Privacy Policy

Privacy Policy

We take Your privacy very seriously. This Privacy Policy describes the policies and procedures regarding the collection, use and disclosure of Your information in connection with Your use of https://treads.app or any other platforms or website(s) offering the Treads Services (collectively, “Website”) or any Treads content, products, or services made available by Us (together with the Website, the “Treads Services” or “Services”). We receive information about You from various sources, including without limitation: (i) if You register for the Services, through Your user account (Your “Account”); (ii) Your use of the Services generally; and (iii) from third party websites and services. In order to provide You with the Services, We will collect, transfer, manipulate, store, disclose, and use Your information as described in this Privacy Policy. We encourage You to read this Privacy Policy carefully. It will help You make informed decisions about sharing Your personal information with us.

The defined terms in this Privacy Policy, if not defined herein, shall have the same meaning as in the Treads Terms of Service, available at https://treads.app/tos (the “Terms of Service” and together with the Privacy Policy, the “Terms”). You should read the Terms before accessing or using the Services. By accessing and using our Services, You consent to the terms of this Privacy Policy, and agree to be bound by it and our Terms. Please note that with respect to the Treads Services, this Privacy Policy applies instead of any other privacy agreement You may have with us.

We collect Your Personal Information.

The information We gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, We may request, collect and/or display some of Your Personal Information. “Personal Information” is information about an identifiable individual, and may include information such as the individual’s name, email address, home and office street addresses, telephone number, bank account details, credit card information, and vehicle information such as model, year, make, tire brand and size, VIN (for purposes of recall notices only), mileage, and geo-location (which we use for purposes of calculating mileage only). “Personal Information” does not include information about you and your use of the Services that has been anonymized and aggregated (meaning it is not identifiable to you). We may also use paid search and social media to market to you, and in certain instances, we may obtain Personal Information about you in that context.

We may collect Personal Information directly from You when You:

· Register to use the Services,

· Use the Services,

· Post to the Treads social media community, forum or on our blog,

· Contact the Treads support team, download the Treads app and/or visit the Website.

· You can always choose not to provide Your Personal Information, but it may mean that we are unable to provide You with the Services.

We may receive Personal Information from You about others.

Through Your use of the Services, We may also collect information from You about someone else. If You provide us with Personal Information about someone else, You warrant and represent that You are authorized to disclose that information to us and that We may collect, use and disclose such information for the purposes described in this Privacy Policy.

This means that You must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Privacy Policy, including the fact that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, our identity, and how to contact us.

Where requested to do so by us, You must also assist us with any requests by the individual to access or update the Personal Information You have collected from them and entered into the Services.

We collect, hold, and use Your Personal Information for limited purposes.

We collect Your Personal Information so that We can provide You with the Services. In doing so, We may use the Personal Information We have collected from You for purposes related to the Services, including but not limited to:

· Verify Your identity and perform client screening, administer the Services,

· Notify You of new or changed services offered in relation to the Services,

· Carry out marketing or training relating to the Services

· Assist with the resolution of technical support issues or other issues relating to the Services,

· Comply with applicable rules, laws and regulations, and communicate with You.

By using the Services, You consent to Your Personal Information being collected, held and used in this way and for any other use You authorize. We will only use Your Personal Information for the purposes described in this Privacy Policy or in accordance with Your express consent.

Note that We collect financial information, such as Your bank account or credit card number, credit card type and expiration date, and other such information (“Financial Information”) for payment of Your Membership Fee. We use a third party payment processor, so none of the Financial Information gathered for payment purposes ever gets processed by or resides on our systems.

When using Your Data for other purposes, You will not be identified as the source of the information.

Treads may, with the assistance of third parties, use the information provided to Treads for purposes such as improving the delivery or quality of services or technology to You and other clients, thought leadership projects, to allow You and other clients to evaluate various business transactions and opportunities, and for use in presentations to You, other clients and non-clients. When Your information is used outside of Treads or such third parties assisting them, You will not be identified as the source of the information. For example, Your information may be aggregated or anonymized so that it is not personally identifiable.

