Last Revised: MAY 2019
APP4U LLC and its affiliates (“APP4U“, “we” or “us“) is committed to protecting the privacy of the users of its website at the address www.APP4U.com or any other website managed and controlled by APP4U (the “Site“) and its online products, including Towed, Towed Mobile, CATS and WhoTowedMe (each a “Service” and collectively the “Services“).
A User may be either an entity which executed an agreement with APP4U or with APP4U’s resellers or distributors who provide APP4U’s Services (“Customer“) or Customer’s users of the Services (“End User(s)“) or visitors of the Site (collectively “Users” or “you“).
This Policy explains the types of information we may collect from you or that you may provide when you visit the Site or use the Services and our practices for collecting, using, maintaining, protecting, and disclosing that information.
GENERAL (THIS SECTION APPLIES FOR ALL SERVICES)
Please refer to the specific Section(s) about the Site or Services you use or plan to use for a complete review of the relevant practices.
CONSENT AND PRINCIPALS OF PROCESSING DATA
APP4U processes data fairly, lawfully, in a transparent manner and in accordance with individuals’ rights (as applicable). The use of information collected through our Services shall be limited to the purpose of providing the service for which our Client has engaged APP4U or, if collected through the website or other marketing means, to APP4U’s legitimate interests, where we have considered these are not overridden by your rights.
Personal Information or Personal Data is information by which an individual may be personally identified, including name, address, e-mail address, telephone number or any other information that is defined as Personal Information, Personal Data, or Personally Identifiable Information under an applicable law (hereinafter referred to as “Personal Information”)
Users are not obligated to provide us with any information by law. However, we require certain information in order to operate properly. Under some jurisdictions (such as under certain E.U. regulations), a User has a right to withdraw its consent at any time. In such a case, the withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
Please note that consent for the gathering and processing of data for one Service does not automatically mean that a User consents to the processing of data in connection with other Services. Controller should always make sure that the User’s consent is relevant, clear, valid, and to the extent reasonably possible, not “bundled” with any other written agreement (especially if required under applicable laws), unambiguous and if required under applicable law, affirmative and active (meaning not by virtue of any inaction).
We do not knowingly collect or solicit information or data from children under the age of 13 or knowingly allow children under the age of 13 to register for the APP4U Service. If you are under 13, do not register or attempt to register for any of the APP4U Service or send any information about yourself to us. If we learn that we have collected or have been sent Personal Information or Personal Data from a child under the age of 13, we reserve the right to delete that Personal Information or Personal Data as soon as reasonably practicable. If you believe that we might have collected or been sent information from a child under the age of 13, please contact our legal@APP4U.com as soon as possible.
We take great care in implementing, enforcing and maintaining the security of our Services, Site and Users’ information. APP4U implements, enforces and maintains security policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Information or Personal Data and to monitor compliance of such policies on an ongoing basis. The information is hosted on the Amazon Cloud in the United States which provides advanced security features and is compliant with the ISO 27001 standard. All information is stored with logical separation from information of other Customers. However, we do not guarantee that unauthorized access will never occur.
We use a combination of processes, technology and physical security controls to help protect Personal Information and Personal Data from unauthorized access, use, or disclosure. When Personal Information or Personal Data is transferred over the Internet, we encrypt it using Transfer Layer Security (TLS) encryption technology or similar technology. Each server is protected by a firewall, exposing it only to the minimum ports necessary. However, no security controls are 100% effective, and we cannot completely ensure or warrant the security of your Personal Information and Personal Data.
Unless otherwise agreed with the Customer and subject to applicable law, APP4U shall act in accordance with its policies to promptly notify Customer in the event that any Personal Information or Personal Data processed by APP4U on behalf of a Customer is lost, stolen, or where there has been any unauthorized access to it.
QUESTIONS, CONTACT INFORMATION AND COMPLAINTS
Please do not hesitate to contact us: info@APP4U.com
This Section specifies the privacy and data retention practices in connection with the App4u.com Website. For a complete view of privacy practices relevant to you, please also read the General Section.
WHAT INFORMATION MAY WE COLLECT ON USERS OF THE SITE AND HOW?
App4u collects the email addresses and login credentials of people who communicate with App4u via email, create accounts or post a public question on the Site Blogs and/or communities. When you post content on or through the Site by way of public posts or survey information etc.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends.
When you use the Site through the mobile web application, we automatically collect information on the type of device you use operating system version.
WHAT ARE THE PURPOSES OF THE COLLECTION OF INFORMATION FROM THE USERS OF THE SITE?
Our primary goals in collecting Personal Information are to provide you with the services made available through the Site, including but not limited to communicating with you and providing you with support and information.
