Welcome to Townsquare. We are happy to have you. 

Last Updated: April 20th, 2022

 

1. Introduction

At Townsquare (referred to as “Townsquare”, “Townsquare mtl”, “we” or “us”), we understand that you want transparency about how we process your personal data. This Privacy Policy contains information about your privacy and your rights. We know there are a lot of privacy policies to read, but we encourage you to take the time to read them before you use Townsquare.

This Privacy Policy (“Privacy Policy”) describes how Townsquare will gather, use, and maintain your Personal Information on the TownsquarePlatform. It will also explain your legal rights with respect to that information.

By using the Townsquare Platform, you confirm that you have read and understand this Privacy Policy (together referred to herein as the “Agreement”). The Agreement governs the use of the Townsquare Platform. Townsquare will collect, use, and maintain information consistent with the Agreement.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.

 

2. General Terms

In this Privacy Policy:​

  • We call a user of the Townsquare Platform “User,” “Users,” “you,” “your,” or “Client” and “Hired Helper” as appropriate.

  • The community platform that we offer at our website (www.townsquaremtl.com) is referred to as the “Site(s).”

  • The mobile applications (whether on iOS or Android) are referred to as the “Apps.”

  • Townsquare’s Sites, Apps and related services, information and communications are collectively referred to as the “Townsquare Platform.”

  • “Terms of Service” refers to our Terms of Service, which can be found here. This Privacy Policy is incorporated into, and considered a part of, the Terms of Service.

3. Information Collection

Townsquare collects certain personally identifiable information about you, including information that can identify, relate to, describe, be associated with you, or is reasonably capable of being associated with you (“Personal Information”). Examples of Personal Information that Townsquare collects include but are not limited to:

Contact Information. This may include your first and last name, postal address, telephone number, and email address.

Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.

Identity Information. If you are a Hired Helper, Business, or Mentor we may collect Personal Information, such as your date of birth and address, national identification number if applicable, together with the result of basic criminal record checks as provided by you, or by our Third-Party Agents (as defined below), as applicable and to the extent permitted by law in your jurisdiction, as well as such information as may be needed to validate your identity.

Financial Information. To help Hired Helpers set up a payment account and help Clients make payments to Hired Helpers and pay fees to Townsquare, we may collect financial information, including credit card number, bank routing numbers, tax information, taxpayer identification number, and other payment information, as applicable. We use Financial Information in order to operate the Townsquare Platform and to ensure that Hired Helpers, businesses and Mentors are paid by Clients. We do this as necessary for our legitimate interests in providing our platform and services and to fulfill our contracts with Users. To keep your financial data secure, we have contracted with a third party to maintain and process your payment information.

Promotional Information. Certain offerings of the Townsquare Platform, such as newsletters, surveys, contests, and the like are optional and so you are not required to enter them or to give us your data in connection with them. Where you do consent to take advantage of Townsquare Platform offerings, we will use your data to (as applicable) send you newsletters and other communications that are tailored based on information we have about you, or to operate and manage the survey, contest or similar offering in connection with our legitimate interest in promoting our business and the Townsquare Platform. To opt-out of receiving marketing communications from us, please see Section 7, Your Rights and Choices.

Employment Information. We collect employment and education history, transcripts, writing samples, and references as necessary to consider your job application for open positions.

Content Information. You also may choose to send Townsquare Personal Information in an email or chat message containing inquiries about the Townsquare Platform and we use this information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the Townsquare Platform (such as through our chat functionality).

We require that you furnish certain information when you register an account with us in order to provide services through the Townsquare Platform. For example, if you are a Client, we collect your first and last name, email address, and your zip or postal code in order to create and administer your Townsquare account. We also collect additional information in order to facilitate your booking request, such as information about the task you are seeking, the time, date and location of the Hired task, and Billing Data. If you are a Hired Helper, Business or Mentor we collect your first and last name, email address, mobile phone number and zip or postal code in order to create and administer your Townsquare account and facilitate communications between you and your Clients through the Townsquare Platform. We also collect information about your jobs, and skills, as well as Identity Information and Financial Information.

4. Information Townsquare Collects Automatically

We automatically collect certain information when you use the Townsquare Platform. The categories of information we automatically collect and have collected, including in the last 12 months, are as follows:

Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, portions of the Townsquare Platform that you view and interact with, the time of day you browse, and your referring and exiting pages.

