Effective as of: August 9, 2025
This Privacy Notice is designed to help you understand how People Who Code LLC d/b/a Tummi (“Tummi”, “we”, “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.
We are committed to protecting and respecting your privacy and will use your personal information in accordance with the General Data Protection Regulation (the “GDPR”), the California Consumer Privacy Act of 2018 (the “CCPA”), California Privacy Rights Act (the “CPRA”), and other applicable laws, regulations, and guidelines.
This Privacy Notice applies to personal information processed by us on the Tummi mobile app (“App”) and Tummi website (“Site”). To make this Privacy Notice easier to read, our mobile app and related offerings are collectively called “Services.”
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect. We encourage you to regularly review this Privacy Notice to check for any changes.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
We may collect the following personal information that you provide to us:
We may collect personal information automatically when you use our Services:
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfill our contract with you and provide you with our Services, such as:
We use your information for various administrative purposes, such as:
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in Section 16 (“Contact us”) below with the subject line “Do Not Share My Personal Information for Cross-Context Behavioral Advertising.”
We also use your information for other purposes as requested by you or as permitted by applicable law:
We disclose your information to third parties for a variety of business and legal purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
The categories of third parties with whom we may share your information are described below:
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be transferred as part of such a transaction, as permitted by law and/or contract.
The privacy choices you may have about your personal information are determined by applicable law and are described below:
In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth in Section 16 (“Contact us”) below. We will process such requests in accordance with applicable laws.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
Your data may be transferred outside the European Economic Area (EEA) to our group companies or third-party service providers which Tummi engages in other regions (including without limitation the USA), which may have data protection laws that are different from the laws where you live. We ensure that your information is protected by using certified services, signing agreements on protection of personal data, and taking technical measures to secure data.
We may store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected. Personal information will be stored on secure servers during the period you have a valid and active account unless you delete such data manually using the App functionality or via a “Remove my data” button. You may also request us to delete your personal data by contacting us at team@tummi.app.
This Supplemental Notice for California Residents applies to our processing of personal information subject to the CCPA and CPRA. California residents have the right to know what categories of personal information we have collected about them and whether such information was disclosed for a business purpose in the preceding twelve (12) months.
| Category of Personal Information Collected by Tummi | Categories of Third Parties Personal Information is Disclosed to for a Business Purpose |
|---|---|
| Identifiers | Service providers, Other users or third parties you share with, Advertising partners |
| Personal information categories listed in Cal. Civ. Code § 1798.80(e) | Service providers, Other users or third parties you share with |
| Commercial information | Service providers, Other users or third parties you share with |
| Internet or other electronic network activity | Service providers, Other users or third parties you share with, Advertising partners |
| Geolocation data | Service providers, Other users or third parties you share with, Advertising partners |
| Inferences drawn from other personal information | Service providers, Other users or third parties you share with, Advertising partners |
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information. You can exercise this right by contacting us at team@tummi.app with the subject line “Nevada Do Not Sell Request.”
Under the Virginia Consumer Data Protection Act, you may request us to exercise your right to access, correct, or delete your personal data, or to opt out of the processing of personal data for targeted advertising or profiling.
The Services are not directed to children under 16, and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, please contact us at team@tummi.app.
The Services may contain links to other websites/applications. We encourage our users to read the privacy policies of each website and application with which they interact.
If you reside in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority. The full list of authorities is available at: EU Data Protection Authorities.
People Who Code LLC is the controller of your personal information. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights, please contact us at:
People Who Code LLC
447 Broadway, 10th Floor
New York, NY 10013, United States
Email: team@tummi.app