Privacy Policy – United States

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Last updated: 1 August 2020

 

 

 

Our Privacy Commitment

 

Togetherall takes privacy seriously. We work hard to safeguard the information you share with us and we have designed our website to enable you to interact with others in a supportive environment without sharing any information that identifies you personally. This Privacy Policy explains how we collect, use, disclose and retain information that can be used to identify you and how you can protect your privacy when using the Site.

 

This Privacy Policy, along with the Member Terms and House Rules, (collectively, the “Terms”) establish the rules for your use of the Site. By accessing and continuing to use the Site, you agree to be bound by the Terms, including this Privacy Policy. Do not use the Site unless you accept all of the provisions of this Privacy Policy.

 

 

Definitions

 

  1. “Member” means a member of the Togetherall website.
  2. “Member Content” means any information that a you or another Member enters on or uploads to the Site. Member Content does not include the Personal Information you provide to register for the service, but it does include Personal Information you provide to activate your account, information in the Account Settings and My Profile sections of the Site, Bricks, Talkabouts, and Courses.
  3. “Personal Information” means information that can be linked, directly or indirectly, to an identifiable individual, including you, other Members, or others. Personal Information includes things like your real name, nicknames, email address, postal code, date of birth, and any other information that can be used to identify you individually, as well as information linked to one or more of those identifiers.
  4. “Site” means the website located at togetherall.com and the pages in that domain controlled by Togetherall and the content and services provided by Togetherall in connection with operating the Site.
  5.  “User Name” means the username you select to identify yourself to other Members, Wall Guides, and Togetherall staff. The goal is to create a username that protects your privacy, so it should not include your first, middle, or last name, initials, nicknames, or any other information that can be used to identify you personally. See the House Rules for more information.
  6. References to “you,” “your,” or “you’re” are references to the you, the Member/end user of the site.
  7. References to “we,” “our,” or “ours” refers to Togetherall Inc.

 

Information We Collect

 

To operate the Site, we collect Personal Information, Member Content, and Log Data. We strive to limit our collection of Personal Information to that which is necessary in order provide and improve the Site and for other legitimate purposes described in the Terms.

 

 

Personal Information You Provide:

 

When you register for the Site, we collect your postal code, date of birth, phone number and email address. Because it is associated in our records with your email address, this information is Personal Information.

 

From time to time, we may collect additional Personal Information when you provide it. For example, we may collect Personal Information if you contact us for support or if you agree to participate in a research survey.

 

 

Member Content:

 

 

When you activate your account, we will ask you to create a User Name that you will use to interact with others on the Site. Your User Name should not include your first, middle, or last name, initials, nicknames, or any other information that can be used to identify you personally. We also ask about your gender and ethnicity.

 

In order to protect your privacy we segregate Member Content from the Personal Information provided when you register. It is your responsibility to ensure that Member Content you post cannot be used to identify you or others.

 

 

Log Data:

 

 

Our webservers automatically collect Log Data, which is technical information about your interactions with the Site including, but not limited to, your IP addresses, date and time stamps associated with your visit, traffic data, location data (derived from your IP address), referrer URLs, information about your activities on the Site (pages you visited, links you clicked, etc.), and information about your devices, their operating system, configuration, and how those devices interact with the Site.

 

The Site also collects information using Cookies and similar technologies, as described below.

 

 

Protecting Your Privacy

 

 

To protect your privacy and the privacy of others, you must follow the House Rules to ensure that you do not post Personal Information about yourself or anyone else on the Site. For example,

 

• Other Members will see your User Name. To protect your privacy you must choose a User Name that is not related in any way to your real name or nickname.

• Do not post details such as your real name, address, phone, email, names of family members or friends, place information, e.g., where you live, where you receive healthcare or places you like to visit. This applies to photos that may reveal personal data about you.

 

The Site has privacy settings to help protect your privacy. For example:

 

• You may choose whether to participate in Community Talkabouts (“TAs”). You may also invite other members to join Group TAs (“GTAs”) or Personal TAs (“PTAs”). Only other Members whom you’ve invited to participate may see your Member Content in GTAs and PTAs. We may also access GTAs and PTAs.

• You may choose to use tools such as Journals and Goals, which other Members cannot view. However these tools are still monitored by Wall Guides to ensure the safety of our members on Togetherall. Journal and Goal tools are available through the ‘Resources” page on the Site.

 

If you do not use our privacy settings, other Members will see the Member Content you post with your User Name beside it. We reserve the right to delete Member Content if we believe that it is Personal Information, but we are not obligated to do so.

