Privacy policy

Last Updated: November 13, 2020

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE SERVICE.

We are committed to respect and protect the privacy of the personal information we obtain from you through the Service and we have created this Privacy Policy to inform you about how we collect, use and share your personal information, and about our privacy practices in general.

We are always ready to address your questions and concerns regarding this policy and our privacy practices. If you would like to contact customer service, please contact us at the email address at the end of this Privacy Policy.

We continually strive to find new ways to enhance your experience with the Service and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices. By continuing to access and use the Service you agree to any such modifications. Therefore, you are responsible for reviewing and should become familiar with any such modifications. You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” date at the top of the Privacy Policy for the most recent version.

Terms of Service. Use of the Service is subject to the terms of our Terms of Service through our online form, which is hereby incorporated and made part of this Privacy Policy. By using the Service, you agree to be bound by our Terms of Service.
Application of this Privacy Policy.
1. This policy applies where a) we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of that personal data, and/or b) where we are acting as a data processor with respect to your personal data, in other words, where we process personal data as instructed by another party.
2. This policy applies where we are collecting Personally Identifiable Information (as further described below) from individuals and sole proprietors and does not apply to the collection of data from corporate entities.
3. This policy is in accordance with various privacy policy laws and regulations including those applicable in the United States including the California Online Privacy Protection Act (“COPPA”) and the EEU’s General Data Protection Regulation 2016/679 (“GDPR”).
How we use your data.
1. In this Section 3 we have set out:
  1. the general categories of personal data that we may process;
  2. the purposes for which we may process personal data; and
  3. the legal bases of the processing.
2. Types and Uses of Collected Information. Company collects two types of information about you, “Personally Identifiable Information” and “Non-Personally Identifiable Information.”
3. Personally Identifiable Information. Personally identifiable information is information that identifies a specific person.
4. How we collect Personally Identifiable Information and how we use it.
  1. when you engage in certain activities via the Service, including but not limited to creating an account, sending feedback, or otherwise participating in the Service (collectively, “Identification Activities”) we may ask you to provide certain information about yourself such as your name, address, email address, telephone number and/or any other information you provide to us, to create your account or profile, to send you communications and to provide our Service to you.
  2. we may use or share Personally Identifiable Information to provide products and/or service to you, to enable third-parties to provide products and/or services to you, to enter a sweepstakes or contest, to enhance the operation of the Service, improve our marketing and promotional efforts, analyze use of the Service, and tailor your experience with third parties as provided below in this Privacy Policy. We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Terms and Conditions and this Privacy Policy, and to comply with applicable law and cooperate with law enforcement activities.
  3. we collect the Parent (admin) email address, password,the Parent and the Child phone numbers, Child’s contacts, and list of applications that are installed on the Child’s phone. We collect and store device identifiers including but not limited to: the IMEI or the ESN of the device and the model and operating system version of the phone. We also collect and store device information such as device manufacturer, model, and mobile OS for the purpose of enhancing the performance of our mobile applications, by means of possible customization for certain types of devices. This information is only collected if the app is registered.
  4. we may process data about your use of our website, apps, and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website and services usage, and the performance of applications including situations in which the application experiences a serious error or crash.. The source of the usage data is our analytics tracking system. Collecting this information is of vital importance to us to be able to fix application issues and improve our products. This usage data may be processed for the purposes of analyzing the use of the website and Service. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and service.
  5. we may process the location of your Child’s phone in a variety of circumstances, including without limitation: (i) when you request a location update by either an SMS command or from the Techless Family Portal; (ii) when location tracking is enabled. If You are a citizen of the EU, You should talk with Your child (especially if Your child is older than 13) and make sure that he or she understands that You will be tracking their location through the Techless app.
