Terms of Service Agreement

Manytown, Inc. (“Manytown” or “we”, “our” or “us”) operates manytown.com.

These Terms of Service form part of the overall “Agreement” between you and us, which also includes our Privacy Policy, which explains how we collect and use your information.

By using the Service, you agree to be bound by this Agreement.

We may modify this Agreement from time to time and such modification will be effective upon posting on the Services. You will be deemed to have agreed to any such modifications by your further use of the Services after any such modification is posted. It is therefore important that you review this Agreement regularly to ensure you are updated as to any changes. If you do not agree with the modifications, please discontinue use of the Services immediately.

Please note that this agreement contains an arbitration clause and class action waiver. By agreeing to these Terms of Service, you agree (a) to resolve all disputes with us through binding individual arbitration, which means that you waive any right to have those disputes decided by a judge or jury, and (b) that you waive your right to participate in class actions, class arbitrations, or representative actions. You have the right to opt-out of arbitration.

CONTENT

Proprietary Rights

With the exception of content posted by users of the Services (“User Content”), all materials contained on the Services, including all content, and the sound, audio, software, graphics, text and look and feel of the Services, and all trademarks, copyrights, patents and other intellectual property rights related thereto (“Proprietary Materials”), are owned or controlled by Manytown, our subsidiaries or affiliated companies, contributors, our third party licensors, and/or our advertising partners. You may not modify, remove, delete, augment, add to, publish, transmit, participate in the transfer or sale of, create derivative works from, or in any way exploit any Proprietary Materials, or any other protectable aspects of the Services, in whole or in part, unless specifically stated otherwise. Subject to your compliance with this Agreement and any other relevant policies related to the Services, we grant you a non-exclusive, non-transferable, revocable limited license, subject to the limitations herein, to access and use the Services and Proprietary Materials for your own non-commercial entertainment purposes consistent with the intended purpose of the Services. You agree not to use the Services for any other purpose.
You may be able to post, upload, or submit content to be made available through the Services (“Your Content”). As a condition of your use of the Services, you grant us a nonexclusive, perpetual, irrevocable, royalty-free, worldwide, transferable, sublicenseable license to access, use, host, cache, store, reproduce, transmit, display, publish, distribute, modify and adapt and create derivative works (either alone or as part of a collective work) from Your Content. You also agree that (a) the other users of the Services shall have the right to comment on and/or tag Your Content and/or to use, publish, display, modify or include a copy of Your Content as part of their own use of the Services, and (b) we have the right to make any of Your Content available to third parties, so that those third parties can distribute, make derivative works of, comment on and/or analyze your Content on other media and services (either alone or as part of a collective work). By posting or submitting Your Content through the Services, you represent and warrant that you have, or have obtained, all rights, licenses, consents, permissions, power and/or authority necessary to grant the rights granted herein for Your Content. You agree that Your Content will not contain material subject to copyright or other proprietary rights, unless you have the necessary permission or are otherwise legally entitled to post the material and to grant us the license described above.
Third-Party Content & User Content

You acknowledge that the Services may include content provided by users. Any opinions, advice, statements, judgments, services, offers, or other information that constitutes part of the content expressed or made available by third parties, including content posted by our contributors or User Content, are those of the respective authors and not of Manytown or its affiliates or any of their officers, directors, employees, or agents. While we retain the right to filter or reject User Content and other content posted by third parties, we review User Content and other third party content in a limited gate-keeper fashion and have no obligation to investigate whether any content or other User Content violate any term of this Agreement and will not do so in most cases. We neither endorse nor are responsible for the User Content or any other content posted to the Services by anyone other than Manytown.
Just as you retain complete ownership of Your Content (subject to the license to us granted above), all other users of the Services retain ownership of their User Content. You may not modify, remove, delete, augment, add to, publish, transmit, participate in the transfer or sale of, create derivative works from, or in any way exploit any User Content in whole or in part.

