Last Updated: May 16, 2015
Device IDs. When you launch a TouchFirst Application, we collect the unique device ID issued by manufacturer of your O.S (“Device ID”) and IP address, if applicable. We use and store your Device ID to enable you to interact with and use our Services and the SNS you may choose to access through them and to make it possible to authenticate and understand the use of our Services. We link your Device ID with the technical information accessed through your use of the Services which enables us to administer resets to your account or to delete information when you request that we do so or for other administrative purposes.
Surveys and Promotions. From time to time, we may provide you the opportunity to participate in surveys, contests or sweepstakes (any of these a “Promotion”) via our Site or Services. If you participate in a Promotion we will request certain Personal Information from you. We use the Personal Information you provide to us in these instances to administer your participation in the Promotion. Participation in a Promotion is completely voluntary and you therefore have a choice whether or not to disclose this information.
Log Data. When you use our Services (e.g., when you visit our Site or interact with a TouchFirst Application), our servers automatically record information that your browser sends whenever you visit a website or service connected to the Internet (“Log Data”). This Log Data may include information such as your computer’s or Windows 8’s Internet Protocol (“IP”) address, browser type, the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, sections of our applications that you access, information you search for on our Site, access times and dates, and other statistics. We use this information to attempt to provide you with a better experience, to improve the Services, to analyze and understand how our Site and Services are used, and for advertising and other marketing purposes.
If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information.
Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may use “persistent cookies” to save a username and login password for future logins to the Site. We also may use “session ID cookies” to enable certain features of the Site or Services, to better understand how you interact with the Site and to monitor web traffic routing on the Site and aggregate usage of the Site and Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Services. Cookies placed on your device or computer by TouchFirst or any third party site or service that you may access through the Services may remain stored on your device or computer until you remove them.
We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Services to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel, that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns.
TouchFirst App Users. As a TouchFirst user who has downloaded and installed our TouchFirst Application on your Windows 8 or mobile device (each a “TouchFirst App User”) you can interact with and use SNSs including but not limited to services like Facebook and Twitter. By using an SNS via the Services you understand and agree that TouchFirst will access and store your SNS account information so that it is available to you through your use of the TouchFirst Application. Depending on the SNSs you choose to utilize via the TouchFirst Application and in accordance with the privacy settings you have set in your SNS account you can post information (including your Personal Information) to your SNS account and information you have posted to an SNS will be available via the TouchFirst Application. For example, via a TouchFirst Application you can access and login to your Facebook account by entering your Facebook account credentials through “Facebook Connect” when prompted to do so and interact with your Facebook account via your TouchFirst. Other services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use. You have the ability to disable the connection between your TouchFirst Application and an SNS you’ve chosen to access at any time via the “Inside TouchFirst” section of the “Table of Contents” in the TouchFirst Application interface.
Aggregate Information and Non-Identifying Information. We may share aggregated information that includes non-identifying information and Log Data with third parties for industry analysis, demographic profiling, and to deliver targeted advertising about other products and services. Any aggregated information shared in these contexts will not contain your Personal Information.
Services Providers. We employ third party companies and individuals to facilitate our Services (e.g., without limitation, maintenance services, database management, web analytics and improvement of our Services’ features), to provide the Services on our behalf, or to assist us in analyzing how Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Compliance with Laws and Law Enforcement. TouchFirst cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of TouchFirst or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Business Transfers. TouchFirst may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
You may email us at firstname.lastname@example.org with a request that we delete your Personal Information. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
You may limit TouchFirst’s use of your personal data for direct marketing purposes. You may also request access to, correction of, or deletion of personal data. For instructions on changing any of your privacy preferences, accessing your information, updating your information or for any privacy or data-protection-related questions, please write to email@example.com.
Subject to the privacy settings you have set in your SNS account, you can email a friend and share certain SNS content or other materials you may choose to share with that friend. If you choose to use this aspect of our services we will ask you for your friend’s name, email address and/or SNS username. We will automatically send your friend a one-time email. TouchFirst stores this information for the sole purpose of sending this one-time email.
Your friend may contact us at firstname.lastname@example.org to request that we remove this information from our database.
TouchFirst is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
If TouchFirst learns of a security breach that results in the unauthorized disclosure of your Personal Information, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. TouchFirst may post a notice on its Site or within the TouchFirst Application if a security breach occurs. If this happens, you will need a web browser or mobile device enabling you to view the notice. TouchFirst may also send an e-mail to you at the e-mail address you have provided to us for a notification pursuant to this paragraph. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), you should notify us at email@example.com.
Identity theft and the practice currently known as “phishing” are of great concern to TouchFirst. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Our Services contains links to other websites and online services. If you choose to visit a third party service or an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website or online service. The fact that we link to a website, content or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use.