, and we will close your account. You typically will receive a response to this request within thirty calendar days of our receiving it.
11. How long does Tallo keep my information?
Unless required by law, Tallo retains Personal Information in order to improve the Services, develop new products and services, internal research purposes, and to improve educational outcomes.
Even after data is deleted from active databases, Tallo may continue to have Personal Information in archive files or similar databases. In addition, Tallo has no obligation to delete aggregated or de-identified information. Tallo may retain and use aggregated and de-identified information for any purpose consistent with laws and regulations.
Even if your account is closed or deleted, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, account recovery or if required by law. All retained data will continue to be subject to the applicable privacy policy for the Service.
12. How will Tallo notify me of changes to this policy?
We will notify you of material changes to the Privacy Policy on our website and/or by email, and may make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services.
Tallo may update this Privacy Policy at any time and any changes will be effective upon posting. Upon any update, the date at the top of this policy will be updated. In the event that there are material changes to the way we treat your Personal Information, you are responsible for regularly reviewing this Privacy Policy and your Tallo account for notice of such modifications. Your continued use of the Services following an update to this Privacy Policy will constitute your acceptance of the updated Privacy Policy.
13. What if I do not live in the U.S.?
The Services are operated in the United States. If you are not located in the United States, you are not authorized to use the Services and are directed not to do so. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you are located, reside and/or are a citizen.
14. What are my additional privacy rights if I’m a resident of certain states?
If you are a California, Colorado, Connecticut, Utah or Virginia resident, or a resident of a state with similar statutory or regulatory requirements as those of California, Colorado, Connecticut, Utah, or Virginia, as a consumer you may have several specific privacy rights that supplement this Privacy Policy. This section describes those rights and applies to the extent required by the laws of those states.
You can request information about the disclosure of your Personal Information for direct/targeted marketing purposes of other entities. You can also tell Tallo not to disclose Personal Information to others for their direct/targeted marketing purposes. You can do so by emailing us at privacy@tallo.com or calling 855-765-7836. You may also opt-out, by clicking the Do Not Sell or Share My Personal Information link.
Residents of those states have certain additional rights related to their Personal Information collected by and on behalf of a business subject to the state’s privacy laws. Much of the information collected by us is collected for the benefit of non-profits and public education institutions. Depending on whether information is collected for Tallo’s business or for the benefit of non-profit and public education institutions, some of what is described below may not be applicable to at least some of your Personal Information that we collect.
Over the past twelve months, we may have collected and disclosed some or all of the following types of Personal Information in connection with providing services to you. The type of information, how it is collected, why it is collected and to whom it is disclosed can vary from person to person depending on the Services the person receives from us and how the person interacts with us.
Identifiers. This information is collected from you and is used to identify users and includes such things as names, email addresses, telephone numbers, usernames, IP addresses or other identifiers.
Audio and Video Data. We may collect audio, video and other electronic information from you.
Customer Records. If you purchase our Services, we collect from you information about what Services you are considering, purchasing or using. This may include your name, signature, education history, and payment information. We collect this information from you in order to provide our Services and for business purposes.
Protected Class Characteristics. We may collect information about protected classification characteristics under federal, state or local laws, such as race, ethnicity, national origin, disability, veteran or military status. We may collect this information from you.
Network Activity. We collect information about your interactions with websites and the internet. We collect this information from you and third parties.
Geolocation Data. We collect information from you about the geographic location from where your device accessed our Services. We collect this information from you and third parties.
Inferences Drawn from Other Personal Information. We may make inferences to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.
Depending on your relationship with us, we may use your Personal Information for one or more of the following purposes: providing educational services, providing support and services you requested, personalizing content and experiences, analyzing and improving our services, content, functionality and the usability of our Services, securing and protecting our assets and rights and preventing misconduct, complying with legal obligations, inviting you to participate in surveys and provide feedback to us, having a better understanding of your needs and interests, contacting you with information that may be of interest to you, improving marketing and promotional efforts and supporting our general business.
