OUR COMMITMENT TO YOU

At Tempest, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and value, so that you can fully trust them and focus on establishing meaningful business relationships, events, and experiences, and making informed business decisions and analyses.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in a manner that is complete, yet easy to navigate and understand.

We work hard to keep your information secure. We have processes dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

PRIVACY POLICY

Welcome to Tempest’s privacy policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used, and your choices regarding your information.

OVERVIEW - THIS NOTICE AND WHO WE ARE

Summary: This Notice (also, this “Privacy Policy”) explains how we may process your Personal Information (also, “Personal Data”). This Notice may be amended or updated from time to time, so please check it regularly for updates.

This Notice is issued by the Tempest, Inc (together, “Tempest”, “we”, “us” and “our”), and applies to anyone who is using or has access to our Services. Tempest is a digital solutions provider who helps innovative Destination Organizations grow and positively impact their communities through Web, CRM and Digital Marketing solutions.  Our contact details are provided in the “Contact Information” section below.

Our Services include but are not limited to:

• Our website(s);
  
• Our Digital Marketing solutions
  
• Our software applications including iDSS, and the Sports Tourism Index
  
• Our newsletter or mailing lists;
  
• Tourism Academy and other events
  
• Other appropriate communication and interactions over the course of your relationship with us.
  

For simplicity, we refer to all of these as our “Services” in this Privacy Policy.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates, if any. The term “User(s)” refers to any individuals or entities using, visiting, or otherwise interacting with our Services, including but not limited to our clients, partners, customers, members, subscribers, consumers, viewers, and other individuals or entities with access to our Services.

By continuing to use our Services, you agree to the terms of this Privacy Policy. This Privacy Policy applies beginning September 1, 2023.

DATA WE COLLECT

We may collect Personal Information when you:

• Communicate with us by email, phone, or otherwise;
  
• Fill in forms or questionnaires;
  
• Register for or use our Services;
  
• Complete a survey or provide us with feedback;
  
• Subscribe to a Service or request certain features (e.g., newsletters, mailing lists, updates, and other services);
  
• Use certain features that require your information to function and optimize your experience (e.g. searching and otherwise using iDSS or the Sports Tourism Index).
  
• Report a problem with our website or Services; or
  
• Post, update, report, or otherwise provide content or information, including business information or venue specifications and your information, to or on any of our Services;
  
• Register for or attend a Tempest event;
  
• Register for, attend, or provide an event affiliated with, facilitated by, connected or otherwise related to Tempest and our Services.
  

We may collect the following types of Personal Information:

1) Information you provide directly to us:

• Your name, email address, postal address, telephone number, your job title or work position, and other information you voluntarily provide over the ordinary course of your relationship with us;
  
• Your company’s name, address, telephone number, contact information, structure, budget, area, facility and event specifications, and other relevant business, proprietary, financial, circumstantial, historical, venue or region related information used to provide our Services;
  
• Financial information, such as credit card information and transaction details, for paid Tempest resources or online accounts;
  
• Images and videos of you taken at our events;
  
• Other information that you provide or send to us during the ordinary course of our relationship (e.g., your User account information, history, and preferences);
  
• Professional, employment, or education information, such as copies of your resume or CV and any other information required to verify your qualifications, for recruitment purposes or for our Services;
  
• Any other Personal Information, business information, feedback or other insights you voluntarily provide, and the content of our communications.
  

2) Data we derive through your interactions with us.

Like many website operators and service providers, we collect information that your browser sends whenever you visit our website or use any features or resources available through our Services.This may include:

• General User information about your computer and your visits to our website (including your IP address, location, browser, operating system, referral source, length of visit and the pages you visit). This information can be facilitated by cookies (see more below).
  

3) Information We Collect from Third Parties.

In order to provide our Services, we may also collect information or Personal Data that is lawfully made publicly available or available to us by public record, third party aggregators, your company, government, state, and county record, court record, or other similar records or sources.  The information collected may include:

• Your contact information, such as name, address, location, email, and telephone number;
  
• Commercial information, such as your company’s name, address, telephone number, contact information, structure, budget, area, facility and event specifications, and other relevant business, proprietary, financial, circumstantial, historical, venue or region related information used to provide our Services.
  

We may also collect Personal Data from social media (e.g., we may collect information from your social media profile(s), if you make a public post about us) or from third parties who provide it to us (e.g. content and advertising information).

