COLLECTION OF PERSONAL INFORMATION

You can browse ChangeTower.com without telling us who you are or revealing any personal information about yourself. If, on the other hand, you register for an account with us, you give us your personal information, and you are not anonymous. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers located in the United States.

We collect the following types of personal information in order to provide you with the use of and access to our site, applications, services and tools, and to help us personalize and improve your experience:

Information we collect automatically: When you visit our site, use our applications, services, and tools, or interact with our advertising or content, we automatically collect information sent to us by your computer, mobile device, or other access device. This information is associated with you personally only when sign in as a registered user, and includes but is not limited to:

• device ID or unique identifier, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the site, referral URL, ad data, IP address, and standard web log information, anonymous information collected through our use cookies and web beacons.

Information you give us: We collect and store any information you enter on ChnageTower.com or you provide to us in context of using ChangeTower.com. This may include, but is not limited to:

• information you provide us when registering for an account, including email address, phone number, mobile telephone number, physical contact information, and financial information, such as credit card or bank account numbers;
• additional information you may provide to us via social media site or services;
• transactional information based on your activities on the site;
• information provided in the context of community discussions, chats, dispute resolution, correspondence through our site, or correspondence sent to us;
• additional personal information we ask you to submit to authenticate yourself or if we believe you are violating site policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity).

MOBILE

When you download or use our Mobile Applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device’s setting’s menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.

INFORMATION FROM OTHER SOURCES

We may receive or collect supplemental information about you from third parties sources and add it to our account information. This may include, but is not limited to, demographic, navigation information, additional contact information, credit check information, background check information, and additional information about you from credit bureaus or other sources, as permitted by law.

INFORMATION SHARING & REGISTRATION WITH SOCIAL MEDIA SITE

We offer sign-on services that allow you to use third party login credentials to access the ChangeTower site or related site. We also offer services that allow you to share information with third party social media website such as Facebook, Google Plus, Twitter, and others.

You may choose to provide us with access to certain personal information stored by such third party website. The personal information we have access to varies by website and is controlled your by privacy settings on that website and your consent. By associating an account managed by a third party with your ChangeTower account and authorizing ChangeTower to have access to this information, you agree that ChangeTower may collect, use and store information from these website in accordance with this Privacy Policy.

USE OF PERSONAL INFORMATION

Our primary purpose in collecting personal information is to provide you with access to our site and/or use of our services, applications and tools, provide you with requested customer service and relevant information about your account and our services, and to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:

• provide you access to our site and the services and customer support you request;
  prevent, detect, and investigate, fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Service;
• customize, measure and improve our services, content and advertising;
• contact you, either via email or telephone, to resolve disputes, collect fees, and troubleshoot problems with your account or our site, services, applications or tools, or for other purposes authorized by law;
• contact you, either via email or telephone to inform you about our services and those of our corporate family, deliver targeted marketing, service updates, and promotional offers based on your communication preferences;
• compare information for accuracy, and verify it with third parties;
• contact you at any telephone number using auto-dialed or pre-recorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy;
• provide you other services requested by you as described when we collect the information.

MARKETING

Personally identifiable information including but not limited to your contact information (name, email address, phone number, billing address, etc.)  kept strictly confidential, and will never be sold, rented or otherwise used for the purposes of third-party marketing. ChangeTower may from time to time send marketing-related emails.

We allow third-party companies to collect certain information when you visit our web site. These companies may utilize cookies, pixels or other technologies to collect and use non-personally identifiable information (e.g., hashed data, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.

OUR DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that content or information violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with this Privacy Policy and applicable laws and regulations. As stated above, we do not disclose your personal information to third parties for their marketing purposes without your explicit consent.

We may also share your personal information with:

• Members of the ChangeTower LLC corporate family to provide joint content and services (like registration, transactions, and customer support), to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches, and to guide decisions about their products, site, applications, services and tools, and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services and will use your personal information in compliance with their this Privacy Policy and our global privacy standards.
  Service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, bill collection, affiliate and rewards programs, site operations, and co-branded credit cards).
• Financial institution partners of the ChangeTower LLC corporate family members who offer financial products to provide joint content and services (like registration, transactions and customer support), to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or security breaches, and to guide decisions about their products, website, applications, services and tools, and communications. These third party financial institution partners will use this information to send you marketing communications only if you have requested their services and will use your personal information in compliance their respective privacy policies and consistent with this privacy policy and our global privacy standards
• Other ChangeTower users, whether located in your country of residence or outside of your country of residence, as authorized by you or your use of our site, services, applications or tools. For example, where you are involved in a transaction with another user, the other user may view your email address and request and obtain your contact information and postal address to help complete the transaction;
• Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).
• Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other ChangeTower user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, ZIP code, telephone number, email address, User ID history, IP address, fraud complaints, bidding and listing history, and anything else we may deem relevant to the investigation.
• Credit bureaus with which we may report information about your account, including information on late payments, missed payments, or other defaults on your account may be reflected in your credit report.
• Other business entities, should we plan to merge with or be acquired by that business entity. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information will be used contrary to this policy, you will receive prior notice.).

Without limiting the above, in an effort to respect your privacy and our ability to keep the community free from bad actors, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

USING INFORMATION FROM CHANGETOWER

We encourage you to disclose your privacy practices and respect the privacy of other users. We cannot guarantee the privacy or security of your information. To help protect your privacy, we offer a number of tools and measures to mitigate the possibility of unauthorized account access or access to our RSVP system.

HOW WE USE COOKIES

When you access our website, or use our applications and/or services and tools, we may place small data files on your computer or other device. We use these data files, commonly known as “Cookies”, to help us identify you as a user, customize our services, content and advertising, to measure promotional effectiveness, and to promote trust and safety.

A few important things you should know about our use of Cookies:

• We offer certain features that are available only through the use of Cookies
• We use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent Cookies remain on your device until you erase them or they expire
• You are always free to decline Cookies if your browser permits, although doing so may interfere with your use of our website, applications, and/or services and tools. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling Cookies
• We encode and protect our Cookies so that only we can interpret the information stored in them
• You may encounter Cookies from third parties, known as service providers, that we have allowed on our site that assist us with various aspects of our web site operations and services
• You also may encounter Cookies from third parties on certain pages of the website that we do not control and have not authorized. (For example, if you view a web page created by another user, there may be a cookie placed by that web page)

NO SPAM, SPYWARE OR SPOOFING

We and our users do not tolerate spam. Make sure to set your ChangeTower communication preferences so we communicate to you as you prefer. To reportChangeTower-related spam or spoof emails to ChangeTower, please forward the email to [email protected]. You may not use our communication tools to send spam or otherwise send content that would violate our Terms of Service. We automatically scan and may manually filter messages to check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content, but we do not permanently store messages sent through these tools. If you send an email to an email address that is not registered in our community (via Refer-a-Friend or other tools), we do not permanently store that email or use that email address for any marketing purpose. We do not rent or sell these email addresses.

ACCESSING, REVIEWING AND CHANGING YOUR PERSONAL INFORMATION

Your password is the key to your account. Use unique numbers, letters and special characters, and do not disclose your ChangeTower password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify ChangeTower and change your password.

You can see, review and change most of your personal information by signing on to ChangeTower. Generally, we will not manually modify your personal information because it is very difficult to verify your identity remotely. You must promptly update your personal information if it changes or is inaccurate.

THIRD PARTIES

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others on our site or other sites throughout the internet, different rules may apply to their use or disclosure of the information you provide to them. ChangeTower does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

CONTACT US

You may write to us at [email protected].

LAST UPDATED

March 19, 2020