Privacy Policy

Last updated: February 14, 2025

Townhall Pro, Inc. (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our application(s), or access any of our plug-in, services or add-ons (collectively, the “Application”), and also applies to any messages between you and the Application and when you interact with the Application directly or through third party website or software.

By using our services, you acknowledge that you have read this Privacy Policy and agree to the collection and use of your data as described herein. For users located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, this Privacy Policy includes additional provisions required by the General Data Protection Regulation (GDPR)

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE APPLICATION.

Our Terms of Service (located at https://townhall.pro/terms-of-service) is incorporated herein by reference, and capitalized terms used herein have the meaning set forth in the Terms of Service. Together, the Terms of Service and this Privacy Policy may be referred to as the “Policy.”

We reserve the right to make changes to this Policy at any time and for any reason. All changes are effective immediately when we post them, or if required by law upon providing notice to you of such changes, and thereafter such changes apply to all access to and use of the Application. You are encouraged to periodically review this Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Policy by your continued use of the Application after the date such revised Policy is posted.

This Policy does not apply to any third party application or content that may link to or be accessible from or through the Application. You acknowledge that the Application may be an add-on or plug-in to third party website, software, and/or applications, and that you may obtain, download, or install the Application through a third-party store or application; we are not responsible for the collection or use of your data collected by any such third party, and you should review the policies of any such third party.

THE INFORMATION WE COLLECT

We collect several types of information from and about users of the Application, which may depend on the content and materials you use, including:

Information by which you may be personally identified, such as your name, email, links to your social media accounts, telephone number , or other identifiers (“Personal Information”); and
Information that is about you or your use of the Application but which does not identify you, such as your actions within the Application and how the Application is accessed and used by you, including but not limited to access times, browser type, browser version, the aspects of the Application that you use, the time and date of your visit, the time spent on those pages, unique device identifiers, the content and advertisements you have accessed or seen, your internet protocol address, and other usage or diagnostic data (“Usage Data”).

HOW WE COLLECT INFORMATION

We collect information from you when you provide it to us, and automatically when you access the Application.

If you agree to use the Application as a plug-in or add-on to a third party provider of video or phone conferencing services, that third party may provide us with certain Personal Information about you upon your agreement to allow access to the Application. If you do not want such third party to provide information about you to us, you should not allow those services to access the Application. If you have a question about a third party’s provision of your Personal Information to us, please review the policies of such third party.

We may request permission to access and/or track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

We may request access to certain features from your mobile device or your computer, including your camera, microphone, sensors, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

We may use various tracking technologies to track your activity on the Website, including but not limited to session cookies, preference cookies, security cookies, web beacons, tags, internet protocol addresses of other websites you may visit, and scripts to collect and track information and to improve and analyze the Application and services we provide, which may be collected directly through the Application or via third-parties providing analytic services to us. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. You may not be able to decline web beacons. You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

We may use certain third-party vendors to analyze and track users’ use of the Application, determine the popularity of certain content or services, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors.

If you agree to pay us for your access to or us of any portion of the Application, we may collect your payment information. We may use a third-party payment processor to better ensure the security of your payment information. Such third-party processor may have its own terms and privacy policies. We recommend that you review such third-party policies when making a payment to us to understand the security measures such third-party has taken regarding your payment information. As of the last updated date of this Policy, we are using Stripe as a third-party payment processor, but this is subject to change in our discretion. You may reach out to us if you have questions about the payment processor then in use.

HOW WE USE YOUR INFORMATION

Having accurate information about you allows us to provide you with a smooth, efficient, and customized experience. We may use your information to operate the Application, perform or fulfill services requested by you, deliver information to you about our products and services, improve and tailor our products and services to better fit our users, inform you of changes to our Application or this Policy, and to solicit additional information from you. We may also use your information to resolve disputes, troubleshoot problems, and enforce our agreements with you, including sales terms and conditions, and this Policy.

We may use your information to send you push notifications regarding your account or the Application if you opt into such communications. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Without limiting the generality of the foregoing, we may use your information to:

Compile statistical data and analysis for use internally and for our marketing purposes, provided that any such data and analysis derived from Personal Information will be de-identified to the extent that it is shared publicly or with third parties (expect where shared with Hosts as described in this Policy);
Deliver targeted advertising, coupons, newsletters, and other information regarding our promotions and the Application to you, and to administer sweepstakes, promotions, and contests;
Email you regarding your Account or services you’ve requested from us, and respond to customer service requests;
Generate a personal profile about you to make future visits to the Application more personalized;
Notify you of updates to the Application, and offer new products, services, mobile applications, and/or recommendations to you;
Help prevent fraudulent transactions, monitor against theft, and protect against criminal activity;
Process payments and refunds; and
Request feedback and contact you about your use of the Application.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you with certain third parties in certain situations described herein.