  6. we may process your Child’s contacts in a variety of circumstances, including without limitation: (i) when the contacts are synced to the device, (ii) when contacts are added or removed from the device. This is required to enable you to: view the contacts that your child has and to choose whether to allow or block communications with the contact, and to allow you to see contact names in detailed call or SMS reports.
  7. we may process information about the applications installed on your Child’s device and the usage of the applications in a variety of circumstances, including without limitation: (i) when the app is registered, (ii) when applications are added or removed from the device, (iii) when an application is used. This is required to enable you to view the applications that your child has and to choose whether to allow or block use of the application, and to provide application usage reports.
  8. we may process your communications with other users (“communication data”). The communication data may include your user ID, name, messages, call history, contacts and other data you choose to include in communicating with other users. The source of the communication data is you. The communication data may be processed for the purpose of providing our Service and your use of the Service. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
    1. we may process SMS and MMS messages and message logs when SMS or MMS messages are received by or sent from Your Child’s phone. The information collected will include the time of the message, the message content text and the phone numbers and names of your Child's friends with whom the message is exchanged. This is required to enable you to view detailed SMS reports.
    2. we may process your Child’s detailed call history in a variety of circumstances, including the time and duration of the call, and the contact name and phone number of the person who was called or was calling your child. This is required to enable you to view detailed call reports.
    3. we may process the details of blocked calls or SMS or MMS messages, including the time, blocked phone number, contact name and for messages the content text of the message.
  9. we may process your profile data (“profile data”). The profile data may include your account name, address, phone number, birthday, current location, location history and other Personally Identifiable Information. The source of the profile data is you. The profile data may be processed for the purpose of providing our Service and your use of the Service. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
  10. we may process your account data ("account data"). The account data may include your password and/or User ID, name, telephone number, street address, email address, and other Personally Identifiable Information. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our Service, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
  11. we may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include first and last names, an email address to be used as a login, billing contact information, and a password. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
  12. we may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
  13. we may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.i
  14. in addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  15. please do not supply any other person's personal data to us unless we prompt you to do so and you have that person’s authorization to provide such, which we may verify via a method chosen in our sole discretion.
5. Non-Personally Identifiable Information. Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include things like the type of browser you are using, your Internet Protocol (“IP”) address, mobile carrier information, mobile device information, or general and/or aggregated location data that does constitute Personally Identifiable Information. We, and/or our authorized third parties may automatically collect this information when you visit or use the Service using electronic tools like Cookies and Web beacons or Pixel tags, as described below in this Privacy Policy. We use Non-Personally Identifiable Information to troubleshoot, administer the Services, analyse trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We reserve the right to use and share aggregated, anonymous data about our users as a group for any lawful business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
Providing your personal data to others.
1. We will not sell, rent, or otherwise provide Your Information or Your Child's Information to any third parties for marketing purposes.
2. In addition, as our business changes, we may buy or sell various assets. In the event all or a portion of the assets owned or controlled by us, our parent or any subsidiary or affiliated entity are sold, assigned, transferred or acquired by another company, the information from and/or about our Service users may be among the transferred assets.
3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. We contract with third-party service providers and suppliers (“Data Processors") such as website and server hosting companies, email service providers, payment processing companies, marketing campaign management or measurement and analytics providers, and customer service companies. Our suppliers and Data Processors are required to keep confidential the information received on behalf of us, and may not use it for any purpose other than to carry out the services they are performing for us.

