At Local Chow, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by Local Chow. This policy explains our privacy practices for TheLocalChow.com (which we’ll refer to as the “Site”), Local Chow’s mobile applications (the “Apps”), and our other services provided by Local Chow, Inc. (“Local Chow,” together with “we,” “us,” and “our”). We’ll refer to the Site and the Apps as the “Services.” This policy does not apply to the practices of third parties (including other members who sell using the Services or API users) who may also collect or receive data in connection with your use of the Services.
By using the Services, you acknowledge that Local Chow will use your information in the United States, and any other country where Local Chow operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information as more fully described in the “Transfers” Section of this policy.
2. Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our vendors and suppliers that help provide Local Chow services you may interact with (such as, for example, for payments or customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. Local Chow uses the personal information it receives and collects in accordance with the purposes described in this policy.
Registration, Account Setup, Service Usage: In order to use the Services, will need to submit a valid email address or phone number. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services. Additional information, such as a shop name, billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address or location permissions, may be necessary in order for us to provide a particular service. For example, we need a physical postal address if you are selling something on the Site or App for pickup. As an Local Chow seller, if you choose to use our payment service (“Local Chow Payments”), Local Chow requires your full name, social security number, identification ID or tax ID, date of birth, bank account information, photograph, credit card information, and/or other proof of identification in order to verify your identity, provide this service to you, and comply with applicable law. For example, in certain markets, Local Chow Sellers’ imprint (including trade name or individual name as applicable), may be displayed to buyers on Local Chow in order to comply with local legal requirements. For both buyers and sellers, Local Chow requires this information from you in order to provide you with the Services (including, to verify ownership of an account, to mitigate fraud and abuse, to comply with regulatory obligations, or to complete a transaction as a buyer or seller). We may store credit card information for both billing and payment purposes. Members in certain countries can elect to save their credit card information to facilitate checkout for future purchases. Local Chow may contact individual shop owners confidentially to request more information about their shops or items listed through the Services, or may request information from buyers to ensure compliance with our policies and applicable law. In order to use certain products or services on Local Chow, you may be required to complete an application; information that you submit through the application process will not be displayed publicly and will only be used internally by Local Chow and its service providers, unless otherwise specified.
Automated Information: Local Chow automatically receives and records information from your browser or your mobile device when you visit the Site, use the Apps, or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. Local Chow may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.
We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing, & Disclosure” Section below.
Data from Local Chow Vendors and Suppliers: We also receive information from our vendors and suppliers about you. This information can include customer service interactions, payments information, shipping information, and information shared in Local Chow’s forums.
Data from Advertising and Marketing Partners: As described below, Local Chow receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to Local Chow comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.
Location Information: We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). When you use the Apps, you can choose to share your geolocation details with Local Chow in order to use functions like our local marketplace, maps, and for in-person sales (although you don’t need to share these details). You can choose to publish your location when you sell on Local Chow.
We obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for Local Chow’s internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and (using non-precise location information) marketing. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the Apps or on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. You may also choose to enable the Apps to access your mobile device’s camera to upload photographs to Local Chow.
Analytics Information: We use data analytics software to ensure Site and App functionality and to improve the Services. This software records information such as how often you use the Apps, what happens within the Apps, aggregated usage, performance data, app errors and debugging information, and where the Apps were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application. For more information, see Local Chow’s Cookies and Similar Technologies Policy and Disclosures.
Information from Third Parties: Some members or visitors may choose to connect to Local Chow or register an Local Chow account using an external third-party application, such as Facebook, or an app developed using Local Chow’s API. Connecting your Local Chow account to third-party applications or services is optional. If you choose to connect your account to a third-party application, Local Chow can receive information from that application. We may also collect public information in order to connect with you, such as when we communicate with you over social media. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on Local Chow on certain social media networks which are connected to your Local Chow account, and you can revoke your permission anytime in your account settings. Certain third-party applications that you use to create or sign in to your account may provide you with the option to discontinue receiving messages from us or allows you to forward those messages to another email address. If we are unable to send you critical messages about your account, we may suspend or terminate your account.