Your Data is transmitted to services over the Internet.

All Data that is entered into the Services by You, or automatically imported on Your instruction, is transferred to our servers as a function of transmission across the Internet. By using the Services, You consent to Your Personal Information being transferred to our servers as set out in this Privacy Policy.

We take steps to protect Your personal information.

We are committed to protecting the security of Your Personal Information and We take all reasonable, industry-standard precautions to protect it from unauthorized access, modification or disclosure. Your Personal Information is stored on secure servers and all Data transferred between You and the Services is encrypted. However, the Internet is not in itself a secure environment and We cannot give an absolute assurance that Your Personal Information will be secure at all times. Transmission of Personal Information over the Internet is at Your own risk and You should only input, or instruct the inputting of, Personal Information to the Services within a secure environment. You are responsible for preventing unauthorized access to Your account and Personal Information, including, for example, by protecting Your account credentials and limiting access to devices on which You access the Services.


We will advise You as soon as reasonably possible, and in accordance with applicable laws, upon discovering or being advised of a security breach where Your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorized persons or in any unauthorized manner.

We disclose Your Personal Information in limited circumstances.

We will only disclose the Personal Information You have provided to us to other parties if it is necessary and appropriate to facilitate the purpose for which Your Personal Information was collected pursuant to this Privacy Policy, including the provision of the Services. We will not otherwise disclose Your Personal Information to a third party unless You have provided Your express consent. However, notwithstanding the foregoing, We do reserve the right to access, read, preserve, and disclose any information as We reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Where possible and appropriate, We will notify You if We are required by law to disclose Your Personal Information.

We may employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide the Services to You. Unless We tell You differently, our Agents do not have any right to use Personal Information or other information We share with them beyond what is necessary to assist us. You hereby consent to our sharing of Your Personal Information with our Agents.

Finally, We may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if We, or substantially all of the assets relating to Treads, were acquired, or if the Treads business is discontinued or We go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use Your Personal Information as set forth in this Privacy Policy.

You may request access to Your Personal Information.

It is Your responsibility to ensure that the Personal Information You provide to us is accurate, complete and up-to-date. You may request access to the Personal Information We hold about You, or request that We update or correct any Personal Information We hold about You, by setting out Your request in writing and sending it to us at concierge@treads.app.

We will process Your request as soon as reasonably practicable, provided We are not otherwise prevented from doing so on legal grounds. If We are unable to meet Your request, We will let You know why. In some circumstances, it may be necessary for us to seek to arrange access to Your Personal Information through a mutually agreed intermediary (for example, the Subscriber).

We’ll only keep Your Personal Information for as long as We require it for the purposes of providing You with the Services. However, We may also be required to keep some of Your Personal Information for specified periods of time, for example under certain laws relating to corporations, money laundering, and financial reporting legislation, and to comply with professional standards.

California Privacy Rights

California has adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020.  We comply with the requirements of the CCPA to the extent they apply to us.
 
If you are a California resident and we qualify as a “business” under the terms of that law, you will have the following rights:
 
  • You have the right to request that we disclose the categories and the specific items of Personal Information about you that we collect, use, disclose, and/or sell and that Personal Information about you that we have collected, used, disclosed, and/or sold during the 12 months prior to your request.
  • You also have the right to have the Personal Information we collect about you deleted.  We use a two-step process to verify your identity and to have the information deleted. Your rights to have Personal Information deleted are subject to several exceptions, specifically the Personal Information that is necessary for us to:
    • complete your transaction;
    • provide you a good or service;
    • perform a contract between us and you;
    • protect your security and prosecute those responsible for breaching it;
    • fix our system in the case of a bug;
    • protect the free speech rights of you or other users;
    • 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 interests that adheres to all other applicable ethics and privacy laws;
    • comply with a legal obligation; or
    • make other internal and lawful uses of the information that are compatible with the context in which you provided it.
  • To make any request under the CCPA, you must complete the Data Request Form found at www.treads.app/ccpa or send an e-mail to concierge@treads.app.  You will be asked to give us your name, e-mail address, telephone number, and any other information we request to reasonably verify your identity.  We will respond to your request within 10 days after receipt of your request, and we will then take action to verify your identity and fulfill your request, as required by the CCPA.
  • We will provide you with a CSV copy of your stored data within 45 days of your request, assuming we are able to verify your identity in that period and so long as you provide a correct email address for successful correspondence.
  • You have the right not to receive discriminatory treatment by us for the exercise of any privacy rights conferred by the CCPA, which means that we will not take any action to hurt or punish you for exercising your rights under the CCPA.
  • You may designate an authorized agent to make a request under the CCPA on your behalf by writing us at concierge@treads.app. Upon receipt of your request, we will provide you with the information you will need to designate that agent.

