Privacy Policy
Effective Date: June 22, 2026
- What we collect: Your first name and email address when you sign up or interact with our site. Plus standard technical data (cookies, IP address, browser info) — same as most websites.
- Why we collect it: To tell you when Tulle is ready, send you product updates, and understand how visitors use our site so we can make it better.
- Who we share it with: A small set of trusted service providers (email, analytics, advertising platforms) — listed below. We don't sell your data.
- Your choices: You can ask us to access, correct, or delete your data at any time. Just email legal@smart-it.io.
1. Who we are
Tulle is operated by Smart IT US Inc., a company incorporated in Wyoming, United States.
Our mailing address is:
30 N Gould St Ste R, Sheridan, Wyoming 82801, USA
For any privacy questions, you can always reach us at legal@smart-it.io.
In this Privacy Policy, "we," "us," and "our" refer to Smart IT US Inc. doing business as Tulle. "You" means anyone who visits tulle.one or interacts with our services.
2. What we collect
We collect two kinds of information:
Information you give us
When you sign up or fill out a form on our site, we ask for:
- Your first name
- Your email address
That's it. We don't ask for your last name, phone number, mailing address, payment card details, or any other personal information on this site.
Information collected automatically
When you visit our site, we automatically collect:
- Device and browser information: IP address, browser type and version, operating system, screen size, language
- Usage information: Pages you viewed, links you clicked, time spent on each page, referring website, scroll depth
- Cookie and tracker data: See our Cookie Policy for the full list
We use this technical data to understand how our site performs, to detect fraud and abuse, and to improve the experience.
3. How we use your information
We use your information to:
- Communicate with you about Tulle — product updates, launch news, and (if you opted in) marketing messages
- Run our site — keep it secure, fix bugs, prevent abuse
- Understand our audience — measure how people find us and what they're interested in, in aggregate
- Run experiments — we may test different versions of pages, copy, or features (A/B testing) to learn what works best. This may involve showing different content to different visitors. We never use sensitive data for testing
- Show you relevant ads — on platforms like Meta (Facebook, Instagram) and Google. See section 6 on advertising
We do not use your information for automated decision-making that has legal or similarly significant effects on you.
4. Legal basis (for visitors from the EU/UK)
If you're in the EU or UK, we rely on the following legal bases under GDPR and the UK Data Protection Act:
- Your consent — for marketing emails, non-essential cookies, and ad targeting
- Our legitimate interests — for site analytics, security, fraud prevention, and improving our service
- Contractual necessity — to deliver something you've explicitly signed up for
You can withdraw consent at any time without affecting the lawfulness of processing we did beforehand.
5. Payments
Tulle is in pre-launch testing. We do not collect payment information or process payments on tulle.one — there is no checkout, and we never ask for card details.
On this site we collect your first name and email address so we can let you know when Tulle is ready.
If you ever see a charge claiming to be from us related to this site, it isn't us — please contact legal@smart-it.io right away.
6. Who we share it with
We share your information with a small set of trusted service providers who help us run our business. Each one is bound by contract to use your data only for the purposes we specify.
| Provider | What they receive | What for |
|---|---|---|
| HubSpot | Name, email, marketing engagement data | Email communications and CRM |
| Google (Analytics, Ads, Search Console, Tag Manager) | Usage data, IP, device info | Site analytics, search performance, advertising |
| Meta (Facebook, Instagram) | Usage data, IP, device info (via Meta Pixel) | Advertising and audience analysis |
We may also share your information:
- If required by law — for example, in response to a subpoena, court order, or government request
- To protect our rights and safety — to prevent fraud, abuse, or harm to us, our users, or the public
- In connection with a business transfer — if we're acquired, merge with another company, or sell assets, your data may transfer with the business (you'll be notified)
We do not sell your personal information to third parties for money.
7. How long we keep it
We keep your information only as long as we need it:
- Email and name: Until you unsubscribe or ask us to delete it, or up to 3 years after your last interaction with us, whichever comes first
- Technical and usage data: Up to 26 months (standard analytics retention)
If you ask us to delete your data, we'll do so within 30 days unless we have a legal obligation to keep it longer.