Non-Member Information: Local Chow receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered Local Chow member (a “non-member”) in connection with certain Local Chow features, such as when a non-member chooses to subscribe to an Local Chow newsletter, a member invites a non-member to visit the Site, a member uploads non-member information using the contact uploader feature, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses Guest Checkout to make a purchase. Non-member information is used only for the purposes disclosed when it was submitted to Local Chow, for purposes necessary to the functioning of Local Chow’s Services or where Local Chow has a legitimate interest, as disclosed in the “Information Uses, Sharing, & Disclosure” Section below, or to facilitate action authorized by a member or the non-member.
You can choose to import your contacts from your mobile device or personal email address book, or a social network account to Local Chow. We do not retain the login information for your email service, mobile device, or social network site. You can search for people you know by email address or phone number on the Site or through the contact information you import. Finding your friends on Local Chow helps you connect with them on our platform. For example, you can follow another member’s public activity, such as public Favorites. When you begin following another member’s activity, they will receive an email notification (if the member has consented to receiving this type of email).
If you do not want your contacts to be able to find you on Local Chow through your email address, phone number, or social networking connections, then you can change your findability through your account settings. If you do not wish to be located on Local Chow via your name, you can remove your name and instead may use a nickname or alias as your name in your public account information.
4. Messages from Local Chow
On occasion, Local Chow will need to contact you. Primarily, these messages are delivered by email, Local Chow Messages, or by push notifications for a variety of reasons, including marketing, transactions, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email or Messages in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. Local Chow may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, Local Chow may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about products and features that you may find of interest. You can update your contact preferences in your account settings.
Some messages from Local Chow are service-related and necessary for members and Guest Checkout users. You understand and agree that Local Chow can send you non-marketing emails, Local Chow Messages, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying Messages with buyers, and correspondence with Local Chow’s Support team (including by chat interface or the other methods of communication as described above).
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number such as for a Guest Checkout purchase, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in marketing emails or messages. Members can also control which marketing emails or messages they receive from Local Chow through their account settings. Please note that some changes to your account settings may take a few days to take effect.
A contact-importer feature is available to help you locate and connect with your friends and contacts who may be members of Local Chow (see the “Findability” section above for more information). If someone in your contact list is not already a member, you may invite them to join Local Chow, and an email will be sent to them on your behalf. Recipients of email invitations may opt out of receiving future invitations by following instructions in the email invitation message. You may send an invitation only to someone who has given you consent to receive one.
Local Chow is a marketplace and a community. We offer several features that allow members to connect and communicate in public or semi-public spaces, such as Forums and Teams, which are a part of the Local Chow Community space. You don’t have to use these features, but if you do, please use common sense and good judgment when posting in these community spaces or sharing your personal information with others through the Services. Be aware that any personal information that you choose to submit there can be read, collected, or used by others, or could be used to send unsolicited messages to you. We engage certain third parties to assist in providing community services to you and, in the context of that relationship, we need to share some of your information with such third parties in order to provide that service. This may include, for example, information from your Local Chow account that is publicly available, your account’s status, your forum posts and Team memberships, your Local Chow username and/or shop name, the display name you’ve optionally chosen to share publicly in your Local Chow account, avatar image, the date that you registered on Local Chow, as well as your language and regional settings on the Site. If you close your Local Chow account, your Community account, which allows you to post in Forums, will also be closed and related personal information will be deleted. However, your posts may remain public after your account is closed, although your name will no longer be displayed alongside the post. You are responsible for the personal information that you choose to post in community spaces through the Services. You can set your privacy preferences and download your data in your Community Settings, and close or delete your Community account by submitting a request to Local Chow.
Another member may follow your public activity on the Site to receive updates, such as when you add an item to your public Favorites. You may choose to make certain activities private through your account settings. You have the option to block any member with whom you do not wish to share your updates.
6. Information Uses, Sharing, & Disclosure
We respect your privacy. Local Chow will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.
You can control your privacy settings through the opt-out buttons in your account settings privacy tab, and the Privacy Settings link in the footer of most site pages and our homepage. Please note that some changes to your privacy settings may take a few days to take effect. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site.
When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
- You have consented to the processing, which you can revoke at any time;
- Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
- Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
- You have expressly made the information public;
- Necessary in the public interest, such as to prevent crime; and
- Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).
We principally rely on consent (which can be withdrawn at anytime) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.
We rely on consent for targeted online and offline marketing including through tools like Facebook Custom Audience and Google Customer Match. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners disclosed in our Cookies and Similar Technology Policy. These partners have their own privacy policies and consent mechanisms for their customers, in addition to Local Chow’s controls. You may see the privacy policies and privacy choices for these partners, and the information you share with them, in our Cookies and Similar Technology Disclosures.
