Privacy Policy

Privacy Policy of Towboss LLC

Towboss LLC (“Towboss”) collects some Personal Data from its Users.

Owner and Data Collector:

Towboss

1 Washington Mall #1482

Boston, MA 02108

United States

info@towboss.com

Towboss may change this Privacy Policy at any time, at its discretion. Your continued use of the platform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

Types of Data Collected: Among the types of Personal Data that Towboss collects, by itself or through other parties, there are: Tracker; Usage Data; device information; shopping history; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; email address; phone number; Data communicated while using the service. 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Towboss. Unless specified otherwise, all Data requested by Towboss is mandatory and failure to provide this Data may make it impossible for Towboss to provide its services. 

Methods of Processing: The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Towboss (administration, sales, marketing, legal, system administration) or external parties (such as other party technical service providers, mail carriers, hosting providers, IT companies, communications agencies, marketing partners) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

The Purposes of Processing: The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or other parties), detect any malicious or fraudulent activity, as well as the following: Handling payments, Analytics, Remarketing and behavioral targeting, Tag Management, Advertising, Displaying content from external platforms, Managing contacts and sending messages, Contacting the User, Access to other party accounts and Connecting Data.For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed Information on the Processing of Personal Data

Facebook Permissions Asked by Towboss: Towboss may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Towboss to connect with the User's account on the Facebook social network, provided by Facebook Inc. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

-Basic information: By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

-Business Management API: Read and write with Business Management

-APIChat: Provides applications that integrate with Facebook Chat the ability to log in Users.

-Mobile Messaging on behalf of Page: Send and receive mobile messages on behalf of a Facebook Page.

-Page Messaging: Send and receive messages through a Facebook Page.

Google Ad Manager (Google LLC): Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy. This service uses the “DoubleClick” Cookie, which tracks use of Towboss and User behavior concerning ads, products and services offered. Users may decide to disable all the Double Click Cookies by going to: Google Ad Settings.

Facebook Lookalike Audience (Facebook, Inc.) Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of Towboss or engagement with relevant content across the Facebook apps and services. On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Google Analytics (Google LLC) Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Towboss, to prepare reports on its activities. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

FullStory (FullStory, Inc.) FullStory is an analytics and heat mapping service provided by FullStory, Inc.FullStory maps how frequently Users interact with the different areas of Towboss, allowing the Owner to draw conclusions about their interests and preferences. FullStory further allows for the recording of mapping sessions making them available for later visual playback.

Google Ads Conversion Tracking (Google LLC) Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on Towboss.

Facebook Ads Conversion Tracking (Facebook pixel) (Facebook, Inc.)Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Towboss. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Zapier (Zapier, Inc.) Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between services.

Mailing list or newsletter (Towboss) By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Towboss. Your email address might also be added to this list as a result of signing up to Towboss or after making a purchase.

Stripe (Stripe Inc): Stripe is a payment service provided by Stripe Inc.

Twilio (Twilio, Inc.)Twilio is a phone numbers management and communication service provided by Twilio, Inc.

Google Ads Remarketing (Google LLC) Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of Towboss with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

Facebook Custom Audience (Facebook, Inc.) Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Towboss with the Facebook advertising network. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Facebook Remarketing (Facebook, Inc.) Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Towboss with the Facebook advertising network.

Google Tag Manager (Google LLC)Google Tag Manager is a tag management service provided by Google LLC.Information on opting out of interest-based advertising.

Cookie Policy: Towboss uses Trackers. To learn more, Users may consult the Cookie Policy.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes.Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;Processing is necessary for compliance with a legal obligation to which the Owner is subject;Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by another party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Retention Time: Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. Therefore: 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 fulfill 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.

Additional Information About Data Collection and Processing

Legal action: The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Towboss or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal DataIn addition to the information contained in this privacy policy: Towboss may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

Information not contained in this policy: More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy: The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Towboss and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references: Personal Data (or Data)Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data: Information collected automatically through Towboss (or other party services employed in Towboss), which can include: the IP addresses or domain names of the computers utilized by the Users who use Towboss, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User: The individual using Towboss who, unless otherwise specified, coincides with the Data Subject.

Data Subject: The natural person to whom the Personal Data refers.

Data Processor (or Processor): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Towboss. The Data Controller, unless otherwise specified, is the Owner of Towboss.

Towboss (or this Application): The means by which the Personal Data of the User is collected and processed.

Service: The service provided by Towboss as described in the relative terms (if available) and on this site/application.

European Union (or EU): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie: Cookies are Trackers consisting of small sets of data stored in the User's browser.TrackerTracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Latest update: December 31, 2023. Towboss relies on information from various sources, including clients and other parties, but cannot guarantee the accuracy and completeness of that information.