CONDUCT

You, as a user, agree to use the Services only for lawful purposes. Without limiting anything else above, specific prohibited activities include, but are not limited to:

depicting, encouraging or partaking in criminal or tortious activity, including fraud, trafficking in obscene or illegal material, drug dealing or using, underage drinking, gambling, violence, harassment, stalking, spamming, spimming, sending of viruses or other harmful files,
depicting, encouraging or partaking in dangerous activities or conduct that is abusive, threatening, obscene, defamatory or libelous;
posting, uploading or sharing content that violates any of the prohibitions herein or that constitutes copyright infringement, patent infringement, or theft of trade secrets;
attempting to circumvent, disable or otherwise interfere with security-related features of the Services or features that prevent or restrict use or copying of any content or enforce limitations on use of the Services or the content therein;
using any software that intercepts, mines, or otherwise collects information about other users or copies and stores any Proprietary Materials (as defined below);
interfering with, disrupting, or creating an undue burden on the Services or the networks or services connected to the Services;
attempting to impersonate another user or person;
soliciting personal information from anyone under 18;
collecting, harvesting, soliciting or posting personally identifiable information about anyone other than yourself;
using information obtained from the Services in order to harass, abuse, or harm another person, whether a user or a contributor;
using the Services a commercial manner.
You represent and warrant that neither your actions on the Services nor Your Content will violate any of the prohibited conduct described above.

LINKS

The Services may contain links or otherwise direct you to websites operated by third parties. We do not monitor or control the linked sites and make no representations regarding, and are not liable or responsible for the accuracy, completeness, timeliness, reliability or availability of, any of the content uploaded, displayed, or distributed, or products, or services available at these sites. If you choose to access any third party site, you do so at your own risk. The presence of a link to a third party site does not constitute or imply our endorsement, sponsorship, or recommendation of the third party or of the content, products, or services contained on, or available through, the third party site.

We reserve the right to disable links to third party sites.

THIRD-PARTY COMPANIES AND PROVIDERS

The Services may enable you to request and receive products, information and services from businesses that are not owned or operated by us. The purchase, payment, warranty, guarantee, delivery, maintenance, and all other matters concerning the merchandise, services or information, opinion or advice ordered or received from such businesses are solely between you and such businesses. We do not endorse, warrant, or guarantee such products, information, or services, and are not liable for the accuracy, completeness, or usefulness of such information or the quality of availability of such products or services. We will not be a party to or in any way be responsible for monitoring any transaction between you and third-party providers of such products, services, or information, or for ensuring the confidentiality of your credit card information. Any separate charges or obligations you incur in your dealings with these third parties are your responsibility and are not part of the fee, if any, charged for the Services.

In addition, the Services may prompt you to establish an account with a third party service provider not owned or operated by us. Your agreement and understanding with any such third party service provider is solely between you and such service provider. Any disputes you may encounter with such third party service provider must be settled solely between you and the service provider.

DISCLAIMERS AND LIMITATION OF LIABILITY

THE SERVICES ARE PROVIDED BY US ON AN “AS IS” AND “AS AVAILABLE” BASIS. TO THE FULLEST EXTENT PERMISSIBLE BY APPLICABLE LAW, WE DISCLAIM ALL IMPLIED WARRANTIES, INCLUDING BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE.

WITHOUT LIMITING THE FOREGOING, NEITHER WE NOR ANY THIRD-PARTY PROVIDER MAKES ANY REPRESENTATION OR WARRANTY OF ANY KIND, EXPRESS OR IMPLIED: (I) AS TO THE OPERATION OF THE SERVICES, OR THE INFORMATION, CONTENT, MATERIALS OR PRODUCTS INCLUDED THEREON; (II) THAT USE OF THE SERVICES WILL BE 100% SECURE, UNINTERRUPTED OR ERROR-FREE; (III) AS TO THE ACCURACY, RELIABILITY, OR CURRENCY OF ANY INFORMATION, CONTENT, OR SERVICE, PROVIDED THROUGH THE SERVICES; OR (IV) THAT THE SERVERS, OR EMAILS SENT FROM OR ON BEHALF OF US, ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.

MANYTOWN EXPRESSLY DISCLAIMS ANY AND ALL LIABILITY FOR THE ACTIONS OF ITS USERS OR THE CONTENTS OF ANY USER CONTENT.

