Translocality (“Translocality”) cares about your privacy and wishes to share the steps it takes to protect your information in compliance with data privacy laws and best practices. The policy below describes: (1) what information may be collected; (2) how such information may be used; and (3) your rights as a visitor or user of this site or any of Translocality’s apps regarding such information. This Privacy Policy applies to all information collected or submitted on Translocality’s website and our apps for iOS and any other devices and platforms (collectively, the “Site”). Translocality uses this information to deliver the services offered on the Site, to inform you of changes to the Site or your account, to prevent illegal or potentially prohibited conduct, and to enforce our Terms of Use (the “Terms”), which incorporate this Privacy Policy by reference.

Before you use the Site we encourage you to read the entire Privacy Policy which is summarized as:

Please Read the Entire Policy

This Privacy Policy governs Translocality’s information management policies including how Translocality gathers, stores or shares your information, if at all. Notwithstanding anything to the contrary, this Privacy Policy does not apply to information that is gathered or collected offline. By using the Site and by submitting information to Translocality, you agree to the practices described in this Privacy Policy and to any other applicable terms, including the Terms. This Privacy Policy is intended to provide you with a clear explanation of how, when and why we collect and use your personal information, as well as an explanation of your legal rights. Nothing in this policy is intended to override the terms of any contract you have with us or any rights you have under applicable data privacy laws.

Please read the entire policy and make sure you fully understand our practices before using our services. If you do not agree with our practices you must immediately leave the Site. If you have any questions after fully reading the policy, please contact us at: [email protected]

Information We Collect

We collect two types of information from visitors. The first, unidentified and non-identifiable information (“Anonymous Information”) does not enable Translocality to identify the visitor from whom it was collected. The Anonymous Information collected by Translocality consists of (1) the date, time and length of your visit, including how much content you viewed (in the aggregate); (2) your Internet browser, operating system or Internet service provider; (3) what parts of the website or app you used and for how long; and (4) the referring site, advertisement or email linking to and from the Site. Translocality may, from time to time, also collect information regarding your wireless device (if any). We may collect information about your wireless device and your wireless communications carrier. Translocality may aggregate, use and share Anonymous Information with third parties for marketing and advertising purposes.

Our Site does not require any personal information to be accessed. However, you have the option to sign up for our email newsletter, which we use to send infrequent announcements about new products and major updates. Your email address is individually identifiable information, meaning information that can identify an individual or may, with reasonable efforts, lead to the identification of an individual (“PII”). If any Anonymous Information is linked to PII, it is treated as PII as long as the connection exists. You may request to be removed from email lists and to have your PII destroyed by sending an email to [email protected].

How is Information Collected?

Translocality collects information about you only if we have a reason for such collection, such as to provide the services, email updates, or to improve our Site. Information is collected in three ways:

a. Information collected automatically through accessing the Site.

When you visit the Site (or any website), your actions while you browse the Site, upload information, download information, or access any links, either directly through the Site or with the help of any third-party services such as cookies, are tracked. Learn more about how we use cookies and third-party services in Section 7 below.

b. Information you provide Translocality.

When you provide your email address, we are collecting your PII. We also store all communications you have directly with us (such as emails).

c. Information obtained from outside sources.

You can learn about these practices in Section 7 below.

Why is Information Collected?

We use the information we collect (both Anonymous Information and PII) to operate and improve our website, apps, and customer support.

We may share anonymous, aggregate statistics with outside parties, such as how many people have read the content in the Translocality mobile applications.

In the future, we may sell to, buy, merge with, or partner with other businesses. In such transactions, user information may be among the transferred assets.

Translocality will not sell, license, rent, or otherwise disclose your PII except as stated herein, or under the following circumstances: (1) you have given your consent; (2) we previously notified you of the disclosure in this Privacy Policy or when you provided your information on the Site; (3) we are compelled by law, legal process, or court order to disclose; (4) disclosure is required to identify, contact, or bring legal action against someone who may cause harm to, or interference with, Translocality’s rights or property, our users, or anyone else; or (5) to respond to an inquiry, request or complaint that you have made. Translocality may cooperate with Internet service providers to identify users whenever required to comply with law, to enforce compliance with this Privacy Policy or our Terms, or to protect the Site, our customers and others.

Where is Information Stored?

Translocality uses industry standard technologies to safeguard your data (both Anonymous Data and PII) from unauthorized use and disclosure and to prohibit security breaches of the Site. Unfortunately, no website, computer system or online communication is completely secure. Translocality cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Site is at your own risk.

