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Two Dots Applicant Privacy Policy

Updated: December 22nd, 2022

This privacy notice for Two Dots Inc ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Visit our website at twodots.net, or any website of ours that links to this privacy notice

  • Engage with us in other related ways, including applying to a property manager using our Services

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@twodots.net.

 

SUMMARY OF KEY POINTS

 

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for. 

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Two Dots Inc and the Services, the choices you make, and the products and features you use. 

 

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. 

 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

 

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. 

 

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. 

 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. 

 

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

 

TABLE OF CONTENTS

 

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

8. DO WE MAKE UPDATES TO THIS NOTICE?

9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?


 

1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us and to your property manager.

 

In Short: We collect personal information that you provide to us or your property manager.

 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • financial data

  • identity data

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following third parties.

 

We may need to share your personal information in the following situations:

  • When required to comply with applicable laws. 

 

4. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. 

 

6. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short:  You may review, change, or terminate your account at any time.

 

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided below.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

If you have questions or comments about your privacy rights, you may email us at support@twodots.net.

 

7. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

 

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

CCPA Privacy Notice

 

The California Code of Regulations defines a "resident" as:

 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

 

All other individuals are defined as "non-residents."

 

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

 

What categories of personal information do we collect?

 

We have collected the following categories of personal information in the past twelve (12) months:

 

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

 

YES

 

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

 

YES

 

C. Protected classification characteristics under California or federal law

Gender and date of birth

 

YES

 

D. Commercial information

Transaction information, purchase history, financial details, and payment information

 

YES

 

E. Biometric information

Fingerprints and voiceprints

 

YES

 

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

 

NO

 

G. Geolocation data

Device location

 

YES

 

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

 

NO

 

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

 

YES

 

J. Education Information

Student records and directory information

 

YES

 

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

 

NO

 

L. Sensitive Personal Information

Account login information, biometric data, debit or credit card numbers, drivers' licenses, passport numbers, precise geolocation, social security numbers and state id card numbers

 

YES

 

 

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with us

  • Category B - As long as the user has an account with us

  • Category C - As long as the user has an account with us

  • Category E - As long as the user has an account with us

  • Category G - As long as the user has an account with us

  • Category I - As long as the user has an account with us

  • Category J - As long as the user has an account with us

  • Category L - As long as the user has an account with us

Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;

  • Participation in customer surveys or contests; and

  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

 

You may contact us by email at support@twodots.net, or by referring to the contact details at the bottom of this document.

 

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

 

Will your information be shared with anyone else?

 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

 

Two Dots Inc has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Two Dots Inc will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

 

Your rights with respect to your personal data

 

Right to request deletion of the data — Request to delete

 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

 

Right to be informed — Request to know

 

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;

  • the categories of personal information that we collect;

  • the purposes for which the collected personal information is used;

  • whether we sell or share personal information to third parties;

  • the categories of personal information that we sold, shared, or disclosed for a business purpose;

  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

  • the business or commercial purpose for collecting, selling, or sharing personal information; and

  • the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

We will not discriminate against you if you exercise your privacy rights.

 

Right to Limit Use and Disclosure of Sensitive Personal Information

 

If the business collects any of the following:

  • social security information, drivers' licenses, state ID cards, passport numbers

  • account login information

  • credit card numbers, financial account information, or credentials allowing access to such accounts

  • precise geolocation

  • racial or ethnic origin, religious or philosophical beliefs, union membership

  • the contents of email and text, unless the business is the intended recipient of the communication

  • genetic data, biometric data, and health data

  • data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.

 

Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

 

Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

 

To exercise your right to limit use and disclosure of sensitive personal information, please email support@twodots.net.

 

Verification process

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

Other privacy rights

  • You may object to the processing of your personal information.

  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

  • You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at support@twodots.net, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

 

8. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Contacting Us

For more information related to our Privacy Policy or our procedures, contact our Privacy Department by email at support@twodots.net or by mail at:

 

Two Dots Inc., 420 E 58th Street, New York, NY, 10022

support@twodots.com

1-415-840-8139

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