We are strongly committed to letting you know how we will collect and use your personal information. The policies below are applicable to data and information collected through all apps published by 468 Communications or Think Local First; and all other interactive features and communications provided through the apps (“App”), however accessed and/or used, that are operated by us, made available by us, or produced and maintained by 468 Communications. We have established this privacy policy (“Privacy Policy”) to let you know the kinds of personal information we may gather during your use of this App, why we gather your information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information.

Please be advised that the practices described in this Privacy Policy apply only to information gathered through our App. It does not apply to information that you may submit to us offline, through our website, or by companies or organizations to which we may link or who may link to us.

By using our App, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the App. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our App following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personal information already in our possession, we will provide you with notice of the modifications or amendments.

If you have any questions about this Privacy Policy or don’t see your concerns addressed here, you should contact us by email at michele@thinklocalvictoria.com.

 

What Information About Me Is Collected and Stored?

We collect two basic types of information from you in conjunction with your use of the App, personal information and non-personal information. Personal information is information that you may supply to us, as described more fully below, i.e., when you obtain a subscription, complete a survey, register on the App, upload content, participate in a community, or provide your e-mail address. Personal information is any information that can individually identify you and includes, among other things, your name, e-mail address, telephone number, postal address, credit card, billing and contact information. Non-personal information includes information that does not personally identify you, but it may include tracking and usage information about your location, demographics, use of the App and the Internet.

Personal Information
As a general matter, you can browse the App without submitting your personal information to us. However, there are a number of circumstances in which you may supply us or our agents with your personal information. The following lists the most common ways in which we may collect your personal information.

  • Registration for an account on the App
  • Profile information that You provide for Your user profile
  • Uploading Content to the App
  • Participation in surveys
  • Sign up to receive alerts or other information via email, text or instant message from Organization
  • App related communications, e.g. account verification; technical notification
  • Submission of content or other data and information on any part of the App that permits it
  • Any other place on the App where you knowingly volunteer personal information

Non-Personal Information
In addition, when you interact with the App, we may collect certain information that does not identify you individually and our servers may automatically keep an activity log of your use of our App (“Non-Personal Information”). Generally, we collect and store the following categories of Non-Personal Information:

  • Non-identifiable demographic data such as age, gender, and five digit zip code as part of collecting personal information
  • Device information about your browser, mobile device, or other device that you use to access the App. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information.
  • Analytics and usage information about your use of the App.
  • Additional “traffic data” and log files such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses.
  • Other information regarding your use of the App.

Collection of Your Source IP Address/Location Information
We may collect and store location information about you on the App and associated with your account that you volunteer on the App or enable through the App or your device. We will not collect any location information that you do not volunteer or enable. We will delete any location information that you request is deleted. We do collect and store your device’s source IP address which may disclose the location of your device at the time you access the App

 

How Do We Use Your Information?

We use the information we learn from you to help us personalize and continually improve your experience on the App. We may use your Personal and Non-Personal Information in the following ways:

General Uses              

  • To upload your content to our App as you request
  • To permit you to update, edit, and manage your content on our App
  • To communicate with you about your account or transactions with us (including service related announcements) and send you information about features and enhancements on our App
  • To communicate with you about changes to our policies
  • To personalize content and experiences on our App, including providing you reports, recommendations and feedback based on your preferences
  • To disclose anonymized Personal Information to disclose statistics and analytics and other details regarding the use of our App.
  • To optimize or improve our products, services and operations
  • To automatically update the App on your device
  • To detect, investigate, and prevent activities that may violate our policies or be illegal
  • To perform statistical, demographic, and marketing analyses of users of the App

Use of Your Location Information

Specifically, we use your location information to:

  • Personalize content on our App, including providing you reports, recommendations and feedback based on your preferences
  • Facilitate the collection and/or redemption of credits, points, or other benefits for associated loyalty or reward programs associated with the App
  • Optimize or improve our products, services and operations
  • Detect, investigate, and prevent activities that may violate our policies or be illegal

Perform statistical, demographic, and marketing analyses of users of the App and their purchasing patterns

 

Who Do We Provide Your Information To?

Except as disclosed in this Privacy Policy, we do not disclose information about your Personal Information collected online to any companies not part of Organization or its parent, subsidiaries or related entities. In no event will we sell or rent your Personal Information as part of a customer list or similar transaction.

Business Partners and Third Parties
We may share your Personal Information with our business partners from time to time. You may withdraw your consent to our sharing of your Personal Information with business partners and third parties at any time by following the opt-out process described below.

Third-Party Agents
We have third party agents, subsidiaries, affiliates and partners that perform functions on our behalf, such as hosting, billing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc. These entities have access to the Personal Information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the App.

Emergency Situations
We may also use or disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the App; (b) protect and defend our rights or property, the App or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the App or the public. This includes exchanging information with other companies and organizations for fraud protection.

 

What Steps Are Taken To Keep Personal Information Secure?

We are concerned about ensuring the security of your Personal Information. We exercise great care in providing secure transmission of your information from your device to our servers. Personal Information collected by our App are stored in secure operating environments that are not available to the public. Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Information to you. Please understand, however, that while we try our best to safeguard your Personal Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

 

How Can We Transfer Your Personal Information?

Your information collected through the App may be stored and processed in the United States or any other country in which Organization, its Clients, Affiliates or service providers maintain facilities. Organization, its Clients, Affiliates, or service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the United States or other regions with laws governing data collection and use that may differ from US law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. Wherever your personal information is transferred, stored, or processed by Organization, Organization will take reasonable steps to safeguard the privacy of your personal information. By registering for and using the App you consent to the transfer of information to the US or to any other country in which Organization, its Clients, Affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

 

How Long Do We Keep Your Information?

Following termination or deactivation of your account, Organization, its Clients, Affiliates, or its service providers may retain information (including your profile information) and user Content for a commercially reasonable time for backup, archival, and/or audit purposes. If you have any questions about termination or deactivation of your account, please contact us directly at michele@thinklocalvictoria.com.

 

Governing Law

This App is published in the United States and Canada. We attempt to protect the Personal Information of all users of our App and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to the Organization services, but our App is located and targeted to United States and Canadian citizens and our policies are directed at compliance with those laws. If you are uncertain whether this privacy policy conflicts with the applicable local privacy laws where you are located, you should not submit your Personal Information to Organization.

 

Assignment

We may change our ownership or corporate organization while providing the App. We may also sell certain assets associated with the App. As a result, please be aware that in such event we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

 

Changes to This Policy

As our App continues to develop, we may add new services and features to our App. In the event that these additions affect our Privacy Policy, this document will be updated appropriately. We will post those changes prominently so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We do, however, recommend that you read this Privacy Policy each time you use our App in case you missed our notice of changes to the Privacy Policy. We will not, however, materially change our policies and practices to make them less protective of Personal Information we have previously collected from you without your express consent.

 

Opt-Out Provisions

Visitors to our App can choose not to provide the personally identifiable information needed to register for the Service, however, those visitors will not be able to use the Service. You may choose not to share your precise geo-location information with us by adjusting the device’s location services settings or the settings on our mobile applications.

 

Accessing and Correcting Your Information

If you have an account with Think Local First, you may review and change your information by logging into your account and editing your profile. Be advised that we may not be able to delete your Personal Information without also deleting your user account. You will not be permitted to examine the Personal Information of any other person or entity and may be required to provide us with Personal Information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete Personal Information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.

If you have any questions about this Privacy Policy, you should contact us by email at michele@thinklocalvictoria.com.