 

 

How We Use Personal Information, Member Content, and Log Data

 

We use Personal Information, Member Content, and Log Data to:

 

• Confirm your eligibility to register, complete your registration, create and administer your Member account, and authenticate you when you login;

• Provide and personalize your experience on the Site;

• Display Member Content when you visit the Site;

• Present information to you in “My Account;”

• Communicate with you, for example, by sending you email about the Site, your Membership, and relevant content;

• Notify you about Site activity such as your receipt of a private message or notify another Member that you have sent them a private message;

• Process and respond to your inquiries and requests;

• Process and deal with any complaints made by or about you;

• Investigate inappropriate use of the Site, including any suspected breaches of, and enforce our House Rules and Member Terms;

• Seek compensation from you or take other action including legal action as set out in the Member Terms;

• Comply with applicable law and/or to protect the rights, property, or safety of [insert name of US entity], affiliates, customers, Members, or others; and

• Learn more about how Members use the Site and its features, enhance and customize the Site, and create reports for statistical, analytical, and reporting purposes or research – but we remove data that identifies you personally from these reports.

 

 

Disclosure of Personal Information, Member Content, and Log Data

 

 

We may disclose your Personal Information, Member Content, and Log Data to third parties:

 

• If we have serious and immediate concerns for your safety or the safety of others, using a specific process described in the House Rules;

• If we are required to do so by law or to comply with any legal obligation;

• In order to enforce or apply our Member Terms or other agreements; or

• To protect the rights, property, or safety of [insert name of US entity], our affiliates, customers, or others.

 

This may include exchanging information with other companies and organizations such as the police, regulatory bodies, or legal advisers for the purposes of security, risk reduction and fraud protection. For example, we may disclose your Personal Information to the police in connection with any alleged criminal offence.

 

Other Members have no access to Member Content you provide when you activate your account or enter into your Account Settings or My Profile. They can, however, view your User Name and the Member Content you provide in avatars, Bricks, Talkabouts, and Courses, subject to your privacy settings. Our Wall Guides may view the Member Content you provide in any avatar, Brick, Talkabout, or Course session, along with your User Name. Our Wall Guides do not have access to your Personal Information.

 

 

Retention and Destruction of Personal Information

 

 

We will retain your Personal Information for three years after your Membership expires. After that time, we delete or securely destroy it in accordance with our document retention policies.

 

 

Accessing Your Personal Information

 

 

While you are a Member, you may login to the Site at any time to view your Personal Information. You may update your email address at any time by logging in and accessing “Account Settings.” If your Membership has expired, you may reactivate it by accessing the Site or communicating with us through the Contact Form for assistance with your access request. We will reactivate your account for two weeks in order for you to access your Personal Information. Please note that information submitted through the Contact Form will be access by members of the Togetherall team who may be located outside of the United States.

 

You may click on your My Profile section and see all the Member Content you have posted in one place. you may also see all your Brick, Talkabout, and Course content by visiting those sections of the Site.

 

 

Cookies

 

 

Our Cookies:

 

Cookies are small pieces of information stored by your browser on your device’s hard drive. We use cookies to allow us to track which pages are viewed on the Site, to determine how frequently particular pages are visited, to determine the most popular areas of the Site, and generally to monitor Site usage. We also use cookies to save a record of access to Courses so we can remind you to complete courses, and to ‘bookmark” Bricks’ positions on the Site. If you wish to disable cookies you can do so by readjusting your browser settings. If you disable cookies you will still be able to use the Site, however you may not be able to use all features of the Site. For more information on cookies and how to disable them, consult the information provided by the Interactive Advertising Bureau www.iab.com.

 

 

Third Party Cookies:

 

 

When using the Site, your browser may receive cookies from third parties including Google, Facebook and AddThis. Using Facebook and AddThis, you can post a link to the Site’s homepage on Facebook. We use Google Analytics and Google Tag Manager to help analyze the use of the Site and improve visitors’ experience. We receive reports from Google containing aggregated data about Site usage for this purpose. Google Analytics creates the reports by using cookies to collect and generate information about your use of the Site. We cannot identify individuals from the Google Analytics reports, and we limit Google’s use of information collected to that which is necessary to provide the service.

 

 

Safeguarding Personal Information and Member Content

 

 

We use appropriate administrative, physical and technical safeguards to protect your Personal Information from loss or theft, unauthorized access, use or disclosure, or modification or destruction. For example, we train our personnel to protect your privacy and require them to comply with our policies and procedures that protect your Personal Information. We use computing systems in secure facilities to store your Personal Information.