If you are a participant in a phone or video conference for which you have allowed access to the Application, your Personal Information may be shared with the host of the conference. We may also share certain metrics regarding your interactions with the conference with the host, including responses to questions or surveys, whether or not you spoke or participated in any chat feature of the conference, and similar details. These details may not be de-identified and may be associated with your name or other identifier.

We may disclose your information to third party service providers, including but not limited to IT service providers, who perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, marketing assistance, and parties who otherwise assist us in operating the Application, improving and developing our services, and performing or fulfilling services requested by you.

Further, you grant permission for us and our licensors to use, reproduce, copy, and publish Usage Data and any other information (including Personal Information) which has been de-identified and aggregated such that it is no longer capable of identifying you, for any lawful purposes, including for our marketing and promotional purposes, and providing the same to unaffiliated third parties for marketing and selling their products and services.

We may allow third-party companies to serve ads when you visit the Application. These companies may use information about your visits to the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

If the Application allows you to interact with other users of the Application, those users may see your name, profile photo, and descriptions of your activity or engagement metrics, and any other information that you choose to share or include on a public profile. Further, if the Application allows you to post public comments, contributions, or other content to or through the Application, your posts may be viewed by all users and may be publicly distributed outside the Application in perpetuity.

Additionally, we may share your information, including your Personal Information:

In response to legal process, court order, or government or regulatory request, and if we believe disclosure is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Policy, and to verify or enforce compliance with the policies governing our sites and applicable laws or as otherwise required or permitted by law or consistent with legal requirements;
To enforce other agreements with you, including for billing and collection purposes;
With our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include companies that we control, are controlled by us, or that are under common control with us;
With credit card issuers and financial institutions in order to obtain payment from you, such that they may process payments and refunds, verify the absence of fraud, or assist in debt collection, in the course of the performance of a contract or on the basis of other legitimate interests;
As part of a transfer or assignment if we are acquired by, sold to, or merged with another entity, or otherwise reorganized or liquidated; and
If we believe that you may harm, or have harmed, our property or infringed upon our rights, or harmed the property or infringed upon the rights of other users or third parties, in order to report, disclose, limit, respond to, or prevent such conduct or activity.

SECURITY OF YOUR INFORMATION

We have put in place industry-standard procedures to safeguard and help prevent unauthorized access to information and data, to maintain data security, and to correctly use the information we collect online, such as dedicated virtual private servers, a web application firewall, an encrypted database, and no third-party access to the server. Unfortunately, we cannot guarantee that 100% of the data transmissions are secure. Therefore, while we strive to protect your personally identifiable information, you acknowledge that: (a) there are limitations to security and privacy of the internet that are beyond our control; (b) the security, integrity and privacy of your Personal Information exchanged between you and us cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

CHILDREN UNDER THE AGE OF 18

Our Website is not intended for children under 18 years of age. No one under age 18 should provide any personal information to or through the Application. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us immediately.

THIRD-PARTY WEBSITES

The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.

YOUR OPTIONS AND ACCOUNT TERMINATION

To the extent we rely on your consent to process any information, you may revoke that consent at any time (except to the extent we are required to retain the information for the limited purposes of completing a service you have requested). You may at any time review or change the information in your account or terminate your account by logging into your account settings and updating your account if such option is available, or by contacting us using the contact information provided below.

Upon your request to terminate your Account, we will deactivate or delete your account from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce this Policy, and/or comply with legal requirements.

Please note that when your account is deleted you may not be able to use or access certain aspects of the Application. If you approve or agree to allow a third party service to access the Application once you have deleted your account, you are agreeing to this Policy, and we may reinstate or create a new profile for you.

We may continuously maintain and use, as set forth herein, any anonymized, de-identified, or aggregated data we collected during your use of the Application.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Townhall
PO Box 2393
Kitty Hawk, NC 27949
info@townhall.pro

CALIFORNIA CONSUMER PRIVACY ACT

The following provisions apply to you if you are a California consumer. For the purposes of this section, “Personal Information” is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, and does not include information that is publicly available, or deidentified or aggregated information.

You have the right to request that we disclose to you the Personal Information we collect, use, disclose, and sell, including (i) the categories of, and specific pieces of, Personal Information that we have collected about you; (ii) the categories of sources from which the Personal Information was collected; (iii) the business or commercial purpose for collecting such Personal Information; (iv) if any, the categories of third parties with whom we have shared such Personal Information; and (v) if any, the categories of your personal information that we have disclosed to third parties for a business purpose.

You have the right to request that we delete any Personal Information about you which we have collected from you, unless that information is necessary for us to retain pursuant to Cal. Civ. Code § 1798.105(d), which for instance, allows retention of such information for completing the transaction for which the Personal Information was collected, detecting security incidents, or complying with a legal obligation.

