Effective January 24, 2020
TouchSource LLC (“TouchSource”, “We, or “Us”) recognizes the importance of privacy. We want you to feel confident using our services, and this privacy notice (“Notice”) is to help you understand and describe how we collect, use, and disclose your information.
“Personal Information” refers to information that personally identifies you, such as your name, mailing address, telephone number, email address or IP address, and any information defined as Personal Information or “Personal Data” under applicable privacy laws.
How to Contact Us
For any questions relating to this policy or our privacy practices, or to exercise any rights you may have with respect to your personal information, you may contact TouchSource by emailing us at firstname.lastname@example.org
DIGITAL INFORMATION DISPLAYS:
TouchSource operates Digital Information Displays for clients in retail, office, and other commercial spaces.
Our Digital Information Displays do not collect, store, or process information that is identified to a natural person.
The Digital Information Displays do not record video, take photographs, or otherwise identify individuals that walk in front of, or interact with, the Digital Information Displays. The Digital Information Displays’ sensors have the potential to process images and information to measure how many people watch or interact with the display, the duration of interactions, the approximate age bracket of a watcher, the gender of a watcher, and general statistics concerning foot traffic. No images would be saved and none of this information is identified to a natural person. Additionally, the Digital Information Displays’ sensors collect information about the ambient environment including temperature, sound levels, and other environmental information.
TouchSource may share anonymous and aggregated data collected from the Digital Information Displays as part of its regular business activities. The Digital Information Displays do not collect information identified to a natural person and none of the Kiosk data TouchSource may share is identified to a natural person.
Neither the Digital Information Displays nor the website are directed to children. TouchSource does not knowingly collect information from children under the age of 16. If we learn that we have collected Personal Information from a child under the age of 16, we will promptly delete that information. If you believe we have collected Personal Information from a child under the age of 16, either through the Digital Information Displays or the website, please email us at email@example.com or call us at the number listed above.
Information We Collect
When a user visits the TouchSource websites, the information we collect includes:
- Information about the devices our visitors use to access the Internet, such as the IP address and the device, browser and operating system type.
- Pages and URLs that refer visitors to our site, and pages and URLs that visitors view once they leave our site.
- Dates and times of visits to our site.
- Information on actions taken on our site, such as page views and site navigation patterns.
- Contact information when you complete a registration form, comment or other feedback form.
Our website does not respond to Do Not Track (DNT) signals. Third party applications and plugins, such as social media integration, may treat DNT signals differently.
How We Use The Information We Collect
- Personal Information. We use the Personal Information collected to operate and maintain the website, to communicate with current and potential business contacts, and to provide information about our company.
When We Share Information
- Business Operations. We may share the information you provide with our affiliates and subsidiaries as part of normal business operations. We may also use third-party suppliers and service providers in connection with our website and make Personal Information available to them to the extent necessary for them to provide services to us. We may use and share with others aggregated and/or anonymous information that we have collected based on web usage data or statistical information that we have compiled about our users. In addition, we may disclose Personal Information to comply with a valid legal process such as a search warrant, subpoena, or court order, if we find that a user’s actions violate our policies, or to protect our rights and property, or to our affiliates or successors to the relevant portions of our business.
- Mergers. We will disclose your Personal Information to any successor-in-interest, such as a company that acquires us. In the event TouchSource goes through a business transition, such as a merger or acquisition by or with another company, or sale of all or a portion of our assets, your Personal Information will be among the assets transferred. In addition, your Personal Information may be disclosed in any due diligence process conducted relative to a potential business transition as described above.
- With Your Consent. In addition, we may share Personal Information with companies, organizations, or individuals outside of TouchSource when we have your consent to do so.
Your Rights and Choices
- Account. In order to keep your personal information accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account page. You may also contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you our Website, contact us at firstname.lastname@example.org. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, to resolve disputes, and enforce our agreements.
- E-mail. As described above, if you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to delete your account.