WE WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES ARISING FROM THE USE OF THE SERVICES OR THE PURCHASE OF ANY PRODUCT THEREFROM, EVEN IF WE OR SUCH PROVIDER HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. UNDER NO CIRCUMSTANCES WILL WE BE LIABLE TO YOU FOR MORE THAN THE AMOUNT YOU HAVE PAID US IN THE ONE HUNDRED AND EIGHTY (180) DAYS IMMEDIATELY PRECEDING THE DATE ON WHICH YOU FIRST ASSERT ANY SUCH CLAIM, AND IF YOU HAVE NOT PAID ANY AMOUNTS DURING THAT TIME PERIOD, YOU ACKNOWLEDGE THAT YOUR SOLE REMEDY IS TO CEASE USING THE SERVICES AND TERMINATE YOUR ACCOUNT.

CERTAIN STATE LAWS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO A USER, SOME OR ALL OF THE ABOVE DISCLAIMERS, EXCLUSIONS, OR LIMITATIONS MAY NOT APPLY TO SUCH USER, AND SUCH USER MAY HAVE ADDITIONAL RIGHTS.

LEGALITY

You are subject to all laws of the state(s) and countries in which you reside and from which you access the Services and are solely responsible for obeying those laws. You agree we cannot be held liable if laws applicable to you restrict or prohibit your participation. We make no representations or warranties, implicit or explicit, as to your legal right to participate in any Services, contests, sweepstakes or tournaments offered through the Services nor will any person affiliated, or claiming affiliation with the Services have authority to make any such representations or warranties.

APPLICABLE LAW; JURISDICTION

The Services are created and controlled by us in the State of Delaware. As such, the laws of the State of Delaware will govern this Agreement, without giving effect to any provisions of Delaware law that direct the choice of another state’s laws.

Subject to the Binding Arbitration section below, you hereby irrevocably and unconditionally consent to submit to the exclusive jurisdiction of the federal and state courts in Delaware for any litigation arising out of or relating to use of or purchase made through the Services (and agree not to commence any litigation relating thereto except in such courts).

BINDING ARBITRATION

Any controversy or claim arising out of or relating to this Agreement, including any threshold questions of arbitrability, will be determined by binding arbitration. The arbitration proceedings will be held and conducted by a single arbitrator in accordance with the Comprehensive Arbitration Rules and Procedures of JAMS (the “JAMS Rules”), as modified by this Agreement. Such arbitration will occur in Delaware and be initiated by any party in accordance with the JAMS Rules. The demand for arbitration will be made by any party hereto within a reasonable time after the claim, dispute or other matter in question has arisen, and in any event will not be made after the date when institution of legal proceeding, based on such claim, dispute or other matter in question, would be barred by the applicable statute of limitations. Discovery issues will be decided by the arbitrator. Post-hearing briefs will be permitted. The arbitrator will render a decision within twenty (20) days after the conclusion of the hearing(s). In reaching a decision, the arbitrator will have no authority to change, extend, modify or suspend any of the terms of this Agreement, or to grant an award or remedy any greater than that which would be available from a court under the statutory or common law theory asserted. The arbitrator will issue a written opinion that includes the factual and legal basis for any decision and award. The arbitrator will apply the substantive law (and the law of remedies, if applicable) of Delaware or federal law, or any of them, as applicable to the claim(s) asserted. Judgment on the award may be entered in any court of competent jurisdiction. The parties may seek, from a court of competent jurisdiction, provisional remedies or injunctive relief in support of their respective rights and remedies hereunder without waiving any right to arbitration. However, the merits of any action that involves such provisional remedies or injunctive relief, including, without limitation, the terms of any permanent injunction, will be determined by arbitration under this paragraph. Judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. The arbitrator will allocate all costs and expenses of the arbitration (including legal and accounting fees and expenses of the respective parties) to the parties in the proportions that reflect their relative success on the merits (including the successful assertion of any defenses).

You agree to pursue any arbitration in an individual capacity and not as class representative or class member in any purported class action proceeding.

BY AGREEING TO ARBITRATE DISPUTES, THE PARTIES HEREBY ACKNOWLEDGE AND AGREE THAT THEY ARE IRREVOCABLY WAIVING ANY AND ALL RIGHT TO TRIAL BY JURY IN ANY LEGAL PROCEEDING ARISING OUT OF OR RELATING TO THIS AGREEMENT OR THE ACTIVITIES CONTEMPLATED HEREBY.

