Definitions and legal references
- This Website (or this Application)
- The property that enables the provision of the Service.
- Owner (or We)
- Touchstone CPM – The natural person(s) or legal entity that provides this Website and/or the Service to Users.
- User (or You)
- The natural person or legal entity that uses this Website.
- The service provided by this Website as described in these Terms and on this Website.
- Personally Identifiable Information
- Refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. Personally Identifiable Information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual.
- A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- This Application collects some Personal Data from its Users.
- Owner and Data Controller
- Touchstone CPM
- Owner contact email:
- [email protected]
What Personally Identifiable Information is collected?
We may collect basic user profile information from all of our Users. We collect the following additional information from our Users: the name, email address, phone number, address, the nature and size of the business, that the User intends to purchase or sell.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
What organizations are collecting the information?
In addition to our direct collection of information, our third party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect this information from our Users. We do not control how these third parties use such information, but we do ask them to disclose how they use personal information provided to them from Users. Some of these third parties may be intermediaries that act solely as links in the distribution chain, and do not store, retain, or use the information given to them.
The detailed information on processing of Personally Identifiable Information is shown below:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC. Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal data processed : Cookies, Usage Data
How does the Website use Personally Identifiable Information?
We use Personally Identifiable Information to customize the Website, to make appropriate service offerings, and to fulfill buying and selling requests on the Website. We may email Users about research or purchase and selling opportunities on the Website or information related to the subject matter of the Website. We may also use Personally Identifiable Information to contact Users in response to specific inquiries, or to provide requested information.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
With whom may the information may be shared?
We may share Personally Identifiable Information and/or aggregated information about our Users, including the demographics of our Users, with our affiliated agencies and third party vendors. We also offer the opportunity to “opt out” of receiving information or being contacted by us or by any agency acting on our behalf.
How is Personally Identifiable Information stored?
Personally Identifiable Information collected by Touchstone CPM is securely stored and is not accessible to third parties or employees of Touchstone CPM except for use as indicated above.
What options are available to Users regarding collection, use and distribution of the information?
Users may opt out of receiving unsolicited information from or being contacted by us and/or our vendors and affiliated agencies by responding to emails as instructed, or by either :
- Emailing us at [email protected]
Are Cookies Used on the Website?
with the drawback that certain features of Website may not function properly without the aid of cookies.
Cookies used by our service providers
How does Touchstone CPM use login information?
Touchstone CPM uses login information, including, but not limited to, IP addresses, ISPs, and browser types, to analyze trends, administer the Website, track a Users movement and use, and gather broad demographic information.
What partners or service providers have access to Personally Identifiable Information from Users on the Website?
How does the Website keep Personally Identifiable Information secure?
All of our employees are familiar with our security policy and practices. The Personally Identifiable Information of our Users is only accessible to a limited number of qualified employees who are given a password in order to gain access to the information. We audit our security systems and processes on a regular basis. Sensitive information, such as credit card numbers or social security numbers, is protected by encryption protocols, in place to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering, and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to Users for any such occurrences.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data.The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You.You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data.This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data.You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data.We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent.You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Information We Collect
The Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
In particular, Website has collected the following categories of personal information from its consumers within the last 12 months:
|A.Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||NO|
|B.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||NO|
|C.Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D.Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E.Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F.Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a Website, application, or advertisement.||NO|
|G.Geolocation data.||Physical location or movements.||NO|
|H.Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I.Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J.Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K.Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like certain health or medical information and other categories of information protected by different laws.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates’ assets in which personal information held by us or our affiliates about our Website users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers.
- Data Aggregators.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
- The right to notice.You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request.Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale of Personal Data (opt-out).You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
- The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- The right not to be discriminated against.You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
- Denying goods or services to You.
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of goods or services to You.
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:
- By email: Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if we cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
How can Users correct any inaccuracies in Personally Identifiable Information?
Users may contact us to update Personally Identifiable Information about them or to correct any inaccuracies by either:
- Emailing us at [email protected]
Can a User delete or deactivate Personally Identifiable Information collected by the Website?
We provide Users with a mechanism to delete/deactivate Personally Identifiable Information from the Website’s database by contacting. However, because of backups and records of deletions, it may be impossible to delete a Users entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.
These are summarized rights that you have under data protection law:
- The right to access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object to processing
- The right to data portability
- The right to complain to a supervisory authority
- The right to withdraw consent
Links to other websites
https://touchstonecpm.com contains links to other websites. Please note that when you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.
Last Updated: August 4, 2022