Device Data, including data about the type of device or browser you use, your device’s operating system, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the Townsquare Platform, Townsquare may collect certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you use, and information about the way you use the Townsquare Platform (“Device Information”). We may use Device Information to monitor the geographic regions from which Users navigate the Townsquare Platform, and for security and fraud prevention purposes. Use of any IP-masking technologies or similar technologies (like the TOR network) may render portions of the Townsquare Platform unavailable and are forbidden on the Townsquare Platform.

Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and, with your consent, precise location data (such as latitude/longitude data). When you visit the Townsquare Platform via a native mobile application, we use, with your consent when required under applicable law, GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a relevant location map. We will not share your current location obtained in this manner with other Users.

Cookies and similar technologies are described in our Cookie Policy, which sets out the different categories of cookies and similar technologies that the Townsquare Platform uses and why we use them.

5. Townsquare Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

  • To operate and make available the Townsquare Platform. We use your data to connect you with other Users to enable the posting of, selection for, completion of, and payment for Hired Tasks, in order to fulfill our contracts with Users;

  • For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which Clients and Hired Helpers can meet and conduct business, and in order to comply with our legal obligations;

  • To conduct identification and criminal background checks, if applicable and to the extent permitted by local law, on Users, in order to advance our legitimate interests as well as for the substantial public interest of ensuring the safety of our Users both online and offline, preventing or detecting unlawful acts, protecting the public against dishonesty, and maintaining the integrity of the Townsquare Platform given that Hired Helpers often interact directly with Clients and may enter their homes;

  • To analyze Townsquare Platform usage as necessary for our legitimate interest in improving the Townsquare Platform to grow our business;

  • To contact you and deliver (via email, SMS, push notifications, or otherwise) transactional information, administrative notices, marketing notifications, offers and communications relevant to your use of the Townsquare Platform, with your consent when required under applicable law, as necessary for our legitimate interests in proper communication and engagement with our Users, and in promoting our business;

  • To provide you with customer support in order to fulfill our contracts with Users;

  • For internal market research for our legitimate interest in improving the Townsquare Platform to grow our business;

  • For troubleshooting problems for our legitimate interests in ensuring a safe and secure environment in which Users can meet;

  • To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;

  • To enforce our Terms of Service and our legitimate interests in ensuring our Agreement is complied with;

  • To facilitate the provision of insurance and/or protection offerings to Hired Helpers by Third-Party Agents; and

  • As otherwise set forth in the Agreement.

Interest-Based Advertising. Ads are a standard part of user experience on the Internet, and Townsquare believes that targeted advertising enhances this experience. Townsquare and affiliate third parties may use cookies and other technologies to place ads where they believe interested Users will see them. In addition to banner ads, Townsquare may advertise products, companies and events that we think might interest you through the email address and/or phone number you provide. We may incorporate Tracking Technologies on the Townsquare Platform (including our website and emails) as well as into our ads displayed on other websites and services. Some of these Tracking Technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-Based Advertising”).

For more information and to understand your choices regarding third-party ads, please see our Cookie Policy. Advertising and marketing is carried out as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Analytics and Market Analysis. Townsquare may analyze information (“Market Analysis”) as necessary for our legitimate interests in providing an engaging and relevant experience, and promoting and growing the Townsquare Platform.

Townsquare uses information to offer services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Cell Phone Numbers. Townsquare may use your cell phone number to call or send recurring text messages to you, using an autodialer or prerecorded voice, in order to provide you notifications about Hired Tasks, for marketing purposes (with your consent where required by law), and to administer the Townsquare Platform. If you would like more information about our policy, or how to opt out, please review the “Your Rights and Choices” section below or Section 9 of our Terms of Service. You may be liable for standard SMS and per-minute charges by your mobile carrier. Townsquare may also message you via push notifications (with your consent when required under applicable law), which you can opt-out of on your mobile device. Data rates may apply.

Call recordings. Calls to or from Townsquare or its Third Party Agents may be monitored and recorded for the purposes of quality control and training. Such calls may contain Personal Information.

6. Information Sharing

We only share the Information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing. 