INDEMNITY

You agree to indemnify and hold Manytown, our subsidiaries and affiliates, and our respective officers, agents, partners and employees, harmless from any loss, liability, claim, or demand, including reasonable attorneys’ fees, made by any third party due to or arising out of your breach of this Agreement and/or any of your representations and warranties set forth herein.

SEVERABILITY

The provisions of this Agreement are intended to be severable. If for any reason any provision of this Agreement will be held invalid or unenforceable in whole or in part in any jurisdiction, such provision will, as to such jurisdiction, be ineffective to the extent of such invalidity or unenforceability without in any manner affecting the validity or enforceability thereof in any other jurisdiction or the remaining provisions hereof in any jurisdiction.

ELECTRONIC COMMUNICATIONS

When you use the Services or send emails to us, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by email or by posting notices through the Services. You agree that all agreements, notices, disclosures and other communications that we provide you electronically satisfy any legal requirement that such communications be in writing.

OTHER

This Agreement is deemed accepted upon any use of any of the Services. Our failure to exercise or enforce any right or provision of this Agreement will not operate as a waiver of such right or provision. The section titles in this Agreement are for convenience only and have no legal or contractual effect.

SUPPORT

Subject to the other provisions of this Agreement, we will attempt to help you with any queries or problems that you may have with the Services or any of your purchases through the Services. To reach our customer support team, please e-mail us at team@manytown.com. It will expedite your request for assistance by providing our representatives with all the information they need to solve your problem as quickly as possible.

MODIFICATION

We reserve the right to make changes to the Services, posted policies and this Agreement at any time without notice other than the reposting of the modified Agreement. We will attempt to notify you of material changes by communicating them to you directly (if we have contact information for you), adding temporary banners to the Services or otherwise highlighting such changes.

Please contact us at team@manytown.com with any questions regarding this Agreement.

Privacy Policy

Manytown respects your privacy and values your trust. This Privacy Policy (“Policy”) describes how we collect and use your information and explains your rights and options.

1. About This Policy And Us

Who we are

Manytown. (“Manytown,” “we”, “our” or “us”) operates the Service. This Policy supplements and is governed by our Terms of Service (“Terms”). Capitalized terms used but not defined in this Policy are defined in our Terms. The Terms describe how the Services work in general and its conditions and requirements of use.

When this Policy applies

This Policy applies when you use the Services, effective as of the Last Updated date above. By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy and the Terms.

Because the Services change often, this Policy may change over time. Anytime we modify the Policy, we will post a revised version on the Services and update the Last Updated date above. If you have given us your contact information, we will notify you before any material changes take effect, so you have time to review them.

Certain parts of the Services work differently, and some information falls outside this Policy:

Certain parts of the Services may have additional terms and privacy disclosures that supplement this Policy, like Learning at Manytown.
The Services may contain links to and from third-party websites and services. This Policy doesn’t apply to outside of our Services. See Third Party Services to learn more.
If you are a current or former employee or contractor of ours, this Policy does not apply to you. You may contact us about your privacy practices and rights at team@manytown.com.
If we receive your information in our role as a service provider to another business, our agreement with that business governs our use of your information. We will refer any questions or concerns of yours to that business.

Location-specific sections

The Services operates from the United States, but this Policy applies worldwide. Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live.

Information you provide

You may use the Services without providing any information about yourself. However, to use some aspects of the Services, we will need information about you, such as if you:

Contact or communicate with us
Subscribe or opt-in to our newsletters, alerts, or other communications
Participate in a contest or promotion or redeem a prize
Information you provide may include your name or email address (“personal identifiers”).
We generally don’t collect your sensitive information, and we strive to limit the amount of sensitive personal information we collect.

For instance, make a purchase through our Services, your payment information, like your full credit card number and any payment-related security information, is only collected and processed by our payment processor.
In the event you provide sensitive personal information to us, we use it only for our operational business purposes, and we do not disclose it to others for any other purpose.

Information collected when you use the Services

As you use the Services, cookies and other technology we use will generate technical data about which features you use, how you use them and the devices you use to access our services. This information may include:

“Commercial Information” about Offerings or other products or services from us and interactions with Manytown products.
“Device Information” related to the device you use to interact with the Services, such as your device’s IP address, advertising IDs (resettable, random numbers, such as the device’s Apple IDFA or Android Advertising ID), its browser and operating system, its internet service provider, and its configuration.
“Internet Activity” related to your use of the Services, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Services, the content or advertisements you interact with, general geolocation information, time stamps and performance logs and reports.