 

You also play an important role in protecting your Personal Information and Member Content. For example:

 

• Follow the House Rules to keep your identity confidential;

• Keep your password for the Site confidential – do not to share your password with anyone;

• Use an email account to which only you have access to receive emails and notifications from us;

• If you access the Site from a shared device, remember to log out.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Site; any transmission is at your own risk.

 

 

Sensitive Information; Information About Children

 

 

We do not knowingly collect information about individuals under 16. Please notify us immediately using the Contact Form if you believe someone under 16 is using the Site.

 

Member Content may include sensitive information, such as information about a Member’s health, lifestyle, sexual orientation, or sexual preferences. In accordance with the House Rules, Members may not associate Member Content with information that would make it personally identifiable. We reserve the right to delete Member Content if we believe that it contains Personal Information, but we are not obligated to do so.

 

 

Information for California Residents

 

 

This Privacy Statement is designed to provide a comprehensive description of our practices regarding the collection, use, and disclosure of Personal Information. We update this Privacy Statement at least annually, as indicated by the date of last “Update” appearing at the beginning of the statement. Please note that we do not knowingly collect information about individuals under 16.

 

If you are a California resident:

 

• We do not sell Personal Information, nor do we disclose such information for direct marketing purposes.

 

• You may have the right to make certain requests under the California Consumer Privacy Act (CCPA):

 

o You may have the right to know about Personal Information that we have collected or disclosed:

 

– The categories of personal information we have collected or shared about you in the preceding 12 months,

 

– The categories of sources from which we have collected that information in the preceding 12 months,

 

– The commercial or business reason(s) we have collected or shared that information, and

 

– The categories of third parties with whom we have shared that information in the preceding 12 months.

 

In addition, upon receipt of a verifiable request from you establishing your identity, we may be obligated to disclose specific pieces of personal information that we have collected about you. Under some circumstances, you may have the right to request deletion of Personal Information about you and the right to direct us not to sell that information.

 

You may be entitled to designate an authorized agent to exercise these rights on your behalf.

 

How to exercise your rights under CCPA:

 

• You may login to the Site at any time to view your Personal Information. You may click on your My Profile section and see all the Member Content you have posted in one place. you may also see all your Brick, Talkabout, and Course content by visiting those sections of the Site.

• You may update your email address at any time by logging in and accessing “Account Settings.”

• You can also submit a request to know or delete your Personal Information by using our Contact Form or sending an email to [insert email alias]. We will contact you by email promptly after receipt of your email to let you know the status of your request and, if necessary, to ask for any additional information we need to verify your identity and fulfill your request. Please note that your request may be processed by Togetherall team members located outside of the United States.

 

Please note that, depending on the nature of your request, we may need additional information to verify your identity including, without limitation, name, address, telephone number, and/or email addresses. We will use any information you submit only to fulfill your request. If you would like to designate an authorized agent, we will require you to submit an email or letter with that information, including information that allows us to verify your identity as well as the identity of your agent.

 

We are prohibited by law from treating you in a discriminatory fashion as a result of your election to exercise any rights you have under CCPA.

 

 

Privacy Policy Changes

 

 

Please note that we may update and amend our Privacy Policy from time to time and we will post any changes on the Site. It is your responsibility to check regularly if there have been changes and to review such changes. The “Last Updated” date at the top of the Policy lets you know when the Privacy Policy was last revised.

 

 

Contacting Us

 

 

If you have any questions, concerns or suggestions about our privacy practices, please get in touch with our Privacy Officer using our Contact Form. Your query will be directed to our customer support team. Please remember to protect your privacy if you contact us, e.g., please do provide your Email address, but do not include information about your health, your User Name, or Member Content. Regular email is never a secure method of communication.

 

By clicking “submit” or “I agree” during the registration process or by your continued use of the Site you expressly agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. It should be read in conjunction with the Member Terms and House Rules and any additional applicable terms posted on the Site.

 

This site is not intended for individuals in an emergency. If you are in a life-threatening situation, please immediately dial your country’s emergency number available here, or go to your nearest Emergency Room.

 

 

© Copyright 2020, Togetherall Inc. All rights reserved.

This site is not intended for individuals in an emergency. If you are in a life-threatening situation, please immediately dial your country's emergency number available here, or go to your nearest Accident and Emergency department.

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