To operate the Townsquare Platform, including processing your transactions, we may acquire your Personal Information so we can provide us with services as follows:

  • Email origination;

  • Identity checks to the extent permitted by applicable law;

  • Fraud prevention and detection (currently carried out by our providers Sift Science and Emailage). Our fraud detection providers also use information relating to you and your use of and activity on the Townsquare Platform to provide fraud detection services to their other clients;

  • Receipt, invoice, or support services;

  • Customer relationship management services;

  • Data analytics;

  • Marketing and advertising;

  • Website hosting;

  • Communications services;

  • Technical support;

  • Financial transaction fulfillment (in which we are currently supported by Stripe, who processes your Personal Information in accordance with its own privacy policy) and related chargeback and collection services;

  • To otherwise help us provide the Townsquare Platform.

Promotions. When you voluntarily enter a sweepstake, prize draw, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners’ list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice, and/or likeness in advertising or marketing materials. We may occasionally contact you, if you want us to, with information about special events, activities, promotions, contests, submission opportunities, and programs. You always have the ability, in your Account, to ask Townsquare not to contact you with this type of information. Please see Section 7, Your Rights and Choices, for more information.

Matched Ads. We use Matched Ads by sharing personal information with another party or incorporating a pixel from another party into our own Sites, and the other party matches common factors between our data and their data or other datasets for advertising purposes. For instance, we incorporate the Facebook pixel on our Sites and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

Other Users. Townsquare facilitates contact between Clients and Hired Helpers and reserves the right to share one User’s contact information (e.g., name, phone number, email, or postal address) with other Users, or with the recipient User’s legal or other authorized representative, in order to: (1) facilitate or communicate the resolution of an investigation or dispute related to or arising from an interaction between two or more Users of the Townsquare Platform; or (2) facilitate the performance of a Hired Task. This exchange of information is essential to the operation of the Townsquare Platform.

Legal Obligations. Townsquare and our Third-Party Agents may disclose your Personal Information or User Generated Content to courts, law enforcement, governmental or public authorities, tax authorities or authorised third parties, if and to the extent required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with Townsquare’s legal or regulatory obligations; (ii) respond to a court order, warrant or subpoena; (iii) respond to a valid legal request relating to an investigation into alleged criminal or illegal activity; or (iv) respond to or address any other activity that may expose us to legal or regulatory liability.

In jurisdictions where Townsquare is, according to applicable law, required to collect or remit information about Users’ permits, licences, tax, or social security registrations, Townsquare and our Third Party Agents may disclose information, including but not limited to, User contact details, identification information, transaction dates and amounts, license and permit status, and tax identification number(s) to applicable governmental authorities.

Townsquare reserves the right to disclose Personal Information from both private and public areas of the Townsquare Platform in the absence of a court order, warrant, or subpoena, to the extent permitted by applicable law, if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or Townsquare or its partners, parents or affiliates.

It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited or otherwise constrained by law or court order from doing so, (ii) we have reason to believe the User’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

Merger or Acquisition. Townsquare reserves the right to share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Public Areas. Your profile on the Townsquare Platform consists of information about you and your business, and may include information such as photographs, your years in business, skills and expertise, hourly pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your User Profile may be visible to all Users and the general public. If you choose to post a Hired Task via the Townsquare Platform, the contents of such listing will be viewable to Hired Helpers you select on the Townsquare Platform.

 

7. Your Rights and Choices

You may opt-out of receiving promotional communications from us, including promotional communications related to the Townsquare Platform, and request the removal of your Personal Information from our databases, or deactivate your account, by logging on to the Site or App and contacting us.

Account Settings. During registration you choose whether to receive marketing correspondence from Townsquare. This information remains on your Profile where you can, at any point, easily edit it. After logging on, click on the “Account” tab, then select “Notifications” to make your preferred selections.

Push Notifications. You have the option to receive updates and relevant offers via push notifications in your app. These notifications can be configured in the settings of your mobile device at any time.

Corrections to Profile. You have the right to access, update, and correct inaccuracies in your Townsquare Profile at any time by logging in and clicking on the “Account” tab. There, you can view, update, and correct your Account information.

So that we may protect the integrity of the Townsquare Platform, there are certain pieces of information, such as your age, that you cannot alter yourself. For example, since children under the age of majority in their jurisdiction of residence are not allowed to register as Users, we need to take reasonable measures to preserve the accuracy of our Users’ ages. You may contact us at Townsquaremtl@gmail.com if there is a need to make a correction to such data. Please see Section 11, Children’s Privacy, for more details.