Information we generate

We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”).

How We Use Your Information

We use each of the categories of personal information described above for the following business and commercial purposes. The activities below can involve outside companies, agents or contractors (“service providers”) to whom we disclose your information for these purposes (discussed further below).

To provide our content, services and products to you

Deliver content you request
Provide you with customer support and respond to your requests
Complete your orders
Communicate with you about our services
To manage your subscriptions or fulfill product orders

Manage your content subscriptions
Deliver and process payments for Offerings you order
To improve our services and develop new ones

Administer focus groups, market studies and surveys
Review interactions with customer teams to improve our quality of service
Develop new content and services
To allow personalized ads and create audiences for third-party advertisers

Administer sweepstakes, contests, discounts or other offers
Gather data and work with third parties to show you personalized ads on behalf of advertisers
Perform and measure the effectiveness of advertising campaigns on our services and marketing campaigns off of the Services
Communicate with you about products or services that we believe may interest you
To prevent, detect and fight fraud and other illegal or unauthorized activities

Find and address ongoing, suspected or alleged violations of our Terms
Retain data related to violations of our Terms to prevent against recurrences
Enforce or exercise our rights; for example, those in our Terms
To create broader findings with aggregate and deidentified data

Aggregate or deidentify information so that it can no longer identify you, as defined under applicable laws.
Better understand and represent our users using deidentified data, such as to measure ad performance, create advertising interest-based segments or compile survey results.
To ensure legal compliance

Verify copyright or IP claims
Comply with legal requirements
Assist law enforcement
Purposes

We rely on the following purposes to collect and use your information as described in this Policy:

Commercial purposes: At times, the reason we process your information is to advance your economic interests or our economic interests. These purposes include performing the contract that you have with us, as embodied by our Terms, which advance our economic interests and yours. For instance, if you order products from us, we use your information to complete your payment and provide your product to you.
Business purposes: Most often, we process your information for operational reasons, in a reasonably necessary and proportionate manner (i.e., for business purposes under CCPA). For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest content we think might interest you and promote our own services, we process information to help keep our members safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
Comply with applicable laws and regulations: We also process your information where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement.
Consent: From time to time, we may ask for your consent to collect specific information, such as your precise geolocation, or use your information for certain specific reasons, like providing your email address or phone number for direct marketing purposes. In general, you may withdraw your consent by changing your settings (such as browser or device settings) or following instructions provided with information we send you on a consent basis (such as clicking ‘unsubscribe’ in any email we send you). You may always withdraw your consent at any time by contacting us at team@manytown.com.

2. Our Disclosures Of Information To Others
   Since our goal is to help you discover great products, content and services, the principal reason we disclose your information is to enhance your experience of the Services and present relevant content to you.

This section describes how and why we exchange personal information with service providers and third parties. It also describes exchanges made for certain purposes, like advertising, legal reasons and consensual direct marketing. We also disclose deidentified and/or anonymized data for these purposes.

With affiliates

Our corporate affiliates may access your information for the purposes listed here, always in accordance with the terms of this Policy.

With service providers

In addition to the use of trackers described above, we contract with service providers to fulfill certain functionality and features of the Services, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions.

We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to service providers as necessary for them to perform their services. are not permitted to use information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of service providers:

Analytics providers, namely Google Analytics, to tell us how the Services are doing, such as which parts interest visitors and how long they visit before leaving. Among other data, they may receive your IP address. You can find out how Google Analytics uses data and how to opt out of Google Analytics.
Various hosting services and data processors to provide the infrastructure of the Services, such as Cloudflare, which ensures that traffic is from real people, not computers. Among other data, they may receive your IP address.
Payment processors, namely Stripe, to process payments between you and us, such as for Offerings. To learn how Stripe processes payment information, see https://stripe.com/privacy. Payment providers receive information about your order in order to tie your payment process to your order. We don’t receive all of the information you may provide to them (for instance, we don’t receive full payment-account numbers).
We sometimes allow service providers to use aggregated or deidentified information for other purposes, in accordance with applicable laws.

