1. The personal Information We Collect.
- Information You Provide to Us Voluntarily. We receive and store any information you knowingly provide to us. For example, when you sign up for a Service account we may collect Personal Information such as your name, email address, phone number, physical address, credit/payment card (“Card”) numbers and expiration dates, Card security codes, your birthday, personal preferences, etc. Certain information may be required to register with us or to take advantage of some of our features. If you do not provide us with such information, your access to or use of the Service may be limited.
- Your Location. We provide a mobile app and a browser-based web application that involves location- based services. To provide such location-based services through the mobile application, we use tracking technologies to collect, use, and share precise location data, including the real-time geographic location of your mobile device, which is used for optimized routing, scheduling and communications. You can control your location information either from your TownConnect account settings or from your mobile device settings.
2. How We Use Personal Information. TownConnect uses your Personal Information to pursue legitimate business interests and to fulfill its contractual obligations, including, as follows:
- To operate and maintain the Service (such as, for the purposes of fixing malfunctions, testing our security systems, etc.).
- To provide you with the features, functions and benefits of the Service.
- To enhance, improve and further develop the Service (such as, creating new features or functions, refining the user experience, increasing Service technical performance, etc.).
- We will use your contact information to provide you with notices related to your use of the Service.
- We may use your contact information (such as, your email address) to provide you with promotional and marketing emails. You can opt-out of receiving certain types of promotional and marketing emails – but in such case you may not receive the full benefit of the Service.
- To help personalize the Service experience for you (such as, remembering your information so you will not have to enter it each time you use the Service).
- And for the other purposes referenced in the “Who TownConnect Shares Your Personal Information With” section below (such as, for the purposes of legal compliance).
3. Who TownConnect Shares Your Personal Information With. We neither rent, sell nor share your Personal Information in personally identifiable form with anyone. However, we may share your Personal Information with third parties as described in this section.
- With your Consent. We may share your Personal Information with third parties with your consent.
- Agents We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing service to charge your Card. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us or for any secondary purpose.
- Profile Information and Public and Quasi-Public Submissions. The Service may allow you to interact with other people who work for your organization – and share content with them. In addition, certain user profile information, including your name and job position, may be displayed to other such users to facilitate user interaction within the Service. Please remember that any content you upload to your intra-organization user profile, along with any Personal Information or content that you voluntarily disclose via the Service in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes available to such other users. In addition, the Service may allow you to interact with other people outside of your organization – and share content with them. In addition, certain user profile information, including your name, job position, and contact information may be displayed to other such users to facilitate user interaction within the Service. Please remember that any content you upload or disclose in such a public manner becomes available to such other users.
- Business Transfers. We may choose to sell the assets of TownConnect. In these types of transactions, customer information is typically one of the business assets that would be transferred, subject to standard confidentiality arrangements. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
- Protection of TownConnect and Others. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order, enforce or apply our Terms of Service and other agreements, or protect the rights, property, or safety of TownConnect, our employees, our users, or others.
- Aggregated Personal Information that’s no longer personally identifiable. We may anonymize your Personal Information so that you are not individually identified, and provide that information to our partners. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate information to any third party in a manner that would identify you personally, as an individual.
4. What You can Do to Your Personal Information.
- Editing your profile. If you are a registered user of the Service, we provide you with tools to access or modify your Personal Information and other profile information. These tools are accessible from Settings when logged- in to your Service account.
- Deleting your account. You can delete your account by contacting the system administrator. Subject to the “Limitations on Deletion” section below, when you request us to delete your account for the Service, your account will be disabled. We will also disconnect our systems from your Card account(s). In addition, you may contact your organization administrator(s) to request removals from the organization you are listed as being part of. If you do this, you will be removed from the organization and your non-public information will become unavailable to the organization (but any information stored or exchanged prior to the removal may remain accessible to the organization).
- Retention. We retain your Personal Information for as long as we need it for the purposes for which it was collected and where we have an ongoing legitimate business need to do so, taking into account the amount, nature and sensitivity of the data, and the potential risk of harm from unauthorized use or disclosure. Where we have no ongoing legitimate business need to process your Personal Information, we will either delete it or anonymize it, or, where this is not possible (for example, because it has been stored in backup archives), we will securely store such Personal Information and isolate it from any further processing until deletion is possible. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
5. Laws and Regulations. We may also retain your Personal Information to the extent required to comply with (or we deem it reasonable in light of) any laws or regulations.