- Cookies. You may also refrain from providing or may withdraw your consent for Cookies via your browser settings. Your browser’s help function should contain instructions on how to set your computer to accept all Cookies, to notify you when a Cookie is issued, or to not receive Cookies at any time. Please keep in mind that Cookies are required to authenticate TouchSource Users as well as perform some actions within the TouchSource products, so in order to use the Services, Cookies are often required.
- Third Party Analytics Services. Some of the services used provide the ability to opt-out.
You may opt out of Google Analytics’ services using the Opt-Out feature on their website. The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/policies/privacy.
- Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
TouchSource maintains appropriate administrative, technical and physical safeguards designed to protect the Personal Information we collect against unauthorized access, disclosure or use. While we have these safeguards in place, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us.
Data Storage and Retention
Links to Other Sites
Our Websites may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your Rights and Choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our websites. Any access to and use of such linked websites and applications is not governed by this Notice but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.
Do Not Track
We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
Changes to this Notice
This Notice is current as of the Effective Date set forth above. This Notice may change if there is a material change to the way information is handled at TouchSource, or to clarify our policy or adjust clerical errors. If any changes are made, we’ll post them on this page, so please be sure to check back periodically. If you continue to use TouchSource after those changes are in effect, you agree to the revised Notice.
Privacy Notice for California Residents
Effective date: January 24, 2020
This Privacy Notice for California Residents (“California Notice”) supplements the TouchSource Privacy Notice. It applies solely to TouchSource Users, and Viewers who live in the State of California (“California Residents”). TouchSource adopts this notice to comply with the California Consumer Privacy Act of 2019 and any subsequent amendments (“CCPA”). All terms used in this California Notice have the same meaning as when used in the CCPA.
Information TouchSource May Collect Regarding California Residents
TouchSource 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, our Websites may have collected the following categories of personal information from Users and Viewers within the last twelve months, for the purpose of establishing, maintaining, and supporting the services that we provide through our Websites:
A. Identifiers: real name; alias; email address; internet protocol address.
B. Personal information categories listed in Cal. Civ. Code Sec. 1798.80(e): Real name; phone number.
C. Commercial information: Purchase records regarding TouchSource products.
D. Internet or other similar network activity: Data on Viewers’ interaction with the TouchSource Websites or Digital Information Displays.
TouchSource Obtains the Categories of Personal Information Listed Above from the Following Categories of Sources
- Directly from our Users.
- Indirectly from our Users.
- Directly and indirectly from activity on our Websites.
- From third parties that interact with us in connection with the services we perform.
How California Resident Personal Information May Be Used
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information or services that you request from us.
- To provide you with email alerts and other notices concerning our services, or news that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our Website.
- For testing, research, analysis and service development.
- As necessary or appropriate to protect TouchSource and our Users.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when your personal information was collected, 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 of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TouchSource is among the assets transferred.
- TouchSource 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 your contract.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with the services we provide to you.
- Government representatives as required by law.
- In the preceding twelve (12) months, we have not sold any personal information.
Access to Specific Information and Data Portability Rights
You have the right to request that we 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, 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 categories of third parties with whom we share that personal information.
- The specific pieces of personal information that we have collected about you.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, 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 providers to:
- Complete the transaction for which we collected the personal information, provide a 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 software to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Otherwise lawfully uses that information in compatibility 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 reaching out to support@TouchSource.com.
Only you or a person registered with the California Secretary of State that you authorize 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 California Resident request for access or data portability twice within a 12-month period.
The request must:
- Provide sufficiently detailed information to allow TouchSource to reasonably verify that you are the person about whom we collected personal information or their authorized representative.
- Include sufficient detail to allow 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.
- TouchSource will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will attempt to respond to California Resident requests in as timely a fashion as possible. In the event of delays over 60 days, 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. Any disclosures we provide will only cover the 12-month period preceding the verifiable receipt of a California Resident’s request. The response we provide will explain the reasons we cannot comply with a request, if applicable.
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 fulfilling your request.
In accordance with the CCPA’s requirements, we will not discriminate against you for exercising any of your CCPA rights.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time and will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: support@TouchSource.com.