For personalized ads

We share information with advertising partners to make the advertising presented to you on the Services more relevant to you. We also market the Services to you through ads facilitated by marketing vendors.

For example, we use Google to serve ads on the Services and we may market the Services to you on third party services through Google. Google uses cookies or unique device identifiers, in combination with their own data, to show you ads based on your visit to manytown.com and other sites. You can opt out of the use of the Google cookie by visiting the related Google privacy policy.
We try to limit how our third-party advertising technology vendors use information they collect from you. Most providers require us to enter contracts that allow them to optimize their ad services and products. Essentially, they combine any information they may gather about you through our Services with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us.
In the past twelve months, we have shared these categories of personal information with third parties to personalize advertising:

Device Information
Commercial Information
Internet Activity
Geolocation
For legal reasons

Finally, we may disclose personal information:

In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. We reserve the right to raise or waive any legal objection or right available to us.
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements.
In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
With your consent or at your request

We may periodically ask for your consent to disclose your information to third parties.

Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure. For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications.
In those cases, the Services will display a tickbox near an email-entry field explaining that by submitting your information, you agree to share your email with the content provider.
To be clear, we only exchange information about you with third parties for direct marketing purposes if you opt in, and will only do so until you opt out.

3. How Long We Retain Your Information
   We retain your information only as long as we need it for the purposes described under How we use information, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.

How long we need information for those purposes varies by category, and even within categories. These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.

For example, we delete some Internet Activity at some soon as you exit the Services, whereas we may retain records of your orders for services and products for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.

4. Your Rights
   In General

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

Content opt-outs: you may “opt-out” of any newsletters or promotional communications from us by following the unsubscribe instructions in the communication you receive. You may also opt-out of receiving newsletters and/or promotional communications through our Opt-Out Request Form. We may continue to send you communications regarding the Services, such as notices about administrative updates, transaction reports, and changes to the Services, this Policy or the Terms.
Exercising rights
Personalized ads: For more about targeted advertising, and how to opt out with your specific browser and device, go to the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. You can download the AppChoices app to opt out in mobile apps.
Rights under GDPR

This subsection applies to you only if you reside in a jurisdiction where GDPR applies.

Lawful bases
If we are aware that you reside in a GDPR jurisdiction, we only collect, use or share information about you when we have a valid reason. This is called a “lawful basis.” Our lawful bases generally map to the Purposes above, but specifically include:

The consent you provide to us at the point of collection of your information
The performance of the contract we have with you
The compliance of a legal obligation to which we are subject, or
The legitimate interests of Manytown or a third party.
We have a legitimate interest in gathering and processing personal data, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct our business; (3) to prevent fraud; and (4) to conduct our marketing activities.

For GDPR purposes, the data controller is Manytown, Inc. at 1638 Mermentau St, Mount Pleasant, SC, 29466.

ii. GDPR rights

Depending on your jurisdiction’s enactment of GDPR, you may have these rights:

Request access (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
Request correction. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised objected to processing (see below), where we may have processed your personal data unlawfully, or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons. If so, we will notify you at the time of your request.
Object to processing where we are relying on a legitimate interest (or those of a third party) and you object to particular processing due to a perceived impact on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
Request restriction of processing during the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. For clarity, withdrawal is not retroactive.
We do not charge for access to your personal data or to exercise any of the other rights. However, we may refuse to comply with your request or charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

Rights under California law

This subsection applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights, including any analogous rights. Except as noted in this subsection, we extend these California rights to residents of those other U.S. states regardless of whether applicable law in those states includes all of these rights.

Rights under CCPA
The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA).

The categories of personal information we collect depend on how you use the Services. They’re generally described in Information We Collect. See Purposes for a general description of the reasons we collect information. For clarity, we have collected personal information for these CCPA categories of business and commercial purposes in the last twelve months:

Advertising and Marketing
Error Management
Internal Research
Provide Products or Services
Quality Assurance
Security
Short-Term Transient Use
We also “share” and “sell” (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.
The categories of third parties to whom we disclose and sell or share personal information are under for personalized ads and with your consent or at your request above. The disclosures under Purposes describe with business purpose or commercial purpose for those disclosures of information.

