PRIVACY POLICY

INTRODUCTION

Touch Won and Subsidiaries ("Touch Won", "we", "us" or "our") is registered in North Carolina. Touch Won is a marketing product for businesses. A business (a "vendor") pays a monthly subscription and gets its own coin code in the Touch Won app. The vendor's customers sign up in the app under that code, so they find the vendor under its own name, and the vendor builds its own customer list.

This Privacy Policy explains, in plain words, what personal information we collect, how we use it, who we share it with, and the choices and rights you have. It applies when you visit touchwon.com or portal.touchwon.com (the vendor portal and dashboard), when you use the Touch Won app, and when you contact us (together, the "Services").

Two promises up front: we never sell vendor or customer data, and a vendor's customers stay that vendor's customers. We don't take them, and we don't give one vendor's customer list to any other vendor.

If you are a vendor, this policy is part of our Terms & Conditions. If you don't agree with this policy, please don't use the Services. Questions? Email us at support@touchwon.com.

This policy covers:

1. Information we collect
2. Cookies and similar tools
3. How we use information
4. How we share information
5. Where we get information
6. Messages we send
7. Your choices and privacy rights
8. Where your information is stored
9. How we protect information
10. Children
11. How long we keep information
12. Changes to this policy
13. Language
14. Contact us

1. INFORMATION WE COLLECT

"Personal information" means information that identifies you or could reasonably be linked to you, such as your name, email address or phone number. What we collect depends on how you use the Services.

1.1 Vendors (business accounts)

When a business signs up in the vendor portal, we collect the name, email address and phone number of the person signing up, a password, the coin code the business picks, the subscription it chooses, and any account details it adds or edits later in the vendor dashboard.

1.2 App users (customers of our vendors)

When you sign up in the Touch Won app, we collect your mobile phone number and the coin code of the business you are signing up with. We send a one-time PIN to your phone by text message to confirm the number. We then keep your account number, the business your account belongs to, the date your account was created, and your balance and activity records under that business's code. A vendor can also add a customer account for you directly from its dashboard using your phone number. If you sign up with more than one business, each one is a separate account.

1.3 Payment information

Vendor subscriptions are paid by card through Stripe, our payment processor. Card details entered on our signup page go to Stripe, which processes and stores them under its own privacy policy. We keep records of your subscription, charges and payment status, and Stripe may share limited details with us, such as the card brand, last four digits and expiry date. App users do not pay Touch Won through the app, so we do not collect payment information from them.

1.4 Usage and technical information

When you use our websites, portal or app, our servers and tools automatically record technical information, such as your IP address, browser and device type, operating system, the pages or screens you view, dates and times of access, and error logs. From the Touch Won app, we collect device information such as your device type, operating system, app version and IP address. The app does not collect your precise location unless you allow it in your device settings.

1.5 Communications

When you email us, call us, text us, fill out a form on touchwon.com or reply to one of our messages, we keep what you send us, such as your name, business name, email address, phone number and the content of your message. For our text messaging program, we also keep records of your consent and any opt-out request.

We don't ask for sensitive personal information, such as Social Security numbers, health information or precise location, and we ask that you not send it to us.

2. COOKIES AND SIMILAR TOOLS

Our websites use cookies, pixels, tags and similar tools. Some are placed by us and some by companies we work with. We use them in these ways:

• Necessary: to keep you signed in, protect forms from misuse and keep the site secure (for example, a session cookie and a security token cookie). The site won't work properly without these.
• Payments: Stripe uses its own cookies on our signup and checkout pages to process payments and help prevent fraud.
• Analytics and advertising: touchwon.com uses the Meta Pixel (from Meta, the company behind Facebook and Instagram) to measure visits and the results of our ads, and HubSpot to understand how visitors use the site and to manage contact form inquiries. These companies may collect information about your visit, such as your IP address, browser and the pages you view, and use it under their own privacy policies. We may also work with other analytics and advertising providers, such as Meta and HubSpot, which collect similar information under their own privacy policies.

