Privacy Policy
Last Updated: September 22, 2021
This Privacy Policy describes how Toosa.com, Inc. (“we,” “our,” or “us”) collects, uses, and otherwise processes personal data that you provide to us, or that we obtain or generate, to provide you with our messaging services, including our apps, features, software, and website (“Toosa”).
This policy is intended to help you understand:
- Our services
- Our collection of information
- Our use of information
- Our disclosure of information
- Our use of cookies
- Your rights & choices
- California privacy disclosures
- European privacy disclosures
- International transfers
- Age requirements
- Changes to this Privacy Policy
- Our contact information
Our services
We issue unique phone numbers (“Toosa Numbers”) to individuals and entities or their designees (collectively, “Toosa Pros”).
Toosa Pros can use Toosa to message with the individuals who have signed up to receive their messages (“Toosa Followers”).
Please also read our Terms of Service (“Terms”), which describe the terms under which you use Toosa.
Our collection of information
We collect the following when you use Toosa:
Contact info:
To sign up as a Toosa Follower, we require certain information, such as your name, date of birth, gender identity, city, and phone number. You may have the option to provide other information as well, such as your email address. We refer to all of this as “contact info.”
If you start a conversation with a Toosa Pro by sending a text message to their Toosa Number, we collect your phone number along with the contents of the text message, so we won’t need to ask you for it. If you later start a conversation with another Toosa Pro by sending a text message to their Toosa Number, we won’t need to ask you again for your contact info. If you start a conversation with a Toosa Pro from a supported website or Internet-based messaging service, the required contact info and signup process may vary.
Note: Toosa Pros may be able to save copies of their Toosa address book for use outside of Toosa, which may include your contact info.
Account Info
To sign up as a Toosa Pro, you must set up a Toosa account. We require your email address, and you may have the option to provide email addresses for additional authorized users for your account. You may customize your account by providing a profile name, profile picture, and voicemail message.
Messaging info
When you send or reply to messages via Toosa, we collect your messages, along with message-related information (such as the phone number from which the message was sent, when the message was sent, and whether the message includes a particular word, phrase, or emoji). When you interact with messages sent via Toosa, we collect information about those interactions. We refer to all of this as “messaging info.”
Keep in mind that anyone who receives your messages via Toosa can save a copy and share your messages with others. This includes any personal information you send in a message (for example, your address), so be careful with what you choose to share.
Note: Toosa Pros may be able to save copies of their messaging info for use outside of Toosa.
Search info
When you search for content via Toosa Search Engine, we collect your search terms, along with search-related information (such as the particular word, phrase, or emoji, time stamps, content accessed, and additional info). When you interact with Toosa Search Engine via Toosa, we collect information about those interactions. We refer to all of this as “search info.”
Note: Toosa Pros may be able to save copies of their search history for use outside of Toosa.
Technical info
When becoming a Toosa Follower or a Toosa Pro, and when using our apps and website as a Toosa Pro, we collect Internet, electronic activity, and other information automatically from the devices and browsers that you use and from the messages that you send. This includes information about the type of device and operating system you use, your phone number, your IP address, cookie and device identifiers, the type and version of browser you use, app version, and your ISP or wireless carrier. We may also collect information about your location, such as by using your IP address to determine your approximate location. When using our apps and website as a Toosa Pro, we also collect information about the links you send or click on, pages you view, other information about how you use Toosa, and other standard server log information.
Payment info
You may provide us with payment information, such as your credit or debit card number, card expiration date, CVV code, and billing address.
Correspondence
When you contact our customer support team, participate in one of our surveys, contests, or promotions, or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need to resolve your question.
Other info
We may also receive information about you from other sources, including from users of Toosa, and third-party services and organizations. We may aggregate or de-identify the information described above. Aggregated or de-identified data (meaning data that cannot reasonably be tied to you or used to identify you) is not subject to this Privacy Policy.
Our use of information
We use the information described above for the following business purposes:
- To develop, operate, improve, deliver, promote, maintain, and protect Toosa (including troubleshooting, data analytics, testing, research, statistical and survey purposes);
- To send you communications (for example, we may use email to respond to support inquiries or to share information about Toosa);
- To manage our relationship with you (including providing you with the information, products and services that you request from us); and
- To keep Toosa and our users safe and secure, to enforce our Terms and other usage policies, to comply with legal requirements, and to protect or exercise our legal rights or defend against legal claims.
Our disclosure of information
We do not sell your personal information. We may share the information described above in the following ways:
- With Toosa Pros. If you are a Toosa Follower, we may share your information with the Toosa Pros you are messaging with via Toosa. The information practices of Toosa Pros are not covered by this Privacy Policy. Before signing up to message with a Toosa Pro via Toosa, we would encourage you to review that Toosa Pro’s privacy policy.