8. Your rights
You have the right to:
- Access the personal data we hold about you
- Correct any data that's inaccurate or incomplete
- Delete your data ("right to be forgotten")
- Object to certain uses (like marketing or analytics)
- Restrict how we use your data
- Portability — receive your data in a machine-readable format
- Withdraw consent at any time
- Lodge a complaint with your local data protection authority
To exercise any of these rights, just email legal@smart-it.io. We'll respond within 30 days. We may need to verify your identity first to protect against fraud.
Depending on where you live, you may have additional rights — see our regional addenda (GDPR, UK DPA, CCPA) for details.
9. Cookies and tracking
We use cookies and similar technologies on tulle.one. The full list — what each cookie does, who sets it, and how long it lasts — is in our Cookie Policy.
You can manage your cookie preferences anytime via the cookie banner on our site, or through your browser settings.
10. Adults only (18+)
Tulle is intended for adults 18 years of age or older. We don't knowingly collect information from anyone under 18. By using the site, you confirm you are 18 or older.
If you believe someone under 18 has given us their information, please email legal@smart-it.io and we'll delete it.
11. International transfers
We're based in the United States (Wyoming). When you give us your data, it is transferred to and processed in the United States.
Most of our key service providers (Google, Meta, HubSpot) are based in the United States and process data there. Your data may therefore be processed in multiple jurisdictions.
For transfers involving EU or UK residents' data, we rely on appropriate safeguards under EU GDPR and UK GDPR — including Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), or each provider's equivalent safeguards. Copies are available on request at legal@smart-it.io.
12. Security
We protect your information with industry-standard safeguards — encryption in transit (HTTPS everywhere), encryption at rest where applicable, limited employee access, and regular security reviews of our providers.
No system is 100% secure, but we work to keep yours as safe as reasonably possible.
13. Changes to this policy
We may update this Privacy Policy from time to time. When we do, we'll change the "Effective Date" at the top and, for material changes, notify you by email (if we have your email) or via a notice on the site.
The current version is always available at tulle.one/privacy.
14. Contact us
For any privacy questions, requests, or concerns:
Email: legal@smart-it.io
Mail: Smart IT US Inc., 30 N Gould St Ste R, Sheridan, Wyoming 82801, USA
If you're in one of the regions below, additional rights and protections apply.
- California residents — see the CCPA Addendum
- EU residents — see the GDPR Addendum
- UK residents — see the UK Data Protection Addendum
California Privacy Rights (CCPA)
If you live in California, the California Consumer Privacy Act (CCPA), as amended by the CPRA, gives you additional rights about your personal information. Here's what they are and how to use them.
Rights you have
As a California resident, you can:
- Know what categories of personal information we've collected about you, the sources we got it from, what we use it for, and who we share it with
- Access the specific pieces of personal information we hold about you (subject to verification)
- Delete personal information we've collected from you (with certain exceptions, such as legal obligations)
- Correct inaccurate personal information
- Opt out of "sale" or "sharing" of your personal information (more below)
- Limit use of sensitive personal information to what's necessary
- Non-discrimination — we can't deny service, charge you more, or give you a worse experience for using these rights
You can also designate an authorized agent to make a request on your behalf.
Categories of personal information we collect
In the last 12 months, we have collected the following categories of personal information from California residents:
| Category | Examples | Source | Purpose |
|---|---|---|---|
| Identifiers | First name, email address, IP address, device ID | Directly from you, via cookies and analytics | Communication, marketing, analytics |
| Internet activity | Pages viewed, links clicked, time on site | Via cookies and analytics | Site improvement, advertising |
| Inferences | Interest in personal wardrobe styling based on your behavior | Derived from your activity | Marketing, audience research |
We do not collect government identifiers (SSN, driver's license), biometric data, precise geolocation, or financial account numbers on tulle.one.
Do we "sell" or "share" your information?
Under CCPA, "sale" and "sharing" include sending personal information to third parties for advertising purposes — even if no money changes hands.