Your choices: you can block or delete cookies in your browser settings, though some parts of the site may stop working. You can control ads from Meta in your Facebook or Instagram ad settings. On a phone, you can limit ad tracking in your device's privacy settings. Our websites do not currently respond to browser "Do Not Track" signals. We honor Global Privacy Control (GPC) browser signals where required by law.

3. HOW WE USE INFORMATION

We use personal information to:

• Provide the Services: create and run vendor and app accounts, confirm phone numbers with a PIN, connect each app user to the business whose code they used, and show each vendor its own customer list and activity reports in its dashboard.
• Bill vendors: process subscription payments, keep billing records and handle billing questions.
• Support you: answer questions, help vendors set up their coin code and respond to requests.
• Communicate with you: send account, billing and service messages and, where allowed, marketing messages about Touch Won (see section 6).
• Improve the Services: understand how the Services are used, fix errors and build new features.
• Keep the Services safe: prevent fraud, misuse and unauthorized access, and enforce our Terms.
• Meet legal duties: comply with the law, respond to lawful requests and protect our legal rights.

4. HOW WE SHARE INFORMATION

We never sell vendor or customer data. We share personal information only in these situations:

• With the business you signed up under (app users): when you sign up under a vendor's coin code, or a vendor adds you, that vendor can see your account in its dashboard, including your phone number, account number, balance and activity under its code. That customer relationship belongs to the vendor, and the vendor may contact you as the law allows. Each vendor is responsible for how it uses its own customer list under its own privacy practices. We don't give one vendor's customers to another vendor.
• With service providers: companies that help us run the Services and may use the information only to do that work for us. These include our payment processor (Stripe), our website and server hosting provider, our text messaging provider (used to send PINs and messages), our customer relationship and email tools (such as HubSpot), and our ad measurement partner (Meta, through the Meta Pixel described in section 2).
• For legal reasons and safety: when we believe in good faith that the law, a court order, a subpoena or another legal process requires it, or that it is needed to protect the rights, property or safety of Touch Won, our users or the public, or to prevent fraud or illegal activity.
• With professional advisors: such as lawyers, accountants, auditors and insurers, under a duty of confidentiality.
• In a business transfer: if Touch Won is involved in a merger, acquisition, financing, reorganization, bankruptcy or sale of all or part of its assets, personal information may be transferred as part of that deal. The new owner must keep using it in line with this policy, or tell you before anything changes.
• With your permission: when you ask us to or agree to it.

Text messaging: no mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent will not be shared with any third parties. We may also share information that has been combined or de-identified so that it no longer identifies anyone.

5. WHERE WE GET INFORMATION

• From you, when you sign up, use the Services or contact us.
• From vendors, when a vendor adds a customer account from its dashboard.
• From our payment processor (Stripe), about vendor payments.
• Automatically, from your browser or device, through our servers and the tools described in section 2.
• From our analytics and advertising partners, such as reports on how our ads and website perform.

6. MESSAGES WE SEND

We send service messages, such as PIN codes, account notices, billing receipts and important changes. You can't opt out of these while you have an account, because they are needed to run it.

We may also send vendors and business contacts marketing emails or texts about Touch Won where the law allows. You can opt out of marketing emails at any time by using the unsubscribe link or emailing support@touchwon.com. For text messages, reply STOP to opt out or HELP for help. Message and data rates may apply. Giving consent to marketing texts is never a condition of buying anything. Our SMS Privacy Policy has more details on our text messaging program.

Messages a vendor sends to its own customers come from that vendor, not from Touch Won. To stop them, contact the vendor directly.

7. YOUR CHOICES AND PRIVACY RIGHTS

7.1 Your account

Vendors can review and update their account details in the vendor dashboard and can close their account there. App users can ask us for help with their account by emailing support@touchwon.com.

