Privacy Policy

EFFECTIVE DATE: MAY 23, 2022

In this Privacy Policy (“Policy”), we describe how (“TwnSqr”, “we” or “us”) collects, uses, and discloses information that we obtain about visitors to our website TwnSqr.com (the “Site”), other mobile applications and electronic services that link to this Privacy Policy and the services available through our Site (collectively, the “Services”).

By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Use (accessible at TwnSqr.com/terms-of-use), including its applicable limitations on damages and the resolution of disputes.  TwnSqr’s Terms of Use are incorporated by reference into this Policy.

  • The Information We Collect About You
  • How We Use Your Information
  • How We Share Your Information
  • Third Parties
  • Security of My Personal Information
  • Access To My Personal Information
  • What Choices Do I Have Regarding Use of My Personal Information?
  • Compliance with the TCPA
  • Children Under 13
  • Special Information for California Consumers
  • Contact Us
  • Changes to this Policy

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The Information We Collect About You

We, along with our affiliates, business partners and service providers, collect information about you directly from you and from third parties, and automatically through your use of our Site or Services.

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Information We Collect Directly From You. We, along with our affiliates, business partners, and service providers, use the Information about you to support your use of the Services.  The Information about you may include information about a property you wish to buy or sell, or a list of potential buyers that you wish to upload to our website. In addition, the Information may include direct identifiers, such as your full name, user name or number, contact information, such as email address, job title, physical address, phone number and other information associated with the direct identifiers, such as your account information, which may include other business details, such as the name of your company or employer.  If we remove direct identifiers about you, such information is no longer considered information about you and is not subject to this Privacy Policy.  We collect Information directly from you, through your interaction with the Services, and from the other persons who may provide Information about you through the Services. Many functions of the Service involve you directly submitting Information (such as by subscribing to our Services) so you may benefit from features or participate in activities using the Services.  For example, we collect or derive Information about you through the Services when you respond to questions and images to derive your personality profile.

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Information We Collect From Other Sources. We may receive additional information about you from a variety of sources, such as from other users with whom you interact through the Services, third party social media platforms, data or marketing partners, and publicly available sources.  Such Information is used to help manage and administer the Services, provide services that you request, and contact you.  We may also receive Information about you from marketing and research firms to help us improve our Services.  We may combine this additional information with other information we have about you.  

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How We Use Your Information

We use your information, including your personal information, for the following purposes:

  • To provide our Services to you and promote our products and services.
  • To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
  • To improve our programs or the content of our Services, and for our own analysis.
  • In cases where we remove the elements of your information that could identify you, We may use and disclose the resulting “de-identified” information without restrictions.  For example, we may create de-identified, statistical, and aggregate data results for research purposes and for reporting to other organizations.  This data reported will not contain personal information and will not identify individuals.  
  • To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. We may transfer Information about you, in which case any such buyer or acquiring party would be subject to the terms and conditions of this Privacy Policy.

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Our Use of Cookies and Other Tracking Mechanisms

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).

Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Site, Services, and on third-party sites.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers may also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

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How We Share Your Information

We may share your information, including personal information, as follows:

  • Service Providers. We may disclose the information we collect from you to service providers, contractors or agents who assist Us in managing, administering or delivering the Services. These service providers include credit card processors and customer data management companies.
  • Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries for any of the purposes described in this Policy.
  • Law Enforcement. To respond to law enforcement requests or where required by applicable laws, court orders, or government regulations.  
  • Your Authorization.   We may also provide Information, including direct identifiers, about you and your use of the Services to others or for other purposes only if you authorize Us to do so.  For example, we may offer specific functions associated to specific sponsors or other business partners, for which more Information about You may be exchanged.  We may share your uploaded Buyer List with other Users and/or link your Buy Box or Purchase Criteria with your account or personal information only if you authorize Us to do so.  In such a case, we would inform you generally about the nature of the information being provided and receive your acceptance (which may be by selecting a button or engaging in other electronic actions that signify your acceptance) before we exchange additional information about you.  We might directly ask you, or we might be able to rely on settings you have made to your account profile, to authorize an information disclosure.
  • Social Media.  If you connect your account with us to a social media service (e.g., Facebook, Twitter, etc.) then We may share your information in accordance with the application program interface of that social media site.  In this case, we are not responsible for your data that you provided to us, that is transmitted to such social media site in accordance with the permission you granted by enabling such connection.  

We also disclose information in the following circumstances:

  • Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
  • In Response to Legal Process. We may disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We may disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Policy, or as evidence in litigation in which we are involved.

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Third Parties

Third-Party Links. Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Services. We also may use other analytic means to evaluate our Site and Services. We use these tools to help us improve our Site’s and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Third-Party Ad Networks. We may use third parties such as network advertisers to serve advertisements on our Site, Services, and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at  www.networkadvertising.org.

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Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

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Access To My Personal Information

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

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What Choices Do I Have Regarding Use of My Personal Information?

Marketing Communications. We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

Buyer Lists and Purchase Criteria. You may upload Buyer Lists or Purchase Criteria onto our website.  When You upload a Buyer list onto the Website, You are certifying that the individuals, companies, or entities on the Buyer List have given their consent to receive correspondence from Us.  The Buyer List will be stored on an account that is owned, managed and accessed only by Us.  We will not share Buyer Lists or Purchase Criteria with any third party unless you authorize Us to do so.  We shall also remove or delete any information in the Buyer List or Purchase Criteria from our account if you request us to do so.

Location Information.  You can prevent your device from sharing precise location information at any time through your device’s operating system settings.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.

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Compliance with the Telephone Consumer Protection Act (TCPA)

The Federal Communications Commission (FCC) requires that We not transmit calls or send text messages that violate the TCPA.  In some instances, we may wish to send a User of our Service (as defined in our Terms of Use) a text message or Short Message Service (SMS) that provides an alert to that User that a new property has been shared with them on our website.  The text message or SMS shall not contain any of Your personal information or the personal information of any other individual.  In addition, the text message or SMS shall not include any direct identifiers, such as a full name, user name or number, contact information, such as email address, job title, physical address, phone number and other information associated with the direct identifiers, such as account information.

We shall only send a text message or SMS to You if you have clicked on “Signup” on Our website and created a free account.  At that point, you will have become a User as defined in our Terms of Use (accessible at TwnSqr.com/terms-of-use) and you will have agreed to the provisions of the Terms of Use, including providing consent to Us to send you a text message or SMS for the sole purpose of providing an alert that a new property has been shared with You on our website. 

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Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

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Special Information for California Consumers

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us.  See the Contact Us section below for more information on how to reach us. Please allow up to thirty (30) days for a response.

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Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:

Info@TwnSqr.com

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Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

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