Last Updated: August 7, 2023
What Information Do We Collect and How?
We may collect information when you:
· Visit or register for the Services;
· Login to and interact with your account;
· Contact our customer service via email, phone, or other forms of communication;
· Interact with us at an event;
· Send us a request;
· Provide us with feedback, comments, or suggestions.
Information you provide to us: We may collect information from you, including through the Services, our Apps, our Sites, or when you otherwise interact with us. This information may include:
Information we collect through automated data technologies: We may collect your information using automated data technologies as described in the “Automated Data Collection Technologies” section below. This information may include technical information like your IP address, cookie IDs, browser information, and information reflecting how you searched, browsed, and were directed to the Services, including mouse movement, click, touch, scroll, and keystroke activity, and any other information provided by your use of our Services.
Information we obtain from third parties: We may obtain your information through third party sources, such as from:
How Do We Use the Information We Collect?
We may use your information to:
· For other purposes consistent with the context of the collection of your information, or as otherwise disclosed to you prior to the use of your information; or
· As you may otherwise agree or consent.
To Whom Do We Disclose Your Information?
In the course of our business, we may disclose your information to third parties in the following instances:
Service Providers and other Companies That Work with or on Our Behalf: We may share your information with service providers who receive, use, and process your information on our behalf, including for operations, technology, payment, marketing, and other purposes.
Sale of Business: In the event we undergo a business transaction such as a merger, acquisition by another company, sale of all or a portion of our assets, bankruptcy proceeding, or other restructuring, your information may transfer with the transaction.
Legal Purposes: We may provide your information if we have a good faith belief that the law requires it, such as in response to a search warrant, subpoena, or other legally valid inquiry, order, or process, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law. We may also disclose information to assist us in collecting a debt, or as necessary to exercise our legal rights or defend claims brought against us.
With Your Consent: We may share your information where you have provided your consent to us sharing or transferring your information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
To the Public or Other Users of our Sites if you post content in a manner that makes it available to others. We may also share with the public portions of content you share on the Services without your name or other identifying information.
Automated Data Collection Technologies
Mobile Device Identifiers and Tracking: We or our partners may use mobile Software Development Kits (“SDKs”) to collect information, such as your IDFA or Android Advertising ID, and other information about how your device interacts with the Services. SDKs allow app developers to enable advertising, collection of data and related services and analytics in apps. We may use this technology to deliver, or to help partners deliver, advertising through the Apps and other mobile applications and browsers based on information associated with your device. Depending on your device, you may be able to reset your device’s advertising identifier by accessing the privacy settings.
Do Not Track (DNT) Settings: Some web browsers (including Safari®, Internet Explorer®, Firefox® and Chrome®) incorporate a “Do Not Track” (“DNT”) or similar feature. At the present time, the Sites do not respond to DNT signals.
How Long Do We Retain Your Information?
We retain your information for as long as reasonably necessary for our business purposes. In determining the criteria by which to retain or dispose of your information, we consider the type, sensitivity, context, and purpose of collecting the information. We may additionally delete your information in response to a valid data subject request, as described below.
How Do We Secure Your Information?
We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. No information, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, ATG cannot and does not ensure or warrant the security of your information.
Protection for Children
The Services are not directed at children and we do not knowingly collect personal information from children under the age of 16. If we become aware that personal information has been collected from a child under age 16, we will take steps to delete that information as soon as possible.
Updating and Correcting Your Information
If you are a registered user of the Services, you can update your information by editing your user profile. You may not be able to remove information about yourself that has been provided by your neighborhood management company.
If you are a California resident, your information may be covered by the California Consumer Privacy Act (CCPA). The below disclosures apply to the extent the CCPA applies to your data, subject to any applicable exemptions.
“Personal Information” We Collect: The categories of “personal information,” as defined in the CCPA, that we may collect include:
· Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
· Commercial information
· Geolocation data
· Internet or other electronic network activity information
· Audio, electronic, and visual information
· Professional or employment‑related information
· Education information
· Inferences drawn from other personal information
“Sales” and “Sharing” of Personal Information: We may share personal information with third parties for targeted advertising purposes. Under the CCPA, these practices may be considered “sales” or “sharing” of data, and you have the opportunity to opt out of these practices as described above under “To Whom Do We Disclose Your Information” and by clicking https://go.townsq.io/privacy-opt-out, or by selecting the “Do Not Sell/Share My Information (Targeted Advertising Opt Out)” option as it appears throughout our Services.
Your California Privacy Rights: You may have the following rights with respect to your personal information under the CCPA:
(i) Right to Know About Personal Information Collected, Disclosed, or Sold: You may have the right to request that we provide certain information to you about our collection and use of your personal information over the past twelve (12) months. Specifically, you may have the right to request disclosure of:
· The specific pieces of personal information we collected about you;
· The categories of personal information we collected about you;
· The categories of sources from which personal information was collected;
· Our business or commercial purpose for collecting or disclosing personal information; and
· The categories of third parties with whom we shared personal information.
(ii) Right to Request Deletion of Personal Information: You may also have the right to request that we delete any of your personal information that we collected or maintain about you, subject to certain exceptions.
(iii) Right to Correct Inaccurate Personal Information: You may also have the right to request that we correct inaccurate personal information we maintain.
(iv) Right to Non‑Discrimination for the Exercise of a Consumer’s Privacy Rights: We will not unlawfully discriminate against you for exercising any of your applicable privacy rights.
(v) Exercising Your California Privacy Rights: To request to exercise your CCPA rights described above, please submit a verifiable consumer request to us by using the information in the “Contact Us” section below. Only you or your “authorized agent,” as defined in the CCPA, may make a verifiable consumer request related to your personal information.
Your verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative; and (ii) 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.
(vi) Response Timing and Format: We will make our best effort to respond to a verifiable consumer request within forty‑five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will maintain records of consumer requests made pursuant to the CCPA as well as our response to said requests for a period of at least twenty‑four (24) months.
Your Rights Under California’s “Shine the Light”: Civil Code section 1798.83 requires certain businesses to respond to requests from California residents asking about practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information to third parties for the third parties’ direct marketing purposes if the customer has opted-out of such information-sharing. ATG has such a policy, as described in the “To Whom Do We Disclose Your Information” above.
Other Privacy Rights
If you are in another state or jurisdiction, you may also have some or all of the rights in the “California Residents” section above, including rights to access, correct, and delete your information, subject to any applicable exemptions or limitations. You may exercise your rights by contacting us in accordance with the “Contact Us” section below.