7.2 Your rights

Depending on where you live, you may have some or all of these rights over your personal information:

• Know and access: ask whether we have personal information about you and get a copy of it.
• Portability: get a copy of it in a usable format.
• Correct: ask us to fix information that is wrong or out of date.
• Delete: ask us to delete it.
• Opt out: opt out of the sale of personal information, of targeted advertising, and of profiling that has legal or similarly significant effects. We do not sell personal information, and we do not use it for that kind of profiling.
• Withdraw consent: where we rely on your consent, you can withdraw it at any time.
• Equal treatment: we will not deny you service, charge you a different price or give you a lower level of service because you used your rights.

These rights have limits. For example, we may keep information we need for billing, security, legal reasons or to finish a transaction you asked for.

7.3 U.S. state privacy rights

A growing number of U.S. states, including California, Virginia, Colorado, Connecticut, Utah, Texas and Oregon, give their residents privacy rights like those listed above. Wherever you live in the United States, you can send us a request, and we will honor it as the laws of your state require.

About ad tracking: under some state laws, letting an advertising partner such as Meta collect information through a pixel on our website can count as "sharing" personal information or as "targeted advertising", even though no money changes hands. If you want to opt out of this, email support@touchwon.com with the subject "Opt out", and use the cookie and ad settings described in section 2.

North Carolina residents: you may send us the same requests, and we will respond to them. Under North Carolina law, if a security breach exposes certain personal information about you, we will notify you as the law requires.

7.4 How to make a request

Email support@touchwon.com and tell us what you are asking for. To protect you, we will check your identity before acting on a request, usually by matching information we already have, such as your account email or phone number. You don't need an account to make a request. You may use an authorized agent; we will ask for your signed permission and may still need to confirm your identity with you. We will use the information you give us in a request only to check your identity and handle the request.

We aim to respond within 45 days. If we need more time, we will tell you why. If we turn down your request, we will explain the reason, and you can appeal by replying with the subject "Appeal". If you are not satisfied with the result of your appeal, you may contact your state attorney general.

If you are an app user and want a vendor to stop using or to delete information it has about you, contact that vendor directly. We will help with the information we hold.

8. WHERE YOUR INFORMATION IS STORED

The Services are meant for people and businesses in the United States. We and our service providers store and process personal information in the United States. Our data is stored in the United States.

9. HOW WE PROTECT INFORMATION

We use reasonable administrative, technical and physical safeguards to protect personal information, such as encrypted (HTTPS) connections, password-protected accounts and limits on who can access data. Card details are handled by Stripe. No method of sending or storing information is completely secure, so we can't promise absolute security. Please keep your password and PIN private, and tell us right away at support@touchwon.com if you think your account or information is at risk.

10. CHILDREN

The Services are not for anyone under 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we will delete it. If you think someone under 18 has given us personal information, please email support@touchwon.com.

11. HOW LONG WE KEEP INFORMATION

We keep personal information for as long as we need it to provide the Services and for the purposes in this policy, including to meet legal, tax and accounting duties, resolve disputes and enforce our agreements. When we no longer need it, we delete it or de-identify it. When a vendor closes its account, we delete or de-identify the account data within a reasonable time, unless the law requires us to keep it. Before closing, a vendor can request an export of its customer list by emailing support@touchwon.com. We keep records of text messaging consent and opt-outs for as long as needed to run the program and meet legal duties.

12. CHANGES TO THIS POLICY

We may update this policy from time to time. When we do, we will post the new version on this page and change the "last updated" date above. If a change is important, we will also tell vendors by email or in the vendor dashboard. If you keep using the Services after a change takes effect, the updated policy applies to you.

13. LANGUAGE

This policy is written in English. If we provide a translation, the English version controls if the two differ.

14. CONTACT US

If you have questions about this policy or want to make a privacy request, contact Touch Won and Subsidiaries by email at support@touchwon.com.