Consumer Services, which include our websites (www.townaide.com and developer.townaide.com) (the “Sites”), our “townaide” mobile applications (collectively, the “Apps”), and our features (i.e. attributes that “townaide” makes available, such as the ability for users to create lists), content (e.g. tips, reviews, photos that users may provide), and widgets (i.e. an application that allows users to access the Apps) (all, collectively, the “Consumer Services”); and
Enterprise Services, which include our media, attribution, analytics, Application Programming Interface (“API”) and Software Development Kit (“SDK”) products (collectively, the “Enterprise Services”).
Part I – “townaide” Users
Below are the types of Data we collect about “townaide” Users and the ways in which we may collect, use and share that Data.
What Data Does “townaide” Collect?
Data You Provide To Us
We receive and store Data that you provide to us when you create an account and use our Consumer Services. When you create an account, we may collect your full name, email address, phone number, birthday, gender, the city in which you created your account, and where applicable, your Twitter, Facebook or Google username and other Data if you create an account using your third party log-in credentials (please see “Data Received From Third Parties” below). As you interact with us and use our Consumer Services, we may also collect other Data that you directly provide to us, which may include pictures that you choose to upload to your account, any restaurant or other venue searches you make, your likes, who you follow, check-ins, comments or tips you make, whether you have created or edited venues, and any other Data that you volunteer to us. Data Collected When You Use Our Consumer Services If you opt-in, we automatically receive Data about your location and/or IP address whenever you interact with, or use, the Consumer Services (e.g. open the App, visit our website, etc.). We use various technologies to determine your location, such as the location services of your operating system or browser, sensor data from your device (e.g. magnetometer or barometer, Bluetooth data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other Data that may help us to understand your precise location. We may also collect additional Data about you when you use the Consumer Services. For example, we receive Data:
relating to how you interact with the Consumer Services, such as your search terms, what pages you view, your access times, the time you spend on each page, your IP address, the redirected pages, or any messages you write to other users or post to the Consumer Services;
relating to your device, such as your hardware model, operating system, unique ID, browser type, language, and wireless network;
If you use our Apps and have enabled background location services in our Apps, you have permitted us to collect the above Data about you in the background even when you do not have the Apps open (as permitted by your device settings). You may turn off location services at any time by going to your device settings and toggling off background location. For more information about location, please see “Determining and Sharing Location” below. Data Received From Third Parties We may receive Data about you from third parties, including Enterprise Customers (e.g. customers of our Media Products) and/or third parties with services that interact with the Consumer Services or that provide services to us, such as unaffiliated apps and websites, e.g., websites and applications offered by third party developers that integrate with our API, advertising exchanges, ad platforms, ad networks or from our partners. This Data may include Data about your activity when using the Consumer Services or on unaffiliated websites and apps, or Data received from web browsers or operating systems such as browser types and settings, the operating systems, device models, carriers, location information, IP address, mobile device and advertising identifiers (e.g. Apple IDFA or Google Advertising ID), as well as cookie information, pixel or other similar technology. If you created your account using your Google, Twitter or Facebook account profile, we may receive certain information from these companies, such as your first name, last name, gender, birthday, email address and your Google, Twitter or Facebook ID.
How Is My Data Used?
Below are the ways that we may use Data about “townaide” Users. To Operate, Maintain And Improve The Consumer Services We may use your Data to operate and maintain the Consumer Services, and to understand you better and tailor the Consumer Services to you. If you download more than one App, we may combine your Data provided in each App. If you use the Consumer Services when you are not logged into your “townaide” account, when you subsequently log into your “townaide” account, we may combine Data collected while you were not logged in with your “townaide” account. We may also use your Data for research and development, to improve the Consumer Services, or to offer new products, features and tools, but only to the extent that this is in compliance with applicable law. For example, we may redesign the Apps to make it easier for you to search for restaurants in “townaide”. We may also use your Data to customize our Apps and Sites to provide you with your own special experience. We do this by inferring your interests and preferences, looking at your search history or allowing you to find and add friends who are also using the Apps and Sites from your device’s contact list or if applicable, your Facebook, Google or Twitter account if you have opted to connect these accounts to your “townaide” account. In these situations, we do not store your contact lists. We also may use your Data to help us map Locations (as defined below). For example, we may use device signals to determine that a particular device is within a particular venue. Additionally, if you consent to sharing crash data (when the Apps crash) with us, we may use that data to help us analyze the cause of the crash. Communicate With You We may use your Data to communicate with you, including by email, text (only if you opt-in), or in our Apps, about new product offerings, updates to the Consumer Services, or anything else we think may be of interest to you. You can opt out of receiving marketing and promotional communications. Protection Of Our Rights We may use your Data to protect the rights, property or safety of “townaide”, the Consumer Services, our users and employees, or any third party. For example, we may use your Data if we need to enforce or apply our Terms of Service or Policies. Enterprise Services We may use your Data in our Enterprise Services and in other services that we may provide to businesses. For example, when partners use our SDK, we may receive certain Partner End User Data back (e.g., wifi end points, Visit Data, and other Data), including Data about “townaide” Users, if the Partner End-Users are also users of our Consumer Services. We may use this Data for our business purposes or to improve the Enterprise Services. As always, you can always opt-out of this type of sharing by disabling your background location services for the Apps. See also “Media Products” section of Part III below.