Note that we are not allowed by law to at any time disclose your Social Security number, driver’s license number, or other government-issued identification number, financial account number, any health insurance or medical identification number, or any account password or security questions or answers.

We have listed the specific and general categories of information we have collected, disclosed, or sold in the last 12 months in the sections above entitled “We Collect Your Personal Information,” “We collect, hold, and use Your Personal Information for limited purposes,” and “We disclose Your Personal Information in limited circumstances.” Those sections also list the specific and general categories of Personal Information we have disclosed to third parties for our business purposes.

We do not sell your Personal Information.

We do not sell the Personal Information of minors under 16 years of age.

For more information, please direct your questions to us at concierge@treads.app.

The Treads Services use cookies and other tools.

In providing the Services, We utilize “cookies.” A cookie is a small text file that is stored on Your computer for record-keeping purposes. A cookie does not identify You personally or contain any other information about You but it does identify Your computer.
 

We and some of our affiliates and third-party service providers may use a combination of “persistent cookies” (cookies that remain on Your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when You close Your browser) on the Website to, for example, track overall site usage, and track and report on Your use and interaction with ad impressions and ad services.

You can set Your browser to notify You when You receive a cookie so that You will have an opportunity to either accept or reject it in each instance. However, You should note that refusing cookies may have a negative impact on the functionality and usability of the Website.

  1. Pages of the Services and our e-mails may also contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  2. We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and users who access the Services.  Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).   

We may also use third-party tracking analytics tools such as Google Analytics to help us understand how our customers and visitors use our Services.You can opt-out of any communications.

We send billing information, product information, Services updates and Services notifications to You via email and/or SMS text messaging. Our emails and text messages will contain clear and obvious instructions describing how You can choose to be removed from any mailing or messaging lists not essential to the Services. We will remove You from mailings relating to Treads at Your request. Please read the applicable unsubscribe instructions carefully. Please note that requesting to be removed from one mailing or messaging list may not result in Your being removed from all mailing or messaging lists to which You are subscribed. You may need to send separate requests to be removed from each specific mailing or messaging list to which You are subscribed.

You are responsible for transfer of Your data to third-party applications.

The Services may allow You, the Subscriber, or another Authorized User within the relevant subscription to the Services to transfer Data, including Your Personal Information, electronically to and from third-party websites, services and applications. This Privacy Policy does not apply to the practices of such third parties that We do not own or control. While We attempt to facilitate access only to those third-party websites, services, and applications that share our respect for Your privacy, We have no control over, and takes no responsibility for, the privacy practices or content of these websites, services, and applications. You are responsible for checking the privacy policy of any such applications so that You can be informed of how they will handle Your Personal Information.

Information for persons in the EU.

We provide our services in the U.S., and do not direct our activities to persons or businesses located in the EU.

You may contact us regarding any privacy concerns.

If You have questions or comments about our administration of Your personal data, please contact us at concierge@treads.app.

This Privacy Policy may be updated from time to time.

We may amend this Privacy Policy from time to time. Use of information We collect now is subject to the Privacy Policy in effect at the time such information is collected. If We make changes in the way We collect or use information, We will notify You by posting an announcement on the Services or sending You an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

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