To submit requests for information or deletion pursuant to this section, you may reach out via email at the address noted in the “CONTACT US” section above. Please note that we can only delete information which is stored on our systems. Only you, or someone legally authorized to act on your behalf, may make a request for information or deletion. We cannot respond to a request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will make a determination regarding whether the information provided by you for verification purposes is reliable, and if not, we may request additional information, or may decline to provide certain information to you. Without limiting the verification procedures available to us:

We may request certain data points from you to compare those with the information we have on file for you. We may require at least two data points which match our records for information deemed less sensitive. If you are requesting certain types of sensitive information, we may require at least three data points from you, which must match our records, or we may require a signed declaration under penalty of perjury that the personal information you request is about you.
If a person or entity purporting to be your authorized agent reaches out on your behalf to obtain information or request deletion of information pursuant to this Policy, and unless that agent has provided a power of attorney to us, we may require that you verify your identify directly with us, or directly confirm to us that you have provided the agent permission to submit such request on your behalf.

For a disclosure request made pursuant to this section, we will endeavor to disclose and deliver requested information to you, without charge, within 45 days of receiving your request, and if an extension of such timeframe is reasonably necessary, we will provide you notice of such extension. The information provided will cover the 12-month period preceding our receipt of your request. We are not required to provide such information more than twice in a 12-month period. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. We are not required to, and may not in some cases, retain Personal Information about you if you have submitted the Personal Information in a one-time transaction.

We will not discriminate against you in violation of Cal. Civ. Code § 1798.125 for exercising your rights set forth in this section of the Policy.

We do not have knowledge that we have sold the Personal Information of any consumers under 16 years of age.

We do not sell, or disclose, release, transfer, or otherwise communicate your Personal Information to any third-party for monetary or other valuable consideration, except to the extent that sharing Reports with Hosts (as further described in the Terms of Service) could be considered engaging in such actions. If you do not desire for us to share Reports with Hosts, which could include your Personal Information as described in the Policy, your option to opt-out of such sharing of data is (i) cease use of the Application, and (ii) submit a request for deletion pursuant to this section.

We have collected, and disclosed for the business purposes set forth herein, certain information from the following categories of Personal Information as set forth in Cal. Civ. Code 1798.140(o)(1), from our users in the past 12 months: (i) identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers; (ii) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (iii) internet or other similar network activity information, including, but not limited to, as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement; (iv) geolocation data; (v) sensory data; and vi) inferences drawn from other personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the categories of personal information listed above from the categories of sources set forth above in this Policy. We collect the categories of personal information for the business purposes set forth above in this Policy.

ADDITIONAL STATE-SPECIFIC RIGHTS

Additional US states, such as Virginia, Connecticut, Utah, and Colorado, may provide their residents with rights to:

Confirm whether we process their personal information;
Access and delete certain personal information;
Data portability;
Opt-out of personal data processing for targeted advertising and sales;
Correct inaccuracies in their personal information, taking into account the information's nature processing purpose; and
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Further, Nevada provides its residents with limited rights to opt-out of certain sales of personal information.

To exercise any of these rights please use the contact information contained in the “CONTACT US” or “CALIFORNIA CONSUMER PRIVACY ACT” sections of this Policy. If a law or regulation governs our conduct and you have rights under such law, we will respond in accordance with such law or regulation.

GDPR COMPLIANCE AND LEGAL BASIS FOR PROCESSING
If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, we process your personal data based on one or more lawful bases under the General Data Protection Regulation (GDPR) (EU) 2016/679 and its UK counterpart. The specific legal bases we rely on include:

Performance of a Contract (Article 6(1)(b)) – When we process your data to provide the services you have requested, such as managing your account, processing payments, or providing customer support.
Consent (Article 6(1)(a)) – When you have given us explicit consent to use your personal data for certain purposes, such as marketing communications or non-essential cookies. You may withdraw consent at any time.
Legitimate Interests (Article 6(1)(f)) – When processing is necessary for our legitimate business interests, such as improving our services, ensuring security, and preventing fraud, unless your rights and freedoms override these interests.
Legal Obligation (Article 6(1)(c)) – When we need to process your data to comply with applicable laws, such as tax, fraud prevention, or regulatory requirements.
Vital Interests (Article 6(1)(d)) – In rare cases, where we need to process personal data to protect someone’s life or safety.

You may object to processing based on legitimate interests at any time by contacting us at info@townhall.pro.