We do not collect special categories of data including race or ethnic origin, political opinions, religious or philosophical beliefs, trade secrets, genetic or biometric data, health or mortality, or sexual orientation.


Summary: We only use your Personal Information for our legitimate business purposes as set out in this privacy Notice. The main reason we use your information is to deliver and improve our Services.

We may process your Personal Data for the following purposes, subject to applicable law:

• To provide our Services and administer your account. This includes:
  
• providing Tempest Services to you and to other Users of Tempest;
  
• operating and managing Tempest and our Services;
  
• providing you with User support and responding to your requests;
  
• completing your transactions;
  
• communicating with you about our Services, including order management and billing;
  
• providing you with other services that you have requested;
  
• providing you with information, content, or promotional items at your request;
  
• notifying you of changes to Tempest or any of our Services
  
• To communicate. This includes:
  
• communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law;
  
• sending you other information about our Services and our relationship;
  
• maintaining and updating your contact information where appropriate;
  
• and obtaining your opt-in consent where required.
  
• To administer our events, our websites and our business.
  
• To personalize our Services to your requests and preferences.
  
• To understand and analyze how you (and others) are using our Services and to help us improve and develop our Services, including conducting internal analyses.
  
• To keep our events and systems secure and prevent fraud.
  
• To contact you about new Tempest Services, offers, events or news where it is legitimate for us to do so.
  
• To otherwise manage our relationship with you or comply with our contractual obligations.
  
• To manage our communications systems; operation of IT security systems; and IT security audits.
  
• To engage with you for the purposes of obtaining your views on our services by survey or otherwise.
  
• To conduct market research, project planning and analysis, audits, and troubleshoot problems;
  
• To detect, investigate, and prevent breaches of policy, and criminal offences, in accordance with applicable law.
  
• To establish, exercise, and defend legal rights.
  
• To comply with our legal and regulatory obligations under applicable law.
  

We may create Personal Data about you, such as records of your interactions with us and details of your purchase history.

We will limit the processing of Personal Data to the activities and purposes stated in this Privacy Policy.

COOKIES POLICY

We use cookies when you browse Tempest websites and online Services. Cookies are small files that allow a website to recognise and track Users. Our cookies do not store Personal Information such as your name, address or registration data; they simply hold the unique ID that, once you are signed in, is associated with this information.

You can set your browser to reject cookies (see the ‘Help’ menu of your browser to find out how to do this), but please bear in mind that if you do this, certain User-generated features of our websites and Services cannot be provided to you.


Summary: We may process (or, “use”) your Personal Data where: you have given your prior, express consent; the processing is necessary for a contract between you and us; the processing is required by applicable law; the processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the processing.

In processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases:

Consent: We may process your Personal Data where we have obtained your prior, express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);

Contractual necessity: We may process your Personal Data where the processing is necessary in connection with any contract that you may enter into with us;

Compliance with applicable law: We may process your Personal Data where the processing is required by applicable law;

Vital interests: We may process your Personal Data where the processing is necessary to protect the vital interests of any individual; or

Legitimate interests: We may process your Personal Data where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business or providing our Services, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.


Summary: We work collaboratively within Tempest and with others as part of operating and providing our Services to you and our Users alike. In accordance with applicable law, we may disclose your Personal Data or other information as described below.

To service providers and partners who help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, User care, marketing, advertising, accounting, event planning and operations, travel, legal affairs, payment processing and security operations, subject to appropriate confidentiality and contractual protections.

To our Users. In order to operate and provide our Services to you and our Users alike, where we have a legal basis we may share certain limited Personal Information with our Users, such as basic contact information or information gathered from third party data repositories as part of our contractual Services. We may also reveal other information such as publicly available information, anonymized or aggregated data, and other business information (including your company’s name, address, telephone number, contact information, structure, budget, area, facility and event specifications, and other relevant business, proprietary, financial, circumstantial, historical, venue or region related information) used to provide our Services. For more details, please see the “DATA WE COLLECT” section above in this Notice under subheading #3, “Information We Collect from Third Parties.”

When required by law. We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights. We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our Users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request. We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.


We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.


We take every reasonable step to ensure that:

• your Personal Data that we process are accurate and, where necessary, kept up to date, and;
  
• if any of your Personal Data that we process are inaccurate, that they are erased or rectified without unreasonable delay.
  

From time to time we may ask you to confirm the accuracy of your Personal Data.