When Is My Data Shared?
If you consent or authorize a third party app to access your “townaide” account, we may share your Data with such third party app. You can revoke your consent at any time in your “townaide” account profile settings.
We sometimes enter into relationships with partners to offer contests and promotions through the Consumer Services. For example, we may partner with a brand to have a contest to win a prize and if you enter the contest, we may share your email address and/or other necessary PII with such brand, with your consent. In these cases, we will only share Data that is necessary with our partner.
Other times we may share your Data when we believe in good faith that such release is necessary to comply with law or a legal process, including laws outside your country of residence; to protect our rights, property, or safety of “townaide”, our employees, the Consumer Services and others. We may share your Data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.
Determining and Sharing Location
What About Cookies and Similar Technologies?
How do I Access or Delete My Data?
You may access and update your Data at any time through the “Settings” tab in your “townaide” account. To view every Location that you have visited, you may access this Data in the “townaide” History tab or app. You may also delete your account at any time on our Sites by clicking on the Delete Your Account link in your Privacy Settings page. If you delete your account, your profile, including your check-in history, tips and photos, badges and stickers received, will be removed from the Consumer Services, and you will no longer be able to access such Data. We may not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual copies of your PII or posts may remain on backup media for a short period of time thereafter. Additionally, we may store certain Data that is not PII, i.e. does not directly identify you, in our internal systems, which we may use in our Enterprise Services. We may also retain Data as required by applicable law and we will not delete any Data that is not PII, i.e., has already been anonymized. If you have questions about accessing, updating, or deleting your Data, please email [email protected]
Can I Opt Out?
How to Opt Out of Marketing and Promotional Emails and Text Messages
By Email: You can opt out of marketing or promotional emails at any time by adjusting your preferences in the
“notification settings” tab in the Apps or through the “Settings” tab on our Sites if you are logged into your account. You may also unsubscribe from emails in the footer of any marketing or promotional email. Please note that you cannot opt out of service or legal notices.
By SMS: If you have opted in to receive SMS messages, you can always unsubscribe at any time by texting STOP in response to a message or by following the instructions in the SMS.
How to Opt-Out of Interest-Based Advertising We adhere to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. At this time, however, we do not honor web browser Do Not Track (“DNT”) signals or other similar mechanisms. You may opt out of interest-based advertising as follows:
If you have a “townaide” account, you may opt-out of seeing interest-based ads from “townaide” only in the privacy settings section of your respective account.
Certain versions of your device’s operating system permit you to opt out of interest based advertising. Please visit your device settings to limit such tracking.
Please note that when you opt out of interest-based ads, you will still see ads, but they will no longer be based on your interests or behavior. After you have opted out, we will no longer use any PII collected from you on that particular browser or device for advertising purposes. We will also be unable to connect that device or browser to a different device or browser. How to Remove Background Location Sharing? If you use our Apps and have opted-in to sharing your background location with us, you may remove your permission at any time by going into your operating device settings and toggling off background sharing.
Part II – Partner End-Users
Below are the ways in which we may collect, use and share Data about Partner End-Users.
API or Data Files
We share Data with third party developers via our API, which may also involve those third party developers agreeing to share Data about Partner End-Users with us. They have committed not to share Partner End-User Data with us: if it comprises PII; or without the Partner End-User giving prior consent to such sharing. (We also share Data with third party developers via data files but this does not involve those third party developers sharing Partner End-user Data with us.)