YOUR GDPR RIGHTS & HOW TO EXERCISE THEM

Right to Access (Article 15) – You can request a copy of the personal data we hold about you.
Right to Rectification (Article 16) – You can request correction of inaccurate or incomplete personal data.
Right to Erasure (Article 17) – You can request deletion of your personal data (“Right to be Forgotten”), subject to legal obligations.
Right to Restrict Processing (Article 18): You may request that we limit the processing of your data in certain circumstances, including if you contest its accuracy or object to processing.
Right to Data Portability (Article 20): You may request a copy of your personal data in a structured, commonly used, and machine-readable format, and you may request that we transmit this data to another controller where technically feasible.
Right to Object (Article 21) – You can object to data processing for direct marketing or other purposes based on legitimate interests.We will stop processing unless we have compelling legitimate grounds that override your rights or the processing is necessary for legal claims.
Right Not to be Subject to Automated Decision-Making (Article 22) – If we use automated decision-making (including profiling) that significantly affects you, you have the right to request human intervention.

To exercise any of these rights, please email us at info@townhall.pro with the subject “GDPR Data Request” and specify the nature of your request. We will respond within one month (or up to three months for complex requests, in which case we will notify you of the delay).

If you believe we have violated your GDPR rights, you may file a complaint with your local Data Protection Authority (DPA).

DATA RETENTION POLICY
We retain your personal data only as long as necessary for the purposes outlined in this Policy, unless a longer retention period is required by law.

Account Data – Retained as long as your account is active.
Payment Data – Retained for 7 years to comply with tax and regulatory requirements.
Marketing Data – Retained for 2 years, unless you opt out earlier.
Usage Data (analytics, logs) – Retained for 12 months for service improvements.

Once the retention period expires, we securely delete or anonymize your data.

DATA BREACH NOTIFICATION
We retain your personal data only as long as necessary for the purposes outlined in this Policy, unless a longer retention period is required by law.We have implemented security measures to protect your data. However, if a data breach occurs that is likely to result in a high risk to your rights and freedoms, we will:

Notify the relevant Data Protection Authority within 72 hours.
Inform affected users without undue delay, describing the nature of the breach, possible consequences, and our mitigation efforts.

If you suspect any unauthorized access to your data, please contact us immediately at info@townhall.pro.

EU REPRESENTATIVE AND DATA PROTECTION OFFICER (DPO)
We have implemented security measures to protect your data. However, If required under GDPR, we will appoint an EU representative and a Data Protection Officer (DPO). Contact information will be updated accordingly. For GDPR-related inquiries, contact info@townhall.pro

AUTOMATED DECISION-MAKING & PROFILING
If our services use automated decision-making (e.g., AI-based moderation, behavior-based analytics), we will:

Explain the logic behind decisions.
Allow you to contest decisions.
Offer a human review upon request.

If you wish to opt out of automated decision-making, contact info@townhall.pro

DATA TRANSFERS FROM THE EU/EEA
Townhall Pro, Inc. is headquartered in the United States, which means that if you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, your personal data (name, email, job title) will be transferred to, stored, and processed in the United States.

We rely on the following lawful mechanisms under Article 46 of the General Data Protection Regulation (GDPR) to ensure your data remains protected:

Standard Contractual Clauses (SCCs): We have implemented EU Commission-approved SCCs, which ensure that any data transferred outside the EEA receives a level of protection equivalent to GDPR standards.
Data Transfer Impact Assessment (DTIA): Before transferring any EU personal data to the U.S., we conduct a DTIA to assess risks and implement additional safeguards where necessary.
Encryption & Security Measures: All data transfers are encrypted in transit and at rest using industry-standard security protocols (TLS 1.2+, AES-256).

By using our services, you acknowledge that your data may be transferred to the United States under these safeguards.

DATA TRANSFER IMPACT ASSESSMENT (DTIA) REFERENCE
In compliance with Schrems II and GDPR requirements, we perform a Data Transfer Impact Assessment (DTIA) for EU personal data transfers. This assessment includes

Reviewing U.S. data protection laws to ensure compliance with GDPR.
Evaluating the necessity of additional security safeguards, such as encryption and pseudonymization.
Assessing the risk of government access to EU personal data and implementing mitigation measures.

You may request general information about our DTIA findings by contacting info@townhall.pro.

LIABILITY AND LIMITATIONS ON DATA TRANSFERS
While we take all reasonable measures to protect your personal data, you acknowledge that:

No data transmission is 100 percent secure. While we use encryption and security best practices, there is always some level of risk in transmitting data over the internet.
Townhall Pro is not liable for third-party actions. If you access our services via third-party platforms, such as social media logins or integrations, those providers may have their own privacy policies that govern data collection.
You accept the risks associated with cross-border data transfers. By using our services, you agree that your data may be subject to U.S. legal requirements that differ from GDPR protections in the EEA.

If you do not agree with these terms, you should not use our services.

CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time, for any reason, at our sole discretion. Any changes will be effective immediately upon posting the updated Privacy Policy on our website, unless otherwise required by law.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of the Application after any changes constitutes your acceptance of the revised Privacy Policy.

If required by applicable law, we will notify you of material changes via email, in-app notification, or other means before the changes take effect.

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