App4u uses the information it collects from you to provide Customers and other Users with the services rendered on the Site and continuously enhance your user experience. Generally speaking, we use the collected information to communicate with you, fulfill your requests, customize the content, improve the website and our products and services, protect our and your rights, administer the website under our terms and for internal operations, including trouble shooting, data analysis, testing, research, statistical and survey purposes; keep the website safe and secure; allow you to participate in interactive features of our service, when you choose to do so; ensure in its legitimate interests that content from the website is presented in the most effective manner for you and for your computer; and comply with laws and regulations.
We may combine information you give us and information we collect. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
App4u may use your Personal Information to send you promotional information and updates regarding App4u and its products and services. We may use your information to tailor advertisements to suit your interests and needs. You may choose not to receive such information and opt-out of such future communications. All such communications sent to you will contain the instructions for opting-out. If you would like to discontinue receiving promotional and updates regarding App4u and its products and services, you may do so by using the “unsubscribe” link found at the bottom of the emails we send to.
In addition to these optional email messages, App4u may contact you via any email address you provide to us with transactional or relationship messages such as account status messages, security updates or notifications of changes in the terms of your account or the App4u Service. These types of transactional or relationship email messages are not optional.
SHARING INFORMATION GATHERED THROUGH THE SITE WITH THIRD PARTIES
Please be aware that information you provide to us or that we obtain as a result of your use of the Site may be processed and transferred in all countries in which App4u has offices and operations and be subject to various applicable laws. This information may also be processed by staff working for us or for one of our suppliers. The privacy and data protection laws in such countries may not be equivalent to the laws in your country of residence. By using our Site, or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to and in such countries.
We may share information we gather as detailed above with service providers as per Section C(i) above, to assist us in providing the services we offer through the website, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists and processing information to our legitimate reasons, analyzing data, providing IT and other support services or in other tasks, from time to time. Further we use analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy.
MODIFICATION OR DELETION OF PERSONAL INFORMATION GATHERED TROUGH THE SITE
Upon request, App4u will provide you with information about whether we hold any of your Personal Information. A User may have a legal right under certain applicable laws (for instance if the User is an E.U. citizen) to receive, rectify, erase, and restrict Personal Information about them that is held by us, to object to processing and, if processing occurs based on consent, to withdraw their consent. Users may also have the right to withdraw consent for processing for statistical and research purposes.
If, for any reason, a User wishes to modify, delete or retrieve his/her Personal Information collected through the website, s/he may do so by contacting App4u at the address detailed below. We shall perform the necessary process to identify the User as a User who has a the right to retrieve the specific information and then we will ask for a specific identification of the User and data (as shall be applicable for the specific Service provided and the requested data – for instance IP address and time of uploading the information to App4u’s servers (IP address is not enough for an identification of User or data)). App4u cannot retrieve data without a specific identification of User and data. App4u may not be able to delete, amend or retrieve User’s information without other Controller’s instructions and authorization (As applicable). We shall make efforts to respond to a User’s request within 90 days however, deletion of data may take longer.
Please note that Personal Information may be either deleted or retained in an aggregated manner, without being linked to any identifiers or Personal Information, depending on technical commercial capability, including without limitation by setting the last octet of IPv4 user IP addresses such that it cannot be linked to any identifiers of the User. Such information may continue to be used by App4u for the purpose of operating the Service.
For any request or question regarding deletion or amendment of User data, you can contact our Data Protection Officer at the contact details listed in the General Section and we shall make efforts to respond and support your request within no more than 30 days.
App4u will retain data it processes on behalf of its Clients only for as long as required to provide the Services to its Client and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements. For Users of the Site which are not Users of any other Service, the Information gathered through the Site shall not be retained for more than 7 years (for backup and litigation purposes) and shall be deleted within 90 days upon request by a user (as technically possible).
TRACKING, COOKIES & PASSIVE COLLECTION THROUGH THE SITE
App4u, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Site on an ongoing basis, and in order to provide our Customers and their Users with a better experience (for instance in order to track Users’ preferences, to better secure our Services, to identify technical issues and to monitor and improve the overall performance of our Site).
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) stored on your device. By default, we use several persistent cookies for purposes of session authentication, monitoring performance of our services and generally providing and improving our Site.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies (we store the cookies only on the designated place for cookies determined by your browser). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Site or may otherwise adversely affect your user experience.
The cookies used by the Site do not include any Personal Information about you, other than a random persistent identifier. The cookies are retained either for as long as your session with the Site exist or for a longer period of time but only for the time period required by the Site.
Beacons/Pixels: We and certain third-party Services may employ a software technology called Web Beacons/Web Bugs or Pixels which enables them and us to improve our Site by measuring effectiveness and performance. Beacons/Pixels are tiny graphics with a unique identifier, similar in function to cookies.
Some web browsers may transmit Do Not Track signals to websites with which the browser communicates, telling the site not to follow its online movements. Because of differences in how web browsers interpret this feature, it is not always clear whether Users intend for these signals to be transmitted, or whether they are even aware of them. Therefore, we currently do not respond to such Do Not Track signals.
If you wish not to have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note that this does not opt you out of being served ads. You will continue to receive generic ads.