If applicable, Translocality will take commercially reasonable steps to use heightened security technologies to protect the transmission and storage of transactional information to the Site. Such heightened security measures may include the secure transmission and encryption of all supplied sensitive financial or other transaction-related information. Such information will only be accessible by authorized individuals with special access rights to our payment systems. Unless otherwise specified, whenever you make a purchase, your financial and other transaction-related information will only be used to process your transaction and will not be stored on our servers or used for marketing purposes.

Data will be maintained, processed and stored by Translocality in the United States of America or other jurisdictions, as necessary.

Requesting Deletion of Your Information and Your Rights

Upon written request Translocality will provide you with information about whether we hold any of your PII. You may access, correct, or request deletion of your PII by emailing: [email protected]. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.

Please note that permanently deleting your PII erases all of your information from our system. After completing this process your PII will be removed permanently, and Translocality will not be able to restore it or retrieve your data in the future.

If you are located in countries that fall under the scope of the European General Data Protection Regulation (“GDPR”), data protection laws give you rights with respect to your personal data, subject to exemptions provided by law. These rights include:

Translocality strives to provide these rights to all visitors and users. Please email us at [email protected] with any requests, questions, or concerns.

Cookies and Third-Party Providers

Some features and advertisements on the Site may contain “cookies” or similar-tracking technologies. A cookie is a small data file stored by your Internet browser, provided that your computer is set to accept cookies. Cookies help improve the user experience by identifying and gathering information about a user, their browser and preferences for websites they have already visited. The use of cookies allows us to better understand how our users interact with the Site so we can work to improve your user experience.

Most modern Internet browsers allow you to change your settings to prevent the storage of new cookies, receive warnings prior to their storage, or to delete cookies from your computer altogether. Please review your browser’s instructions for more information or visit http://www.cookiecentral.com/faq. Please be aware that if you choose to disable cookies, some portions of the Site may cease functioning properly.

Translocality does not and cannot control cookies in advertisements placed by our authorized advertising partners. This Privacy Policy does not govern the privacy practices of third parties who gather information directly from you to provide advertisements on this Site and other websites. The Site may embed or contain links and advertisements for third party websites. Similarly, third-party websites may embed or contain links and advertisements for the Site. Translocality cannot control and is not responsible for the privacy practices or content on any non- Translocality websites. Translocality is therefore not liable for your use of and exposure to such third-party websites and any content or advertisements they contain. You should familiarize yourself with the privacy policies and terms of use of these third parties to better understand their information management policies.

If you choose to opt in to receive communications from a third party, any information you provide to said third party, will be subject to the privacy policy of the third party. If you later decide to opt out, you should contact the third party directly.

Where permitted by local data laws, Translocality may disclose or otherwise allow others to access your PII pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable law. If we have a good faith belief that the law requires disclosure, we may disclose your PII, with or without notice to you.

Children and Privacy

We never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13. Translocality is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. § 6501, et seq.

Translocality does not and will not knowingly request, collect, store, maintain, or share any personally identifiable information of children under the age of 13, without first obtaining the consent of a legal guardian. In those limited instances, Translocality will only collect reasonably necessary information, and will not share with third parties any personally identifiable information of a child under the age of 13 without the explicit consent of a legal guardian, or as permitted by COPPA or other applicable law.

You may revoke your consent and request the removal of your child’s information at any time. If you are the legal guardian of a child under the age of 13 and discover that your child has submitted their personally identifiable information without securing your consent, Translocality will use commercially reasonable efforts to remove this information. If at any point you wish to review, amend, or request the removal of your child’s information, please send an e-mail to [email protected] and provide the name and account information for your child’s user account.

California Compliance

We comply with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent. California Civil Code Section 1798.83 permits users who are California residents and who have provided with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, or how the Translocality reviews and processes any request from you to amend your personal information, please contact us at [email protected]

Changes to this policy

If we decide to change our Privacy Policy, at our sole discretion, we will post those changes prominently on this page and may choose to update the Privacy Policy modification date below. Any changes to the Privacy Policy will be effective as of the date it was posted. Your continued use of the Site after Translocality posts any modifications to the Privacy Policy shall be deemed your explicit acceptance of those modifications and shall constitute your agreement to comply with the Privacy Policy, as modified.

Contacting Us

If you have questions regarding this privacy policy, you may email [email protected]

Last modified: 2020-09