Promotional Communications. You can opt out of receiving promotional communications from Townsquare via the Account tab in your Profile. In addition, you can opt out of email marketing by clicking on the unsubscribe link in any message. You can opt out of promotional communications from Townsquare sent via text message at any time by following the instructions provided in those messages to text the word “STOP”. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, Townsquare will continue to send you non-promotional communications, such as those about your account, Tasks, transactions, servicing, or Townsquare’s ongoing business relationship with you. If you receive unsolicited promotional communications from a Townsquare domain, please let us know.

8. Townsquare’s Information Retention Policy

We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations. We may also retain data from which you cannot directly be identified, for example where stored against a randomly-generated identifier so we know the data relates to a single User, but we cannot tell who that User is. We use this kind of data for research purposes and to help us develop and improve our services, and we take appropriate measures to ensure you cannot be re-identified from this data.

 

9. Townsquare’s Security of Collected Information

Your Townsquare account is password-protected so that only you and authorized Townsquare staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer, you should sign out of your Townsquare account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties.

Townsquare implements and maintains reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Townsquare has staff dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically reviewing security, and making sure that every Townsquare employee is aware of our security practices. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

10. Notification of Changes

Townsquare’s Privacy Policy is periodically reviewed and enhanced as necessary. This Privacy Policy might change as Townsquare updates and expands the Townsquare Platform. Townsquare will endeavor to notify you of any material changes by email. Townsquare also encourages you to review this Privacy Policy periodically.

11. Children’s Privacy

This service is intended for a general audience, and is not directed at children under 13 years of age. In certain jurisdictions, this minimum age may be higher. Please check the Jurisdiction-specific Provisions below for more information.

If you are a parent or guardian and you believe that we have collected information from your child in a manner not permitted by law, please let us know by contacting us. We will remove the data.

We do not knowingly collect or “sell” the Personal Information of minors under 18 years old who are Canadian residents.

12. Contacting Us

If you have any questions about this Privacy Policy or the manner in which we or our Third-Party Agents treat your Personal Information, the practices of the Site, your dealings with the Townsquare Platform, or if you have technical problems, you may contact us at Townsquaremtl@gmail.com

Townsquare’s staff will respond to all mail or email from Users with questions about privacy, including the types of Personal Information stored on the Townsquare databases, and requests to know, delete or rectify such Personal Information.

13. Jurisdiction-specific Provisions

Information of Canadian Users. Our collection, use, and retention of the Personal Information of Canadian Users is in accordance with applicable Canadian laws, as is our determination of what is deemed to be “personal data and/or information.”

Townsquare expressly disclaims any liability that may arise should any other individuals obtain the information you submit to the Townsquare Platform.

Interest-Based Advertising in Canada. 

Townsquare’s Security of Collected Information. While Townsquare will use commercially reasonable efforts to ensure the security of all Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all Personal Information stored therein, and you agree to hold Townsquare harmless for any damages that may result therefrom. If you have any further questions on this issue, please refer to the Terms of Service.

In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and Townsquare may have legal grounds for keeping such data.

To exercise any of these rights, please submit a request at townsquaremtl@gmail.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt-Out. To the extent Townsquare sells your Personal Information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your Personal Information by us to third parties at any time. You may request to opt-out by making your choice and submitting a request at townsquaremtl@gmail.com

Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination. You have the right to non-discriminatory treatment by us, should you exercise any of your rights.

Shine the Light. To exercise a request, please contact us at townsquaremtl@gmail.com. Requests must include “Canada Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please note that Townsquare is not required to respond to requests made by means other than through the provided email address or mail address.

Transfer Of Data. We primarily store data about you, including Personal Information, on servers located and operated within Canada. If you reside or are located outside of Canada, we may send and store your Personal Information (also commonly referred to as personal data) to the Canada in order to provide and operate the Townsquare Platform. By accepting the terms of this Privacy Policy, you acknowledge the transfer to and processing of your Personal Information on servers located in Canada.

Custom Audience. We may use services provided by third-party platforms (such as social networking or other websites) to serve targeted advertisements on such platforms to you, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your Personal Information for such purposes, please submit a request at townswquaremtl@gmail.com

Interest-Based Advertising. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit townsquaremtl@gmail.com