THIRD-PARTY LINKS AND WIDGETS
Occasionally, at our discretion, we may include links to third parties. Be sure to read the privacy policies, supplemental notices, and settings of all websites or platforms that you visit so you can understand their privacy practices and your options. These third-party sites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these sites.
This section details the privacy practices in connection with Towed, Towed Mobile, CATS and WhoTowedMe. For a complete view of privacy practices relevant to you, please also read the General Section.
WHAT INFORMATION MAY WE COLLECT ON USERS OF APP4U SERVICES?
- Categories of information and data we may collect from our Users.
- Passive Collection. Passively Collected Information means any information which is available to App4u while Users are using the Service. Passively Collected Information consists of technical information and behavioral information (i.e. the interaction of the User with the Service).
- App4u may also collect the email addresses of people who communicate with App4u via email or create accounts and login credentials.
HOW DO WE COLLECT INFORMATION ON USERS OF APP4U SERVICES?
- Automatic Collection of Information. When You use the Service we gather, collect and record the information relating to such usage.
- Information You Provide to Us. You provide us information, including Personal Information, when you communicate with us, including for instance providing Your email when you contact support.
WHAT ARE THE PURPOSES OF THE COLLECTION OF INFORMATION IN THE APP4U SERVICES?
- Passively Collected Information is collected in order to:
- Provide Customers with the Service;
- For customization and improvement of the Service.
- Personal Information is collected in order to:
- Provide Customers with the Service;
- Contacting Users and/or customers for the purpose of providing them with technical assistance and other related information about the Service;
- Replying to User’s queries;
- Troubleshooting problems, detecting and protecting against error, fraud or other criminal activity.
- For risk control, to comply with laws and regulations, and to comply with other legal processes and law enforcement requirements.
SHARING INFORMATION GATHERED THROUGH APP4U SERVICES WITH THIRD PARTIES
MODIFICATION OR DELETION OF PERSONAL INFORMATION GATHERED THROUGH THE APP4U SERVICES
If, for any reason, a User wishes to modify, delete or retrieve his/her Personal Information, s/he may do so by contacting the applicable Controller (as defined in the General Section or provided herein) (e.g. the provider of the platform on which the App4u System™ is operating). The Controller shall perform the necessary process to identify the User as a User who has a the right to retrieve the specific information and then furnish to App4u the data required to be amended, deleted or retrieved together with a specific identification of the User and data (as shall be applicable for the specific Service provided and the requested data – for instance IP address and time of uploading the information to App4u’s servers (IP address is not enough for an identification of User or data)). App4u cannot retrieve data without a specific identification of User and data. App4u may not be able to delete, amend or retrieve User’s information without the Controller’s instructions and authorization.
Please note that Personal Information may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Information, depending on technical commercial capability, including without limitation by setting the last octet of IPv4 user IP addresses such that it cannot be linked to any identifiers of the User. Such information may continue to be used by App4u for the purpose of operating the Service or for its legitimate interest without derogating from users’ rights.
For any request or question regarding deletion or amendment of User data, you can contact us at the contact details listed in the General Section and we shall make efforts to respond and support your request.
DATA RETENTION – APP4U SERVICES
Any Customer may request information regarding the storage and retention of data (“Audit”) by contacting us. App4u shall make reasonable efforts to respond to the Audit in a reasonable time and subject to applicable law and to the protection of App4u’s trade secrets.
App4u will retain data it processes on behalf of its Customers only for as long as required to provide the Service to its Customers and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements.
Unless otherwise agreed in writing with the Customer, after a request from the Customer to delete any data or termination or expiration of the agreement with the Customer, an automated process will begin that permanently deletes the data in accordance with the timelines set forth in the tables below. Once initiated, this process cannot be reversed and data will be permanently deleted.
|Type||Timeline for Deletion (after deletion process begins) for Cancellation, Termination or Migration|
|Access Logs||2 years|
|Data in Analytics Platform||90 days|
COOKIES & PASSIVE COLLECTION WITH APP4U SERVICES
When you access or use the Service, App4u may use industry-wide technologies such as cookies or similar technologies, which store certain information on your computer (“Local Storage“) and which will allow the system to enable automatic return to a stage or page you visited and make your Service experience much more convenient and personalized. The cookies used by the Service do not include any Personal Information about you, other than a random persistent identifier, unless configured otherwise by the Customer.
The cookies are retained only for the time period required by the Service (according to Customer’s requirements and settings) but in any event not more than 2 years from cessation of use of the Service by the Customer (older versions of the system may include cookies stored for a longer period of time).
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Please note that deleting our cookies or disabling future cookies may prevent you from accessing certain areas or features of our Services or may otherwise adversely affect your user experience.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
We may use third-party software and/or services in order to collect and/or process the information detailed herein. Such software includes without limitation:
|Amazon Web Services Inc.||United States||Hosting infrastructure services||https://aws.amazon.com/privacy|