Our Legitimate Interests
Where we process your information on the basis of legitimate interests, we do so as follows:
Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on Local Chow.
Providing Marketing Communications: We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for Local Chow’s advertising programs (including Local Chow’s on-site advertising and marketing).
Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to Local Chow’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with Local Chow or other members.
Site Customization: We may learn about the types of products that you’re interested in from your browsing and purchasing behavior on (and off) the Site or Apps and use such information to suggest potential purchases as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on Local Chow.
If Local Chow receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, Local Chow may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details. Find out more about how Local Chow responds to requests for records or information about members of Local Chow’s community in our Requests for Information Policy.
Aggregated Information: Local Chow may share demographic information with business partners, but it will be aggregated and de-personalized so that personal information is not revealed.
Service Providers: Local Chow also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Local Chow not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
This policy does not apply to the practices of third parties (such as other members who sell using the Services, certain third-party providers on whom we rely to provide certain services, or API users) that Local Chow does not own or control or individuals that Local Chow does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While Local Chow requires these third parties to follow Local Chow’s privacy and security requirements, Local Chow does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Local Chow is not responsible for the privacy or security practices of these sellers, API users, or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these sellers, third party providers, and API users are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.
To the extent that Local Chow is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:
The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of Europe. We often use these Model Clauses when transferring personal information outside of Europe. You can request a copy of our Model Clauses by emailing legal@Local Chow.com.
Local Chow, Inc. does not participate in Privacy Shield at this time. However, Local Chow Ireland UC may rely on the EU-US Privacy Shield to transfer personal information to some of our third party service providers in the United States, where they are certified to receive such information under the Privacy Shield Program.
Necessary for the Performance of the Contract between Local Chow and its Members
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. Local Chow offers advanced security features and settings for members, such as two-factor authentication for signing in, and sign in history and notifications; you can view more information in your account settings.
If you have any questions about the security of your personal information, you can contact us at legal@Local Chow.com.
Local Chow will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Local Chow member account), or as needed to provide the Services to you. If you no longer want Local Chow to use your information to provide the Services to you, you may close your account. Local Chow will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Local Chow sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
10. Your Rights & Choices
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, Local Chow gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Local Chow account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information.While some of these rights apply generally, certain rights apply in limited cases.
- Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used. See this Help Center article for more information.
- Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
- Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Local Chow. See this Help Center article for more information.
- Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
- Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
- The CCPA provides California residents with the following additional rights:
- Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
- Right to Opt-Out: To the extent that Local Chow “sells” personal information(as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).
If you would like to manage, change, limit, or delete your personal information, you can do so via your Local Chow account settings. Alternatively, you can exercise any of the rights above by contacting us by submitting a message through our contact form available in our Help Center, chat support, or through any other channels available via our Help Center. Once you contact us to exercise any of your rights, we will confirm receipt of your request.
Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact Local Chow through one of the channels listed below under “Contact”. We will respond to your request within a reasonable timeframe.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
Email & Messages
You may also control the receipt of certain types of communications from Local Chow in your account settings. Local Chow may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from Local Chow” Section of this policy. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.
We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies. A more detailed explanation of the technologies we use, and how to opt out when applicable, can be found in Local Chow’s Cookies & Similar Technologies Policy.
Additional Disclosures for California Residents
Notice of Collection
In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the “Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:
- Identifiers, including name, email address, shop name, IP address, and an ID or number assigned to your account.
- Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
- Demographics, such as your age or gender, or, where you have provided such information to Local Chow voluntarily, demographic information about your race, ethnicity, sexual orientation, or gender identity, provided in relation to specific marketing and advocacy projects and campaigns.This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, including purchases and engagement with the Services.
- Internet activity, including your interactions with our Services and what led you to our Services.
- Sensory visual data, such as pictures posted on our Service.
- Geolocation data provided through location enabled services such as WiFi and GPS.
- Inferences, including information about your interests, preferences and favorites.
The Purposes for Our Collection
We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.
Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)
Local Chow does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities. You can read more in our Cookies & Similar Technologies Policy.
To opt-out of receiving interest based advertising, you can exercise your choice by using your account privacy settings, or the general privacy settings link located at the footer of our homepage and most pages of the Site. The right to opt-out of interest based advertising is available to all Local Chow users.
Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Shine the Light
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Other than to Sellers on Local Chow (see “Buying and Selling” under the “Information Uses, Sharing and Disclosure” Section above), who must obtain your separate consent for their own marketing off of Local Chow, or unless you request us to or consent to it, Local Chow does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below. For information on interest based advertising with Local Chow and how your information is used for marketing, see Local Chow’s Cookies & Similar Technologies Policy.
If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact” section below.
11. Your Responsibilities
If you sell using our Services, you may receive and determine what to do with certain personal information. Your privacy responsibilities, including when you act as an independent data controller (someone who decides what personal data to collect and the purpose you use the data for) are laid out in the Local Chow Seller Policy.
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ platform. We encourage you to check back regularly and review any updates.
If you have any questions:
Contact Local Chow’s Support team.
Send an email to Local Chow’s Data Protection Officer at support@TheLocalChow.com
Write to us at the following addresses:
728 W Morning Dew Drive
Murray, Ut 84123
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our US-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Without prejudice to any other rights you may have, if you are located outside of North America or South America, you also have the right to file a complaint against Local Chow with the Irish Data Protection Commission (“DPC”), which is Local Chow’s Lead Supervisory Authority. The DPC’s contact details are:
Data Protection Commissioner
21 Fitzwilliam Square South
Dublin 2, D02 RD28, Ireland
Phone: +353 (0761) 104 800
Webform: https://forms.dataprotection.ie/contact Email: firstname.lastname@example.org
If you live in the EEA, you may also file a complaint with your local data protection regulator.
FOR SELLERS ON LOCAL CHOW
What information does Dwolla collect?
- Identifiers, such as a real name, postal address, phone number, email address, account name, or other similar identifiers.
- Internet activity, including IP address, type of device, operating system, browser, UR data, and similar data.
- Inferences about preferences from cookies and site usage, including those used to gauge interest in obtaining Dwolla Services.
- Financial information, such as your full bank account number if you choose to use it with the Dwolla Services.
- Detailed personal information, such as your date of birth or social security number, as may be required by law or rule.
- Other personal information provided by third party service providers such as credit bureaus and identity verification services.
- Information that you provide to Dwolla when interacting with our customer support team or other team members via phone, email, online form, or other correspondence.
- Email and/or phone number for your contacts that you enter into Dwolla payment flows. We use this information to notify your contacts that you have sent them a payment and/or payment request.
- If you use a device to access the Dwolla Sites or Dwolla Services, we may also collect your IP address, the type of device you use, your device identifier, your operating system version, the type of browser you use, your location, and the URL that you came from and the next URL that you visit.
- Dwolla uses analytics software to allow us to better understand the functionality of the Dwolla Sites. This software may record information such as how often you use the Dwolla Sites, the events that occur with such use, aggregated usage, and performance data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Sites and the Dwolla Services.
- Detailed personal information, such as your date of birth or social security number, and protected legal characteristics, such as your membership in a protected class. We may collect this information if you apply for or accept a job at Dwolla, to the extent required by law.
- Credit information and criminal record information from third party vendors performing pre-employment background checks as authorized by law.
How does Dwolla use the personal information that it collects?
Over the past twelve months, and on an ongoing basis, Dwolla collects your personal information to do the following:
- Customize and improve your Dwolla experience with the Dwolla Sites and the Dwolla Services.
- Provide the Dwolla Services to you.
- Validate your account.
- Notify you about your account activity.
- Process transactions and collect fees.
- Provide customer support and resolve disputes.
- Verify your identity and account information.
- Identify, prevent, and report potentially prohibited, fraudulent, or illegal activities.
- Notify you about important changes to the Dwolla Services and/or Dwolla’s terms and conditions.
- Provide you with news, offers, and information about the Dwolla Services based on your communications preferences.
- Process your application for Dwolla employment, or the award of employment with Dwolla, in accordance with law.
- Any other purpose that we disclose to you in the course of providing the Dwolla Sites, Dwolla Services, or Dwolla Employment to you.
How does Dwolla share my personal information?
Over the past twelve months, and on an ongoing basis, we may share your personal information as follows:
- When you send or receive money using the Dwolla Services, we will provide the other party to the financial transaction appropriate details about the transaction.
- If your payment to another Dwolla user fails, we may provide that user with details of the unsuccessful payment.