We may share your Personal Information with other entities that perform certain functions for us, analytics and service providers, benefits providers, transaction processors, and law enforcement (if necessary). We may also share your Personal Information, including for commercial and/or marketing purposes, with our parent, subsidiaries and affiliates, third-party social media platforms (e.g., if you “comment” on a post), and other carefully selected business partners, or as part of a business transfer. We share your Personal Information with our Tallo Platform Partners, which is an essential feature of the Services.
We may process your information to provide you with direct/targeted advertising (also known as cross-contextual advertising and online behavioral advertising) and offers and promotions that you may be interested in.
As a resident of those states, there are several rights regarding the collection, use, transfer, and processing of your Personal Information. We have the right to reasonably verify your identity, to limit your rights to the extent they adversely affect the rights and freedoms of others and, if your request is excessive, repetitive or unfounded, to require payment from you. If a fee is applicable, we will advise the person making the request before completing the request, explain why a fee applies and provide an estimate. We may have additional rights under law and do not waive them.
Only you, your parent or legal guardian (if you are not yet 18 years of age) or a person registered as may be set forth in your state’s law and that you authorize to act on your behalf may make a request related to your Personal Information. To verify your identity as a resident of one of the states, we may request Personal Information from you to compare against our records. We will only use Personal Information provided in your request to verify your identity and will delete any Personal Information you provide after processing the request. If we believe that your request is fraudulent we may take additional steps as necessary to verify your identity as a resident of the state. We may also request that you sign a declaration under the penalty of perjury. Making a verifiable consumer request does not require you to create an account with us.
If you choose a person registered as may be set forth in the state’s law to act on your behalf to submit your requests, we will require that you provide the agent and that the agent provide us with written permission to allow them to submit your request. We will also require that you verify your identity directly with us.
Our goal is to respond to requests within 45 days. If we need another 45 days, we will advise the person making the request within 45 days after receiving the request.
You have the right to request we inform you of the Personal Information we collected, used, and disclosed about you to third parties over the previous twelve months. If you make such a request, we will provide you with information about the categories of your Personal Information collected, the categories of sources from which your Personal Information is collected, the business purpose for collecting or selling the information, and the categories of third parties to which your Personal Information is shared or sold. If you request it, we will provide you with information about specific pieces of Personal Information collected about you. you may request this information twice in a 12-month period. We will inform you if an exception to your right to this information is applicable.
You have the right to request that we and our service providers delete your Personal Information that we collected from you and have retained. This right is also subject to certain exceptions. We will let you know if an exception applies. These exceptions include where we or a service provider uses the Personal Information to complete a transaction for which the Personal Information was collected, provide goods or services that you requested or reasonably should have anticipated within the context of our relationship with you, use the information internally in a way that is compatible with the purpose for which you originally provided the information, detect or protect against security incidents, or malicious, deceptive, fraudulent, or illegal activity or otherwise comply with law. If we decide not to act on your request, you have the right to appeal our denial of your request. We will provide you with an explanation for such denial and instructions on how to appeal our decision.
You have the right to opt-out of the sale of your Personal Information by a business subject to certain laws and regulations. However, to the extent that third party advertising cookies and related technologies are ultimately determined to be a “sale” we may engage in that activity.
If you would like to request your Personal Information, that your Personal Information be deleted or that your Personal Information not be sold, please send the request to privacy@tallo.com or 855-765-7836. You may also opt-out, by clicking the Do Not Sell or Share My Personal Information” link.
You also have the right not to be discriminated against for exercising your privacy rights under the state privacy statutes. We will not discriminate against you (by, for example, denying goods or services to you or providing a different level of quality of goods or services to you) because you exercised any of these privacy rights.
If you are a Nevada resident, you may notify us to put you on a list of persons who have opted-out of the sale of Personal Information. Our address for such requests is privacy@tallo.com. You may also opt-out, by clicking the Do Not Sell or Share My Personal Information link. Please be aware that we may require you to verify your identity before processing any such request.
15. How can I contact Tallo?
If you have questions or comments about this Privacy Policy, please contact us via email at privacy@tallo.com.