- With Toosa Followers and the general public. If you are a Toosa Pro, we may share your account information (such as your Toosa Number, profile name, profile picture, and voicemail message) and messages with Toosa Followers and the general public.
- With authorized third-party vendors and service providers. We may share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, message delivery, marketing our services, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
- With corporate affiliates. We may share your information with our corporate affiliates.
- In business transfers. We may share information about you as part of a merger or acquisition. If we are involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.
- For legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Toosa.com, Inc. and our affiliates, users, and the public.
- With your consent. If you consent, we may also share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services via Toosa, these third-party services may be able to collect information about you, including information about your activity on Toosa, in accordance with their own privacy policies.
Our use of cookies
We collect the following when you use Toosa:
When you use Toosa, we use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”), including third-party cookies, to collect information from your browsers or devices. By using Toosa, you consent to our use of cookies and similar technologies.
The following types of cookies are used on Toosa:
- Essential cookies. These cookies enable you to use Toosa. These cookies are essential to enable you to browse Toosa and use certain features. Disabling them may prevent you from using certain parts of Toosa. Without these cookies, some of the functionality of Toosa may no longer be available to you. These cookies also help keep Toosa safe and secure.
- Preference cookies. These cookies store information such as your preferred country and language selection, login data, and website preferences. Without these cookies, we may not be able to remember certain choices you've previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance cookies. These cookies collect information about how you use Toosa, such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Your rights & choices
If you are a Toosa Follower:
- If you want to stop receiving messages from a particular Toosa Pro, send the message “STOP” (case insensitive) to their Toosa Number. You can later send the message “START” (case insensitive) to their Toosa Number to start receiving their messages again. If you want to stop receiving messages from all Toosa Pros, email privacy@toosa.com.
- If you want us to delete your information, email privacy@toosa.com. Keep in mind that Toosa Pros may still retain copies of your information, like your contact info and messages you have sent them, even after you have deleted the information from Toosa.
- If you want a Toosa Pro to delete your information, you will need to contact them directly, review that Toosa Pro’s privacy policy to learn more.
Note: if you unsubscribe from a Toosa Pro’s messages, they won’t be able to send you additional messages via Toosa, but we and they may still have your information.
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. Requests should be submitted in writing by emailing us at privacy@toosa.com. We will try to comply with your requests as soon as reasonably practicable or as required by applicable law.
There may be legal requirements to retain your information, for instance if we receive valid legal process asking us to preserve data or if we are investigating potential violations of our Terms.
You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of Toosa may no longer be available to you.
California privacy disclosures
The California Consumer Privacy Act (“CCPA”) affords consumers residing in California certain rights with respect to their personal information.
Your CCPA rights
If you are a California resident, this section applies to you, and here is a quick summary of your rights under the CCPA:
- You have the right to know whether we sell your personal information (we do not), and to opt-out of a sale if we do (though again, we do not).
- You have the right to receive an overview of the personal information we collect, how we use it, and who we share it with.
- You can request access to your personal information, get a copy, and ask us to delete your personal information.
- You have the right not to be discriminated against for exercising your privacy rights.
- You can email us at privacy@toosa.com to exercise your rights under the CCPA.
In the past 12 months, we have collected the categories of personal information described in the “Our collection of information” section above, including: (i) identifiers; (ii) internet and other electronic network activity information; (iii) financial information; (iv) geolocation information; (v) other information you provide; and (vi) inferences from this information.
We collect personal information for the business purposes described in the “Our use of information” section above.
We do not sell your personal information to third parties. In the past 12 months, we have shared your information with third parties for business purposes and with Toosa Pros at your direction, each as described in the “Our disclosure of information” section above.
CCPA requests
Depending on your request, we may ask you to take steps to verify your identity, such as by texting us from the phone number you used when signing up or providing additional information. We will not discriminate against you for exercising your rights and choices. If we receive your request from an authorized agent purporting to act on your behalf, we will ask the agent to provide proof that it has valid written authority to submit requests on your behalf, and we may ask you to verify your identity directly with us and to confirm that you provided such agent with power of attorney.
European privacy disclosures
If you are an individual in the European Economic Area, the UK, or Switzerland, please read this section, which provides additional information applicable to you.
We collect and process information about you only where we have legal bases for doing so under applicable laws in your home country. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you with our services consistent with our Terms, including to operate Toosa, provide customer support and personalized features, and to protect the safety and security of Toosa;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to promote Toosa and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose
- We need to process your data to comply with a legal obligation.