Yes — we share your information for advertising purposes, primarily by using cookies from Meta and Google to show you relevant ads and measure their performance. This counts as "sharing" under CCPA.
We do not sell your personal information for money to data brokers.
How to exercise your rights
Opt out of sharing for advertising: Click "Do Not Sell or Share My Personal Information" in the site footer, or use "Cookie settings" to reject advertising cookies. We also honor the Global Privacy Control (GPC): if your browser sends a GPC signal, we treat it as a valid request to opt out of the "sale"/"sharing" of your personal information for that browser.
Any other request (access, delete, correct, limit, etc.): Email legal@smart-it.io with the request. Include enough information for us to verify it's you (typically the email address you used to sign up). We'll respond within 45 days. If we need more time, we'll let you know.
Authorized agents: If you're submitting on someone else's behalf, include a signed permission letter or power of attorney.
Sensitive personal information
We do not collect sensitive personal information as defined by CCPA via the standard tulle.one flow.
Notice at collection
This Addendum, combined with this Privacy Policy, serves as the notice at collection required by CCPA. We provide it before or at the point we collect your information.
GDPR Notice (European Union)
If you're in the European Economic Area (EEA), the General Data Protection Regulation (GDPR) gives you specific rights about your personal data.
Who is the controller?
Smart IT US Inc. is the data controller for personal data collected via tulle.one.
You can contact us at legal@smart-it.io or Smart IT US Inc., 30 N Gould St Ste R, Sheridan, Wyoming 82801, USA.
We do not currently target Tulle to individuals in the EEA. If our activities change such that an EU representative under Article 27 is required, we will update this notice.
Legal bases for processing
We process your data on one of the following legal bases:
| Processing | Legal basis |
|---|---|
| Sending you marketing emails you signed up for | Consent (Article 6(1)(a)) |
| Setting non-essential cookies (analytics, advertising) | Consent (Article 6(1)(a)) — collected via cookie banner |
| Running our site, security, fraud prevention | Legitimate interests (Article 6(1)(f)) |
| Analytics in aggregate | Legitimate interests (Article 6(1)(f)) |
| Responding to legal requests | Legal obligation (Article 6(1)(c)) |
You can withdraw consent at any time without affecting the lawfulness of processing done before.
Your rights under GDPR
You have the right to:
- Access your data (Article 15)
- Rectify inaccurate data (Article 16)
- Erase your data — "right to be forgotten" (Article 17)
- Restrict processing (Article 18)
- Portability — receive your data in a portable format (Article 20)
- Object to processing based on legitimate interests, including profiling (Article 21)
- Object to direct marketing at any time (Article 21(2))
- Not be subject to fully automated decisions with legal or similarly significant effects (Article 22) — we don't do this
To exercise any right, email legal@smart-it.io. We respond within 30 days.
Right to complain
You can lodge a complaint with your local Data Protection Authority. Find yours: edpb.europa.eu/about-edpb/about-edpb/members_en
International transfers
We (the controller) are based in the United States (Wyoming). When you give us your data, it is transferred to and processed in the United States, where most of our service providers are also based.
For transfers from the EEA to the United States, we rely on the European Commission's Standard Contractual Clauses (SCCs) with our service providers, plus additional safeguards (encryption, access controls). Copies are available on request.
Special categories of data
We do not intentionally collect special categories of personal data (such as health, biometric, or political data) via the standard tulle.one flow.
UK Data Protection Notice
If you're in the United Kingdom, your rights are governed by the UK Data Protection Act 2018 and the UK GDPR — these are substantially the same as EU GDPR. The GDPR summary above applies, with the following UK-specific points:
- Supervisory authority: The Information Commissioner's Office (ICO). Complaints: ico.org.uk/make-a-complaint
- International transfers from UK: We rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs.
- Contact us the same way: legal@smart-it.io
We do not currently target Tulle to individuals in the UK. If our activities change such that a UK representative under Article 27 is required, we will update this notice.
This policy is written in plain English. If anything is unclear, please ask us at legal@smart-it.io — we'll explain.