We take every reasonable step to ensure that the Personal Data we process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.


You may have the right to access and/or request a copy of your Personal Data which we hold about you. Please contact us at the information listed below and we will take reasonable steps to accommodate your request, subject to applicable law.


Summary: You may have a number of rights regarding your Personal Information depending on applicable law - most notably, the California Consumer Privacy Act (CCPA) for consumers in California, and the General Data Protection Legislation (GDPR) for individuals in the EEA and UK.  We may require proof of your identity before we can give effect to these rights.


If you are a California consumer, you have the following rights under the California Consumer Privacy Act of 2018 (CCPA):

• The right to know what Personal Information is being collected about you.
  
• The right to know whether your Personal Information is sold or disclosed and to whom.
  
• The right to say no to the sale of Personal Information.
  
• The right to access your Personal Information.
  
• The right, in certain circumstances, to delete the information you have provided to us.
  
• The right to equal service and price, even if you exercise your privacy rights.
  

Request for Information and Deletion (CCPA). California consumers have the right to request, up to twice in a 12-month period, that a business that collects Personal Information about the consumer disclose to the consumer the information listed below for the preceding 12 months. TEMPEST retains the right to request verification of your identity for all requests for information.

1. The categories of Personal Information it has collected about that consumer.
   
2. The categories of sources from which the Personal Information is collected.
   
3. The business or commercial purpose for collecting or selling Personal Information.
   
4. The categories of third parties with whom the business shares Personal Information.
   
5. The categories of Personal Information that the business sold about the consumer and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
   
6. The categories of Personal Information that the business disclosed about the consumer for a business purpose.
   
7. The specific pieces of Personal Information it has collected about that consumer.
   

Do Not Sell My Personal Information (CCPA). California consumers have the right to opt out of the sale of the consumer’s Personal Information.  If we received your records from a third-party data repository, we may also direct you to the third party in order to make your request.
Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes.

To make any request mentioned in this Notice, please contact us using the contact details provided in the “Contact Information” section below.


If you are from the European Economic Area or United Kingdom, under the General Data Protection Legislation (GDPR) you have the right, under certain circumstances, to:

• Access your Personal Information;
  
• Correct inaccurate Personal Information;
  
• Request erasure of your Personal Information without undue delay;
  
• Request the restricted processing of your Personal Information;
  
• Request portability of the Personal Information that you have given us;
  
• Object to the processing of your Personal Information (however, please note that we may be unable to provide you with the full benefit of Tempest and our Services if you do not provide us with your Personal Data).
  
• Withdraw your consent, where we process your relevant Personal Data on the basis of your consent (as opposed to another legal basis provided in this Notice).  Such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your Personal Data in reliance upon any other available legal bases.
  

If you are from the European Economic Area, you also have the right to lodge a complaint with a supervisory authority, under certain circumstances.

To make any request mentioned in this Notice, please contact us using the contact details provided in the “Contact Information” section below.

Applicable law (and therefore, your rights) may not apply to:

1. Certain Personal Information, including “publicly available” information lawfully made available from federal, state, county, court, or local government records, and “anonymous” data that has been stripped of all identifying information.
   
2. Other information such as general business information, or data about a company or legal entity, as long as this information has not been linked to an individual natural person.
   

We take every reasonable step to ensure that your Personal Data are only processed for as long as is necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows.

We will retain your Personal Data in a form that permits identification only for as long as:

1. we maintain an ongoing relationship with you (i.e., for the duration for which you are a User of Tempest’s Services); or
   
2. your Personal Data are necessary in connection with the lawful purposes set out in this Notice for which we have a valid legal basis (e.g., where we have a legal obligation to, or legitimate interest in, the retention of your Personal Data).
   

Once the time period has concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
  
• anonymize the relevant Personal Data.
  

Summary: We may process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.

We may process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide Services to you, we may send information to you regarding our Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by managing your email preferences within TEMPEST, or by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any Services you have requested.


The Services are not directed at individuals under the age of 16. We do not knowingly collect Personal Information from children under 16. If you become aware that a child has provided us with Personal Information, please contact us using the contact details provided in the “Contact Information” section below. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information.


Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.


We may change our Privacy Policy at any time. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.


If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the processing of Personal Data carried out by us, or on our behalf, please contact:

Tempest, Inc
30, S 15th St Suite 1001
Philadelphia, PA 19102
[email protected]