Privacy Policy
Last Updated: August 7, 2023
Advanced Technology Group, Inc. and its affiliates, including TownSq, Community Archives, Inc., HOAM Ventures, Inc., and Coming Home Media Group, Inc. (collectively, “ATG”, “we”, “our”, or “us”) respect your privacy. This Privacy Policy discloses our practices regarding information we collect and receive from users of our desktop and mobile websites such as www.atgonline.com, www.townsq.io, www.communityarchives.com, www.hoamventures.com, and www.cominghomemedia.com (the “Sites”), mobile applications such as the TownSq mobile application (the “Apps”), other services, such as emails, mailings, and Home Owners Association property management services, provided by ATG, and other contexts in which we present you with this Privacy Policy (collectively, the “Services”). Unless we state otherwise, any new features or functionality provided by ATG on the Sites and/or Apps are also part of the Services. Please read this Privacy Policy carefully before registering or using our Services or submitting any content.
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:
- Your name, email address, mailing address, and similar contact information;
- Information you share about yourself in your profile, like your interests and skills;
- Messages you send to other users of the Services;
- Geolocation information, such as if you share your location, tag your posts or pictures, or check-in at a location on our Apps;
- Your requests or comments;
- The information you provide about those individuals you invite to use or register for the Sites or Apps;
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:
- Your community property manager, title company, real estate agent, and similar entities;
- Your family members, roommates and/or neighbors;
- Our service providers; and
- Data sellers and advertising partners.
How Do We Use the Information We Collect?
We may use your information to:
- Provide the Services to you, including providing technical and other support for the Services;
- Facilitate and improve the operation of our business, including to maintain the safety, security, and integrity of our Services;
- Set up your account and populate your profile;
- Identify and invite potential new members;
- Communicate with you regarding the Services and respond to your inquiries and requests, such as subscriptions to email newsletters;
- Administer contests and sweepstakes, and notify you if you have won;
- Perform legal compliance activities, including to enforce our Terms of Use, to address fraud and other illegal activities, including claims of copyright infringement, to exercise and defend legal claims, and to protect your safety and the safety of other users of the Services;
- Develop and deliver advertising and content that is customized to your individual behavior or characteristics, or the behavior or characteristics of others, based on your information and your use of the Services and information gathered in other contexts, such as other online or mobile websites, apps and services;
- Verify that you live at the address you gave us through a combination of your address and a second factor, such as a code we provide you, digits from your credit card, or manual verification by the member who invited you;
- Analyze your use of the Services and the performance of and your interactions with advertising and content provided on the Services;
- Respond to your feedback, suggestions, and comments to monitor and/or improve the ways in which we serve you;
- Provide the information to service providers and other third parties as described in the “To Whom Do We Disclose Your Information?” section below;
· 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:
Our Subsidiaries and Affiliates: We may share your information with our subsidiaries and affiliates, in accordance with this Privacy Policy.
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.
Targeted Advertising. We may also share your information with businesses such as advertising partners and similar companies to deliver targeted advertising in accordance with this Privacy Policy. You may opt out of such data sharing 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.
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
Cookies, Web Beacons, and Similar Technologies. Our Sites use a technology called “cookies,” which are pieces of information that may be placed on your computer’s browser or your device by a website or service to store your preferences. We also use similar technologies such as “Web Beacons” or clear GIFs, which use pieces of information placed on a service or email to track and collect information about user behavior, for example by counting the number of visitors to a web page, delivering a cookie to a user’s browser or tracking open rates, clicks and forwards. We may use cookies and similar technologies to customize your visit to or use of the Services, or to help us to enhance or improve the Services, for example by storing your password or delivering relevant advertising to you when you use the Services. We may also work with our partners to use such technologies to help them provide advertisements to you when you visit other websites or applications, and to research and analyze how the Services are used as well as user response to and interaction with advertisements. We may work with our partners to synchronize unique identifiers contained in cookies in order to match our identifiers with those used by our partners. These companies may collect and use information during your visit to or use of the Services and other websites and apps. You may be able to set your browser to disable cookies. However, doing so may mean that certain parts of the Services may not work for you.
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.
Google Analytics. We use automated technologies and applications, such as Google Analytics, to evaluate usage of our Sites. We also may use other analytic means to evaluate our Sites and Services. We use these tools to help us improve the Sites, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: http://www.google.com/analytics/learn/privacy.html.
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.
California Residents
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:
· Identifiers
· 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
We may obtain, use, and share these data categories as detailed in the “What Information Do We Collect and How?,” “How Do We Use Your Information We Collect?,” and “To Whom Do We Disclose Your Information?” sections of this Privacy Policy, above.
“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.
Changes to this Privacy Policy
At times, it may be necessary for us to make changes to this Privacy Policy. Where we make material changes to this Privacy Policy, we will take steps to notify you of those changes by, for example, posting notice on the websites or emailing you using the contact information we have on file. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy. We encourage you to bookmark this page and to periodically review it to ensure familiarity with the most current version of our Privacy Policy.
Contact Us
Please feel free to contact us at any time if you have any questions or comments about this Privacy Policy. You can contact us by emailing privacy@hoamventures.com.
