Last modified: February 23, 2017
2. We have strict policies and procedures to protect Your information from being disclosed to unauthorized parties. We safeguard Your information in accordance with industry standard procedures and security standards and We maintain physical, electronic and procedural safeguards to protect Your personal information. Additionally, We continually assess new technologies to ensure that We are taking reasonable steps to protect Our records.
4. We hope that the information below provides You with a better understanding of Our strict privacy protection policies. Please note that 2ndLine reserves the right to modify these policies at any time. We invite You to periodically consult this section for possible updates and changes.
5. We are responsible for the personal information under Our control, including,but not limited to, information that has been transferred to a third party for processing (if applicable).
6. We have designated a Privacy Officer who is responsible for Our compliance with this policy and with privacy legislation. If You wish to contact Our Privacy Officer, You may contact them through one of the following means:
Post: TextNow, Inc.
375 Hagey Blvd., Suite 310
7. We may collect the following types of information:
(a) Registration Information: When You sign up for a user account for any of the Services, We collect personal information, such as Your name, and email address and telephone number.
(b) IP Information: In general, We collect and use anonymous information and data regarding Your access and use of the Services. When You visit the Services via a browser, Our servers record the information that Your browser automatically sends whenever visiting or using any of Our websites (“Websites”), including Your web request, the Internet Protocol address and browser configuration of Your computer, the date and time of Your request, the uniform resource locator of the referring and/or exiting websites.
(c) Cookies and Analytical Tracking: Sometimes We use cookie technology, web beacons and other similar devices on Our Websites to enhance functionality and navigation for our visitors and portions of Our Websites may use statistical tools that may be operated by third party providers (collectively, the “Analytical Tools”). Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of a Website a user visits; and (iv) other websites a user visited before visiting one of the Websites. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may be unable to access some customized features on the Websites. Cookies do not collect or contain your personal information.
Internet tags, graphic tags and similar web beacon type functions allow Us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on the Websites to count users and to recognize users by accessing our cookies. Being able to access our cookies allows Us to personalize the Websites and improve your experience at the Websites. We may also include web beacons in HTML-formatted e-mail messages that We send to determine which e-mail messages were opened. Like cookies, web beacons do not collect or contain your personal information.
In the case of Analytical Tools, the information generated by the cookies and/or web beacons about your use of the Websites (including your IP address) will be transmitted to and stored on servers located outside of Canada including, but not limited to, the United States, by the applicable third party provider of an Analytical Tool. This information will be used for the purpose of evaluating your use of the Websites, compiling reports on Websites activity and providing other services relating to Websites activity and Internet usage. The third party providers of Analytical Tools may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf.
By using a Website, you consent to the processing of data about you by third party providers of Analytical Tools in the manner and for the purposes set out above.
(d) Information that You Provide: We may occasionally request from You or You may otherwise voluntarily provide Us with information that personally identifies You (including, but not limited to, downloads, product or service purchases, user support, contests, feedback, surveys and forums). We may receive personal information about You from a broad range of activities through the Services, including, but not limited to, Your inputs to the Services and general correspondence with Us. Depending on the service used, the personal information We collect may include contact information and demographic information, such as email address, phone number, display name and information about Your Device, as defined below, including, but not limited to, its unique identifier number.
(e) User communications: When You send email or other communications to US, We may retain those communications in order to process Your inquiries, respond to Your requests and improve the Services. Some of the Services may be used to send messages and/or other content between other users of the Services or to third parties. If You send a message and/or other content to another user of the Services, We will retain that message and/or other content on Your behalf and will disclose that message and/or content to such user. When You send and receive SMS, MMS or other messages to or from one of Our services that provides SMS, and/or MMS functionality, We may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction.
(g) Non-personal information may be collected and shared with third parties for the purpose of tailoring advertising on other applications or websites. If you choose to opt-out of the sharing of non-personal information you may contact our Privacy Offer as noted in section 6 and we will take commercially reasonable steps to accommodate such request.
9. You can choose not to provide Us with certain information in some situations. 2ndLine will not, as a condition of the supply of the Services, require an individual to consent to the collection, use, or disclosure of information beyond that is required to fulfill the explicitly specified and legitimate purposes. However, if You choose not to provide Us with certain information, We may not be able to provide You with certain, or all of, the Services or information.
11. In general, We collect and use Your personal information to:
o provide and improve the Services to You and other users of the Services;
o protect the rights or property of 2ndLine or other users of the Services;
o maintain commercial relations and to communicate with our Services (which will include, but not be limited to, advertising, promotion and account verification);
o respond more accurately and efficiently to Your requests;
o protect against fraud;
o manage and develop 2ndLine's business and operations; and
o meet legal and regulatory requirements.
12. We may use Your email address to communicate with You about Our services. We may also keep and use anonymous aggregate statistics that do not personally identify You for various purposes including, but not limited to, analysis and reporting of usage patterns.
13. Our servers are located in the United States. Accordingly, in connection with providing You with the Services, Your personal information will be processed and stored in the United States and the governments, courts law enforcement or regulatory agencies of which may be able to obtain disclosure of Your personal information through the laws of the United States. If You are a resident of the European Economic Area, Your personal information will be transferred outside of the European Economic Area for processing and storage on 2ndLine's behalf or to facilitate the use or functioning of the Services.
14. We only share personal information with other companies or individuals outside of 2ndLine in the following limited circumstances:
(a) With Your Consent: When We have Your consent. We require opt-in consent for the sharing of any sensitive personal information.
(b) Legal or other compulsion: In certain circumstances We may disclose personal information where We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request; (ii) enforce applicable terms or use, license or other agreements applicable to the Services, including investigation of potential violations thereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; or (iv) protect against imminent harm to the rights, property or safety of 2ndLine, its users or the public as required or permitted by law.
(d) Aggregate Information: We reserve the right to use and disclose anonymous aggregate statistics for any purpose and to any third party in Our sole discretion.
15. From time to time We may employ third parties to help Us provide or improve the Services. These third parties may have limited access to databases of user information or registered member information of a Service solely for the purpose of helping Us provide or improve such Services and they will not be able to use the information about Our members or visitors for any other purpose.
17. We will retain personal information that has been used to make a decision about an individual long enough to allow the individual access to the information after the decision has been made, and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under applicable law.
18. In the event that Your personal information that is in Our control is to be transferred to a third party for processing, 2ndLine will use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
19. We have deployed a variety of technology and security features to ensure the privacy of personal and anonymous information on Our system. We use procedural and technical safeguards to protect Your personal information against loss or theft, as well as against unauthorized access or disclosure, to protect Your privacy, including firewalls and encryption. We employ many different security techniques to protect such data from unauthorized access by users inside and outside 2ndLine.
21. The Services may include advertisements regarding or otherwise contain hyperlinks to other websites, including those of Our business partners, vendors and advertisers. Advertisements for third parties and their products may be included with the Services and those third party advertisements and web sites may include a cookie, web beacons, or other device(s) of the third party. We do not have control over the cookies, web beacons, or other devices used by third parties and do not have access to whatever information they may collect. You acknowledge and agree We are not responsible for the content or for the privacy practices employed by third parties.
22. Upon written request, We will make readily available to You specific information about Our policies and practices relating to the management of personal information, other than confidential commercial information.
23. We make good faith efforts to provide You with access to Your personal information that We have retained and either to correct this data if it is inaccurate or to delete such data at Your request if it is not otherwise required to be retained by law or for legitimate business purposes.
24. Upon appropriate request, We will usually be glad to update or amend Your personal information that We have retained, but We reserve the right to use information obtained previously to verify Your identity or take other actions that We believe are appropriate.