Effective Date: Aug 01, 2022
You can access, participate in, and interact with our Platform in many ways, including from a computer or mobile device. This Policy applies regardless of how you access, participate in, or interact with our Platform. Depending on how you access, participate in, or interact with our Platform, there may be some cases where we need to provide you with additional information about how we collect, use, protect or disclose your Personal Data and/or what options you have regarding our collection, use or disclosure of your Personal Data. We may provide this additional information through notices on our Platform or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Policy.
Please read this Policy carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Policy, please do not access, participate in, interact with or use our Platform, provide us with your Personal Data or authorize any third party to make your Personal Data available to us. By accessing, participating in, interacting with or using our Platform, you acknowledge that you understand that we may use your Personal Data as described in this Policy. Please note, as described in this Policy, we may receive your Personal Data from third parties that have not expressly told you that they will provide your Personal Data to us. If you have any questions about how we collect, use, protect or disclose your Personal Data in connection with our Platform, please contact us by email at [email protected].
PERSONAL DATA AND OTHER INFORMATION WE COLLECT
Our primary goals in collecting Personal Data are to facilitate purchases, conduct our business operations, and improve our Platform.
When we refer to “Personal Data” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
Categories of Personal Data We Collect
Depending on how you access, use or otherwise interact with our Platform, we, or third parties acting on our behalf, may collect the following categories of Personal Data about you:
- Identifiers and contact information, such as your real name, alias, email address, telephone number, postal address, physical address, social security number, driver’s license number, unique personal identifier, date of birth, online identifier, IP address and other similar information;
- Internet and other similar network activity information, such as your browsing history, search history, interactions with our Platform and online advertisements and other similar information;
- Financial information, such as bank account number, and other similar information;
- Payment information, such as credit card information and similar information;
- Transactional information, such as information about purchases you have made or participated in through our Platform and other similar information;
- Communication information, such as information contained in voicemails, chats, emails, and other similar information;
- Location information, such as where you live, where you are located and other similar information; and
- Other information you provide to us.
Other Information We Collect
Depending on how you access, interact with or use our Platform, the Usage Data that we, or third parties acting on our behalf, may collect may include:
- Device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a device used to access, use, or interact with our Platform;
- Information about online interactions with our Platform, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with a device used to access, use, or interact with our Platform;
- Information about internet and network activity, such as websites visited, search engine results and similar information associated with a device that accesses, interacts with or uses our Platform;
- Other information automatically collected by cookies and other technologies on our Platform; and
- Any other information that a browser or device automatically sends whenever connected to a website or an online application.
How We Collect Personal Data
A large portion of the Personal Data we, or third parties acting on our behalf, collect is collected directly from you. In some cases, we may collect Personal Data from third parties in the ways described in this Policy.
Directly from You
When you access, use or otherwise interact with our Platform, or otherwise engage with us in connection with our Platform, such as requesting more information about us, we may ask you to provide certain Personal Data.
From Third Parties
We, or third parties acting on our behalf, may collect Personal Data about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Data from these Third Party Sources can occur in a variety of ways, including, without limitation:
- When you access, use or interact with our Platform through Third Party Sites, associate your access to, use of, or interactions with our Platform with Third Party Sites or share our content via Third Party Sites, you acknowledge that you are authorizing us to collect, share, store and use any Personal Data we receive from those Third Party Sites about you. In some cases, you may be able to revoke our access to your Personal Data and other content and information we receive from Third Party Sites by changing the appropriate settings for your account with the applicable Third Party Site.
- When you interact with us on other platforms, including, but not limited to, social media sites such as Facebook and Twitter (the “Third Party Sites”) or share our content via the Third Party Sites, we may receive information about you from those sites. As a result, we, and third parties acting on our behalf, may share, store, use, and otherwise process any Personal Data we receive from or in connection with those Third Party Sites.
- Third parties whose content is linked to on our Platform. Any links to other websites, applications or other third party content on our Platform, are not an endorsement, authorization, or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications, or content you access.
- We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with the operation of our Platform (“Service Providers”). Service Providers may include, without limitation, hosting providers and payment providers.
Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more Third Party Sources.
How We Collect Usage Data
We, and third parties acting on our behalf, collect Usage Data in a variety of ways. Some Usage Data, such as the IP address of a device attempting to access, use or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Data, such as information about which features of our Platform are popular, help us to improve and advertise our Platform. This section describes primary ways Usage Data is collected in connection with our Platform:
- The systems we use to make our Platform available to you. When you access, use, or interact with our Platform, these systems automatically record certain information that your browser or device sends whenever you visit a Platform or utilize an online application as well as information about how long your device is connected to our Platform and the activities that device engages in while connected.