The Data Processors we use are:

- Website and Server Hosting: SquareSpace, Amazon Web Services

- Payment Processing: iClassPro, PayPal

- Sending Emails: SendGrid

- Analytics: Google Analytics, Firebase Crashlytics

- Marketing campaign management: MailChimp

Release of Non-Personally Identifiable Information.
1. We may disclose or share Non-Personally Identifiable Information with Third Party Service Providers and the public. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) or use Third Party Service Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our users to administer the Service. We may also publish this aggregated information for promotional purposes. Such data is collected on our behalf and is owned and used by us.
Choices on Collection/Use of Information.
1. You can always choose not to provide certain information, although a certain level of information is required to engage and participate in the Service.
2. You may "opt out” of receiving marketing or promotional emails from us by following the instructions in those emails, or by emailing us at hi@techless.com. If you opt out, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.
3. You may revoke Your agreement to our collection of your or Your child's information by contacting hi@techless.com.
About cookies.
1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
4. We use cookies for the following purposes:
  1. authentication - we use cookies to identify you when you visit our website and as you navigate our website.
  2. status - we use cookies to help us to determine if you are logged into our website.
  3. security - we use cookies as an element of the security measures to protect our website and services generally.
  4. analysis - we use cookies to help us to analyze the use and performance of our website and services; and
  5. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our service providers and/or affiliates.
1. Our service providers, affiliates and partners use cookies and those cookies may be stored on your computer when you visit our website.
2. We may use Google Analytics or similar tools to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
Managing cookies
1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
  1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
  3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
  5. https://support.apple.com/kb/PH21411 (Safari); and
  6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
2. Blocking all cookies will have a negative impact upon the usability of many websites.
3. If you block cookies, you will not be able to use all the features on our website.
Analytics.
1. We continuously improve our websites and our products, and we utilize different third-party web analytics tools to help us do so. We are interested in how visitors use our websites, our desktop tools, mobile applications, or our API, what they like and dislike, and where they have problems. Our products, desktop tools, mobile applications and API use analytical tools to understand feature usage patterns, to enhance and improve your product experience and offer you specific usage tips and guidance. In connection with normal business operations, as well as to increase functionality and enhance your user experience, this usage information may be linked to personal information that we have about individual users. We maintain ownership of this data and we do not share this type of data about individual users with third parties.
2. This information is used solely to assist us in maintaining a more effective and useful websites and products for our customers. This data will not be shared with third parties without your prior consent or unless required by law.
Transfer and Storage of Information.
1. We use Secure Sockets Layer (SSL) encryption when collecting or transferring data from our websites and mobile device applications. SSL encryption is designed to make the information unreadable by anyone but us.
2. Your information may be transferred to, and maintained on, servers and databases located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as your jurisdiction. Please be advised that we may transfer your information to and from any state, province, country or other governmental jurisdiction, and process it in the United States or elsewhere. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to any such transfer.
3. The information collected to provide you with reports, including location information, application usage history, messages, calls, and alerts is only stored for approximately 90 days on our servers. We will retain other aspects of Your and Your Child's information such as email addresses and phone numbers for the duration that your account is active or as needed to provide services.
4. If you wish to cancel your account or request that we no longer store or use your information to provide You services, contact us at hi@techless.com. It is also possible for you to delete your account at the Techless Family Portal. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Security of Information.
1. We are committed to taking all reasonable precautions to safeguard the privacy of personal information which has been provided by its users. We use technical, contractual, administrative and physical security steps to protect your personal information. Security measures such as restricted access and the use of passwords and encryption have been adopted to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Our employees have been trained to respect your privacy at all times and those employees with access to your personal information shall use your personal information strictly in accordance with this Privacy Policy. We will protect your credit card information by using industry standard encryption technology.
2. Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
Notice of Privacy Rights to California Residents. California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (“COPPA”) and the California Business and Professions Code. As required by COPPA, we will provide you with the categories of Personally Identifiable Information that we collect through the Service and the categories of third-party persons or entities with whom such Personally Identifiable Information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of Personally Identifiable Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. COPPA further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or physical mail to the address found below. When contacting us, please indicate your name, address, email address, and what Personally Identifiable Information you do not want us to share with our marketing partners. The request should be sent to the attention of our legal department and labeled “California Customer Choice Notice.” Please allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your Personally Identifiable Information or requesting this notice.
Children.
1. The Service is not directed to people under the age of eighteen (18). If you become aware that your child has provided us with personal information without your consent, please contact us at the email address listed below. If we become aware that a child under this age has provided us with personal information, we take steps to remove such information and terminate the child’s access.
Additional terms that apply to some residents of the European Economic Area (EEA).

In addition to the rights already recorded above, if you are based in the EEA, you may have the following additional rights in relation to the personal information we hold about you, in accordance with The General Data Protection Regulation 2016/67.

In this Section 15, we have summarized the rights that you may have under data protection laws in the EEA. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection laws in the EEA are:
1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.
You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully process. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
1. consent; or
2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
You may access your personal information that we hold by contacting us using the contact details below. We will provide you with a copy of the personal information we keep about you. However, we reserve the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account the time, cost and effort involved.
You may request that the personal information we hold about you be corrected by contacting us. If we do not agree to your request for a correction, you may then request that we take reasonable steps to attach to the information a statement of the correction sought but not made.
Please be aware that some of these rights may be limited or unavailable where we have an overriding interest or legal obligation to continue to process the data, or where data may be exempt from disclosure.

Contacting us.

If you have any comments or questions regarding Privacy Policy or wish to report any violation of this Privacy Policy, you may contact us at

hi@techless.com
Techless, LLC, 320 E 10th Street, Shiner, TX 77984, USA

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