Privacy Policy

For most of us, our cars are the second largest purchases we will make in our lifetimes after our homes. Taking precautions to protect these investments is important to us all. At Throdle, we understand that drivers are sensitive about data that relates to them and their cars circulating online. We have taken every precaution across our platform to safeguard your data, online privacy, your location and the location of your car(s) to ensure you can feel comfortable posting to Throdle.

As part of our ongoing commitment to privacy, transparency and the requirements of the EU General Data Protection Regulation (GDPR), we have updated our privacy policy, which will be posted on this page for everyone to see and understand what information we collect, why we collect it, and how we use it.

Here are a few highlights:

Our EU users: The General Data Protection Regulations (“GDPR”) places new obligations on companies offering services to people in the European Union. Our Privacy Policy addresses specific GDPR obligations.

Global Presence. Our updated policy addresses the new standards put in place by the GDPR, but we are rolling it out globally. All users deserve to have their data protected and understand how it’s being used.

We will continue to evaluate and enhance our policies in order to give you the best experience possible.

OUR COMMITMENT TO YOU

At Throdle, your privacy is our top priority and at the core of how we design and build the services that bring drivers together. Our secure by design ethos means you can fully trust us and focus on building connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not take chances with your privacy. Each product and service is designed from the ground up with security in mind, rather than retrospectively making a product secure. Having leadership that understands security, both virtual and physical ensures that we take the right precautions to maintain our security posture.

We involve experts from across the business to ensure that we make cohesive decisions with security in mind pertinent to all aspects of our platform and business.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure.
Information Security requires an ongoing commitment and focus. The threat landscape changes day by day and ensuring we have the tools, expertise and resources to monitor, detect, analyze and respond to threats is of primary importance to us. We work hard to continually enhance our technology and processes to achieve a heightened level of information security.

PRIVACY POLICY

Welcome to Throdle’s Privacy Policy.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

1. WHO WE ARE

2. WHERE THIS PRIVACY POLICY APPLIES

3. INFORMATION WE COLLECT

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

5. HOW WE USE INFORMATION

6. HOW WE SHARE INFORMATION

7. CROSS-BORDER DATA TRANSFERS

8. YOUR RIGHTS

9. RESIDENTS OF CALIFORNIA

10. HOW WE PROTECT YOUR INFORMATION

11. HOW LONG WE RETAIN YOUR INFORMATION

12. CHILDREN'S PRIVACY

13. PRIVACY POLICY CHANGES

14. HOW TO CONTACT US

1. WHO WE ARE

The company that is responsible for your information under this Privacy Policy (the "data controller") is:

Throdle Inc,
1510 Fashion Island Blvd - Suite #300

San Mateo, CA 94404, USA

2. WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to websites, apps, events and other services operated by Throdle. For simplicity, we refer to all of these as our "services" in this Privacy Policy. To make it extra clear, we have added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.

3. INFORMATION WE COLLECT

Fully benefitting from Throdle’s services will inevitably mean we will need to capture some information about you. We will capture some basic profile details as well as details about the cars you have owned. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

Information you give us

You choose to give us certain information when using our services. This includes:

· When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work and offer you an enjoyable experience, such as your email or mobile phone number, your city name and username, and favorite car brands.

· A critical part of your profile relates to the virtual garage and the cars you own or have owned in the past. We ask that you add as many of these cars to your profile as possible to increase the chances of forming new and interesting connections. The virtual garage will capture the car’s make, model, year, trim, color, transmission type, any modifications made and a description, as well as purchase date and sold dates, pictures and a license plate number. Much of the information is optional and left to the user’s discretion.

· When you build your profile you may add certain content, like pictures or videos. You may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered "special" or "sensitive" in certain jurisdictions, for example, your car license plate number (optional). By choosing to provide this information, you consent to our collection and retention of that information.

· When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.

· When you participate in surveys or focus groups, you provide us your insights into various products and services, responses to questions, and testimonials.

· When you choose to participate in promotions, events or contests, we collect the information that you use to register or enter in such promotions, events or contests.

· If you contact our customer care team, we collect the information you give us during the interaction. We may monitor or record these interactions for training purposes and to ensure a high quality of service.

· Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

· Other Users
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

· Social Media
You may be able to use your social media login (such as Facebook Login) to create and log into your Throdle account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.

· Other Partners
We may receive info about you from our partners, for instance when Throdle accounts can be created through a partner's websites (in which case they pass along registration information to us) or where Throdle ads are published on a partner's websites and platforms (in which case they may pass along details on a campaign's success).

Information collected when you use our services

When you use our services, we collect information about which features you've used, how you've used them and the devices you use to access our services. See below for more details:

Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you've been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive), how frequently you post and what you post.

Device information
We collect information from and about the device(s) you use to access our services, including:

· hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google's AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device' settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);

· information on your wireless and mobile network connection, like your service provider and signal strength;

· information on device sensors such as accelerometers, gyroscopes and compasses.

· Other information with your consent - If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you're using, including GPS, Bluetooth or WiFi connections. The collection of your geolocation may occur in the background even when you aren't using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.

Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may request our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a "Do Not Track" ("DNT") feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Throdle, do not currently respond to DNT signals.

5. HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you

· Create and manage your account

· Provide you with customer support and respond to your requests

· Complete your transactions

· Communicate with you about our services, including order management and billing

To help you connect with other users

· Analyze your profile and that of other users to recommend meaningful connections

· Show users' profiles to one another

To ensure a consistent experience across your devices

· Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To improve our services and develop new ones

· Administer focus groups and surveys

· Conduct research and analysis of users' behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users' behavior)

· Develop new features and services (for example, we may decide to build a new interests-based feature to further requests received from users).

To prevent, detect and fight fraud or other illegal or unauthorized activities

· Address ongoing or alleged misbehavior on and off-platform

· Perform data analysis to better understand and design countermeasures against these activities

· Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

· Comply with legal requirements

· Assist law enforcement

· Enforce or exercise our rights, for example our Terms

To process your information as described above, we rely on the following legal bases:

· Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.

· Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users' behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.

· Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

6. HOW WE SHARE INFORMATION

Since our goal is to help you make meaningful connections, the main sharing of users' information is, of course, with other users. We also share some users' information with service providers and partners who assist us in operating the services, and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

· With other users
You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. You have the opportunity to create a private profile ensuring only those you accept can view your information, nevertheless, you control what is visible.

If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your account settings.

· With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

· For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, receivership, bankruptcy or other change of ownership or control.

· When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

· To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

· With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in deidentified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Match Group companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy, which is available upon request.

7. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area ("EEA"), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

8. YOUR RIGHTS

We want you to be in control of your information, so we have provided you with the following tools:

· Access / Update tools in the service

Tools and account settings that help you to access, rectify or delete information that you provided to us and that's associated with your account directly within the service. If you have any questions regarding those tools and settings, please contact our customer care team for help by emailing us at admin@throdle.com.

· Device permissions

Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

· Deletion

You can delete your account by using the corresponding functionality directly on the service.

We want you to be aware of your privacy rights. Here are a few key points to remember:

· Reviewing your information

Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request by emailing us at admin@throdle.com.

· Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us by emailing us at admin@throdle.com.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your email address or mobile phone number.

· Uninstall

You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

· Accountability

In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

9. RESIDENTS OF CALIFORNIA

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

10. HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately by emailing us at admin@throdle.com. You can also exercise your rights to opt out by using our Opt Out Link.

11. HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5 and as permitted by applicable law).

In practice, we delete or anonymize your information upon deletion of your account or after two years of continuous inactivity, unless:

1. we must keep it to comply with applicable law;

2. we must keep it to evidence our compliance with applicable law;

3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints

12. CHILDREN'S PRIVACY

Our services are restricted to users who are 16 years of age or older. We do not permit users under the age of 16 on our platform and we do not knowingly collect personal information from anyone under the age of 16. If you suspect that a user is under the age of 16, please contact us immediately by emailing us at admin@throdle.com.

13. PRIVACY POLICY CHANGES

Because we are always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

14. HOW TO CONTACT US

If you have questions about this Privacy Policy, please email us: info@throdle.com