- Other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Platform, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
- Third party analytic tools, such as:
- Meta Pixel. We may use Meta Pixel, a cookie placed by Meta, that enables us to measure the effectiveness of advertising campaigns served on Meta sites. The information collected by that cookie will be transmitted directly to and stored by Meta. For more information about Meta’s privacy practices, please refer to https://www.facebook.com/about/privacy. To opt-out, please visit https://www.facebook.com/help/247395082112892.
Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
Third Party Information Collection
Based on the nature of our Platform, third parties may collect information from or about you through or in connection with our Platform. In addition to other information provided in this Policy, third parties may collect information about you through or in connection with our Platform including:
- Third parties whose content is linked to on our Platform.
We encourage you to read the privacy policies or statements applicable to any third party Platforms, applications, or content you access.
How do we use Personal Data?
We use Personal Data for various purposes to operate and improve our Platform and to conduct our business operations. The primary purposes for which we use Personal Data are:
- Operational Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Platform, which may include, without limitation, presenting content to you and other users to fulfill our business purposes and to facilitate your use of features you elect to use on our Platform, such as engaging in transactions with other users through our Platform; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) notifying you about issues with, or changes to, our policies, terms, and agreements; (5) sending you emails to provide you with alerts and updates about your engagement with our Platform; (6) providing customer service; (7) conducting statistical or demographic analysis; (8) complying with legal and regulatory requirements; (9) customizing your experience with our Platform; (10) protecting and defending Towlos against legal actions or claims; (11) preventing fraud; (12) satisfying contractual obligations; (13) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (14) any purpose for which you authorize or instruct us to use your Personal Data; and (15) other business purposes permitted under applicable law.
- Marketing Purposes – we may, either on our own or jointly with our third party marketing partners (“Marketing Partners”), use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Policy) and use such linked information for Marketing Purposes. Our Marketing Purposes may include using Personal Data collected through cookies and other tracking technologies to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and our Marketing Partners on and off our Platform. If you do not want us to use your Personal Data for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Data” section below.
We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Platform for materially different, unrelated, or incompatible purposes without providing you notice.
Please note, we may use and disclose aggregated, anonymized, or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Policy.
SHARING PERSONAL DATA WITH THIRD PARTIES
To operate our Platform and provide our Platform, we may share certain Personal Data that we, or third parties acting on our behalf, have collected, with certain third parties. The third parties that we may share Personal Data with include:
- Our Operational Service Providers in connection with the services they provide to us, including, without limitation, marketing, data hosting, payment processing and fraud protection and prevention. We require these Operational Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which we provided it to them.
- Our Marketing Partners to facilitate the delivery of targeted ads, promotions and offers to you, on our behalf, on and off our Platform.
- Depending on how you interact with our Platform, we may provide Personal Data about you, including, without limitation, your first and last name, profile information including picture, and certain location information, to other users for purposes related to the operation of our Platform, including facilitating transactions you engage in with other users through our Platform.
- Government and law enforcement individuals or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available or to comply with applicable laws.
- Any third party to whom you consent and/or instruct us to provide your Personal Data.
PROTECTING YOUR PERSONAL DATA
We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the use of email and the internet. Your Personal Data and other information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us. We cannot guarantee the security of any information, including your Personal Data, that you disclose online, and you do so at your own risk.
We do not direct or target any piece of our Platform to children under the age of 13. If we learn that we have collected the Personal Data of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Data to us, please contact us at [email protected]. We will make reasonable efforts to remove such information from our databases.
MANAGING YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data.
- To update or correct any Personal Data you have provided us, update your preferences, or otherwise contact us about our use of your Personal Data, please contact us at [email protected].
- You can also request that we delete any of your Personal Data that we have collected from you in connection with your use of the Website by emailing us at [email protected]. Please note, we will ask you to provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative. Additionally, there are certain circumstances in which we may be unable to delete your personal information. For example, we cannot delete information that is still necessary to complete the transaction for which you provided the Personal Data or where we must retain Personal Data to comply with a legal obligation.
- For marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Platform.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your personal information to third parties for direct marketing purposes: (1) the categories of personal information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to [email protected] with the subject line “CA Privacy Rights Request.”
CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the services we provide are continually evolving, this Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Platform after any changes to this Policy become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Policy.
We welcome your questions, comments, and concerns about privacy. Please email us at [email protected] with any questions or feedback you have pertaining to our privacy practices.