- With third parties to provide, maintain, and improve the Dwolla Services, including fraud prevention, identity verification, analytics and marketing services, and financial institutions and other partners that are part of the payment process. These companies are authorized to use your personal information only as necessary to provide these services to us.
- To the extent third party analytics software is used to improve the functionality of the Dwolla Sites, the providers of the software may receive information about your use and interaction with the software in order to assist Dwolla with providing and improving the Dwolla Sites and the Dwolla Services.
What are other circumstances when Dwolla may disclose my personal information?
- Dwolla may release information to third parties upon your request. For example, you may authorize a Dwolla integrating partner to access your personal and business information.
- Dwolla may release your information if we believe disclosure is reasonably necessary to comply with any applicable law, legal process, or government request; to investigate or bring legal action against someone who may be violating our rights, our terms and conditions, or the rights of others; or to protect the safety and security of Dwolla, our users, or the public.
- Dwolla may also share aggregated, non-personally identifiable information with third parties for auditing, analytics, maintenance, security, or other related business purposes as determined appropriate by Dwolla.
Does Dwolla sell my personal information?
No. Dwolla does not sell your personal information.
Will Dwolla refuse service, charge me a different rate, or provide different quality service if I decline to provide certain data?
In order to use Dwolla Services to transfer funds through the U.S. monetary system, a user must comply with applicable federal laws and rules. These applicable laws and rules may require the disclosure and retention of information regarding the identity of senders and recipients of funds.
Dwolla will not discriminate against you for exercising any rights you may have under the California Consumer Privacy Act (“CCPA”) or any other applicable law or rule. Dwolla does not base its prices or the quality of its services on the exercise or non-exercise of legal privacy rights.
As reflected above, Dwolla and its marketing, analytics and fraud prevention service providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about Dwolla’s user base, and we may receive such information on an individual and aggregated basis from such providers.
We may gather certain information about our website visitors automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve the Dwolla Services.
We may partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you do not want this information to be used for the purpose of serving you interest-based ads, you may opt-out by clicking here. This does not opt you out of being served ads and you will continue to receive generic ads.
We use Local Shared Objects, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website also use Flash cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here.
How do I opt-out of receiving promotional emails from Dwolla?
If you prefer not to receive promotional emails from Dwolla, click on the unsubscribe link at the bottom of any promotional email that we send you to remove your email address from future promotional email campaigns. If you have difficulty with the unsubscribe process, contact us at email@example.com.
What security precautions does Dwolla take to protect me?
We have security measures in place to protect your personal information, including the use of industry-standard data encryption technology and internal policies and restrictions regarding the storage of and access to your personal information. Please note that no data transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. Dwolla’s servers and business operations are entirely located in the United States. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
How do I update my information?
If your information changes, you can correct it in your account settings by contacting your organization’s Account Manager at www.dwolla.com.
If you wish to close your account or request that we no longer use your information to provide you the Dwolla Services, contact us at email@example.com and we will respond to you in a reasonable timeframe. We will retain your information for as long as your account is active or as needed to provide you the Dwolla Services, or to the extent required by applicable law or rule.
What about the privacy of children?
Dwolla is a general audience website. Dwolla does not knowingly collect any personal information from anyone under the age of 13.
Rights for California Residents
If you are a California resident, you have the right to request disclose of the specific pieces of personal information that Dwolla may have collected regarding you. California residents also have the right to request deletion of personal information that Dwolla may have collected regarding you.
In order to request a copy of personal information or to request deletion of personal information, California residents can forward verifiable consumer requests to Dwolla through one of the following methods:
- Emailing us at firstname.lastname@example.org;
- Calling Dwolla at 1-888-289-8744.
Only you, or someone registered with the California Secretary of State in order to act upon your behalf, may make a verifiable consumer request. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for data access, transport, or deletion twice within a twelve-month period.
In order to submit a verifiable consumer request to Dwolla, the request must both provide sufficient detail for Dwolla to be able to appropriately ascertain your identity and give sufficient clarity for Dwolla to understand the nature of the request. Dwolla will determine the criteria for a verifiable consumer request based upon the nature of the request and account.
If you have submitted a verifiable consumer request to Dwolla, Dwolla will respond in a timely manner consistent with applicable law. If Dwolla is unable to verify your request, or if Dwolla is unable to ascertain that you are a California resident subject to the rights in this Section, Dwolla will submit an appropriate response.