App developers may partner with us to use our SDK, which they integrate into their own apps to help them identify when Partner End-Users are near interesting places of relevance to their service (e.g. a nearby store with respect to which they can offer a coupon), identify accurate venue data (such as the geo-coordinates of a restaurant or store) or to identify when their end users have visited a specific venue (“Visit Data”). When partners use our SDK, we may receive certain Partner End-User Data back (e.g. wifi end points, Visit Data, and other Data), including Data about users of our Consumer Services, if the Partner End-Users are also “townaide” Users.
Part III – Individuals Who Are Not “townaide” Users or Partner End-Users
Below are the ways in which we may collect, use and share Data about individuals who are not “townaide” Users or Partner End-Users.
We, our partners, and advertising service providers may receive Data from unaffiliated apps and websites, advertising exchanges, ad platforms, ad networks or from our partners, which we, our partners and advertising service providers may use to send interest-based advertising. The Data collected for this purpose may include Data such as activity when using the Consumer Services or on unaffiliated websites and apps, or Data received from web browsers or operating systems such as browser types and settings, the operating systems, device models, carriers, location information, IP address, mobile device and advertising identifiers (e.g. Apple IDFA or Google Advertising ID), as well as cookie information, pixel or other similar technology. We may combine the Data described above with demographic, location and other interest-based segment Data from third parties to provide the Enterprise Services. When we partner with a business, PII is not shared with them. We will only share Data in aggregate or in some cases, pseudonymized form. When we share Data in a pseudonymized form, a unique identifier is shared so that our partner can measure conversion as to whether an individual has seen its ad, visited its website, or visited their brick and mortar location. We may collect Data about individuals acting in their professional capacity as a representative of a third party developer, vendor, partner or enterprise customer. We may collect their names, job titles, phone numbers, email addresses and/or billing addresses (of their organization), so that we can contact and interact with these organizations in relation to the contracting process, billing, and/or promotions. We do not combine Data from these individuals with any Data about users of our Consumer Services. In the case of developers who use our API or SDK, we also collect Data that developers provide on their developer account profiles, as well as certain Data that we process when a developer uses his or her account (such as time of use and device information). We may share Data we collect about these individuals with service providers, vendors and contractors to provide or perform services on our behalf, such as providers that help us manage customer relationships, sales, and marketing for “townaide”. Our service providers, vendors and contractors will be subject to binding contractual obligations to: (i) only process this Data in accordance with our prior written instructions, and not use the Data for their own purposes; (ii) use measures to protect the confidentiality and security of the Data; (iii) comply with additional requirements under applicable law. We may also share this Data when we believe in good faith that such release is necessary to comply with law or a legal process, including laws outside the individual’s country of residence; to protect our rights, property, or safety of “townaide”, our employees, the Consumer Services and others. We may also share this Data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.
Part IV – Individuals Described In All of Parts I, II and III.
This Part IV applies to Data about individuals we may collect in the circumstances described in all of Parts I, II and III.
Your legal rights
Subject to applicable law, you may have a number of rights regarding the processing of your PII, including:
the right to request access to, or copies of, your PII that we process or control, together with information regarding the nature, processing and disclosure of that PII;
the right to request rectification of any inaccuracies in your PII that we process or control;
the right to request, on legitimate grounds:
deletion of your PII that we process or control; or
restriction of processing of your PII that we process or control;
the right to object, on legitimate grounds, to the processing of your PII by us or on our behalf;
the right to have your PII that we process or control transferred to another data controller, to the extent applicable;
where we process your PII on the basis of your consent, the right to withdraw that consent; and
the right to file a complaint with a Data Protection Authority regarding the processing of your PII by us or on our behalf.
This does not affect your statutory rights.
We use industry standard physical, technical, and logical security measures to protect your Data. We endeavor to safeguard your Data to ensure that it is kept secure. However, we cannot guarantee the security of Data in an account from unauthorized entry or use, hardware or software failure, and other factors. Your account is protected by a password that you have chosen. We recommend using a password that is unique to your “townaide” account. If you use the Consumer Services on public or shared networks (e.g. public wifi), we cannot ensure the security of your account.
Children under 13
Neither the Consumer Services nor the Enterprise Services are directed to individuals who are under 13 years of age. We do not knowingly collect any Data from children under 13. If you notice or suspect that a user is under 13, please contact us immediately at [email protected]
Our Apps and all of our data, including your Data, are hosted on servers in the United States. If you are using or accessing the Consumer Services or Enterprise Services from outside of the United States, your Data will be transferred to, processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain your Data through laws applicable in the United States. United States laws may not offer the same privacy protections as the law of your jurisdiction.