6. The Location of Your Personal Information. While your Personal Information is in our possession, it will be primarily stored at hosting facilities located in the USA. These facilities are either operated by TownConnect or our third party providers. By using the Service you are consenting to have your Personal Information stored, transferred and processed in the USA. If we transfer your Personal information from the European Union or Switzerland to other countries not deemed adequate under applicable data protection laws, we ensure that the recipient of your Personal Information offers an adequate level of protection, for instance by entering into appropriate back to back agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission.
7. The Security of Your Personal Information. TownConnect takes data security very seriously. We have implemented certain technical, physical and administrative safeguards to protect your Personal Information and to limit the risk that it will be accessed without authorization. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. Given the nature of information processing technology, however, we cannot guarantee that any information, during transmission through the internet, or while stored on our System, will be absolutely secure from intrusion by others.If we learn of a security systems breach, then we may attempt to notify you via email, phone, physical mail, or by a posting on your Service account page – so that you can take appropriate protective steps. Pursuant to our Terms of Service you have consented to receive such notice by electronic means (provided that such consent is void where prohibited by applicable law). To receive a free written notice of a security breach, or if you have any questions about the security of the Service, please contact us.
In addition to the security measures referenced above, your Service account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
8. Your Data Protection Rights. Individuals located in some jurisdictions, including the European Economic Area, have certain statutory rights in relation to their Personal Information, including, subject to any exemptions provided by law, the right to request access to Personal Information; the right to request that we transfer your Personal Information to another controller; the right to restrict or object to our processing of Personal Information; as well as the right to seek to update, delete, and/or correct such information. Similarly, if we have collected and processed your Personal Information with your consent, you can withdraw your consent at any time. Where applicable, you may also lodge a complaint with your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
11. Information from Children. We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us.
12. Contacting Us. If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@TownConnect.co or write to: TownConnect, Inc. (“TownConnect”), 33882 Rowland Dr,Fremont,Ca-94555 Attention: Privacy.
13. California Residents. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request. In addition, under the California Consumer Privacy Act, California residents may request information regarding the collection of their Personal Information by us and any disclosure of that information to third parties.
- Additional Information on California privacy rights:
This Privacy Notice for California Residents supplements the information contained in TownConnect, Inc. TownConnect’s GENERAL PRIVACY NOTICE and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
- Information We Collect: Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, TownConnect, Inc. TownConnect has collected the following categories of personal information from its consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.||Yes|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||No|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||No|
|G. Geolocation data.||Physical location or movements.||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes|
|K. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- TownConnect, Inc. TownConnect obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
- Resume upload on the careers section.
- Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information and for permitted business purposes. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all ofTownConnect, Inc. TownConnect ‘s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TownConnect, Inc. TownConnect about our Website users is among the assets transferred.
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
- Sharing Personal Information
- We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
- Disclosures of Personal Information for a Business Purpose
- In the preceding twelve (12) months, TownConnect, Inc. TownConnect has disclosed personal information for a business purpose to its Service providers.
- In the preceding twelve (12) months, TownConnect, Inc. TownConnect has not sold personal information.
- Your Rights and Choices
- The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights
- You have the right to request that TownConnect, Inc. TownConnect disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Deletion Request Rights
- You have the right to request that TownConnect, Inc. TownConnect delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion ), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
- We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Exercising Access, Data Portability, and Deletion Rights
- To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at +1 (408) 887-7974
- Sending us an email at privacy@TownConnect.co
- Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
- You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
- Making a verifiable consumer request does not require you to create an account with us. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
- We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In .
- Response Timing and Format
- We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
- If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
- Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
- We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
- Changes to Our Privacy Notice
- TownConnect reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
- Contact Information
- Phone: +1 (408) 887-7974
- Website: https://townconnect.co/
- Email: support@TownConnect.co
- Postal Address: 33882 Rowland Dr, Fremont, CA-94555
- Data deletion policy: If you are part of any office community or residential complex please reach out to your administrator to remove your data.
If you are using TownConnect services you can request to delete your data by sending us an email at firstname.lastname@example.org and we will delete your data within 10 business days.