Under CCPA, California consumers have the following rights:

A. Rights to Know, Access, Correct and Delete.

You have the right to request that we disclose, correct and delete personal information about you that we have collected. Your right to know includes the personal information we have sold or shared or disclosed for a business purpose or a commercial purpose.

Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:

comply with legal obligations;
allow you, other consumers, or us to exercise free-speech rights or other legal rights;
complete an obligation that you have requested (for instance, if a product you purchased carries a warranty or could reasonably be subject to recall under applicable law); or
if we use the information only for internal purposes reasonably aligned with consumer expectations.
B. Rights to Limit and Opt-Out of Sharing/Sale

You also have the right to direct us (1) not to share or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Services to you.

To opt out of the sharing of your information, please use our Our Opt-Out Request Form or the ‘Do Not / Share My Personal Information’ link on our homepage. Because we do not maintain user accounts or other means of permanently logging your opt-out, your opt-out will be specific to the browser or device where you clicked ‘Do Not Sell/Share’ and will last until you clear your cookies (or local storage in apps) on that browser or device).

We do not currently offer a mechanism to exercise the right to limit our disclosure of sensitive personal information, as we limit our use of any sensitive information to the purposes you consented to.

As of the Last Updated date, we have no knowledge of any use of personal information we collect from individuals under the age of 16 for ‘sale’ or ‘sharing’ purposes.

C. Right of No Retaliation

CCPA prohibits us from discriminating against you if you exercise rights under CCPA, except when you opted into a financial incentive involving certain of your personal information, and subsequently restrict our use of that personal information through a CCPA rights request.

For example, if we offer you a discount code for consenting to receive marketing emails, and you then require us to delete your email address, we may not honor that discount code.
Your right of no retaliation doesn’t need to be exercised. We never retaliate against anyone exercising their rights under this Policy or CCPA.

D. Preference signals

The Services are designed to automatically recognize and honor any global opt-out preference signal sent from a California IP address through browser or device settings, provided the signal complies with CCPA’s requirements. Our goal is for the Services to automatically respond to compliant signals by opting California residents out of any sharing or sale of their data in a frictionless manner.

Please contact us at team@manytown.com if you believe the Services collected or processed your information in a manner inconsistent with your opt-out preference signal.

E. Request process for CCPA rights

To submit a CCPA request relating to the foregoing rights, please contact team@manytown.com with “California Privacy Rights Request” in the subject line. The process described under Requesting information generally applies to requests to exercise CCPA rights. However, in addition:

A California resident’s authorized agent may submit CCPA rights request.
Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described below. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.
An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.
We will acknowledge your request within 10 days, and our goal is to fulfill your request within 45 days. However, we may you that we will require up to 45 further days to fulfill your request, along with an explanation of why our response is delayed.

We provide responses in the manner we receive your request (i.e., with an email response to an email request).
ii. Other California law

Because we only give your information to third parties for direct marketing purposes with your consent, and always allow you to opt out of direct marketing communications after opting in, we believe we are not currently required to comply with California Civil Code Section 1798.83.

(g) Requesting information

Submitting requests
To exercise any of these rights, use Our Opt-Out Request Form or contact us at team@manytown.com. Your request must:

provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.
not disclose any social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.
ii. Verifying requests

We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain. If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you.

If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.

iii. Responses to requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. We will always respond in accordance with any deadlines or requirements specified by the laws that apply to you.

At times, we may be unable to provide responsive personal information. For example:

If disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ account with us, or the security of our systems or networks.
we do not disclose account passwords or any other non-personal information that enables access to an account.
We reserve the right to retain an archive of any deleted information, to the extent permitted by law. We may also retain deidentified or aggregate data derived from information about you.

5. Security
   Manytown has implemented technical, administrative and physical security measures to protect your information from unauthorized access, use or disclosure. Still, no data transmission over the Internet is 100% secure, so we cannot guarantee or warrant the security of any information you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.
6. Use by Minors
   The Services are intended for adult users. We do not knowingly collect information from anyone under the age of majority in their jurisdiction (such as 16 in the UK or 18 in Mexico), and we do not share or sell information about anyone under 16 without affirmative authorization. If we learn that we have collected information from a child under age 16, we will delete that information as quickly as possible.

If you are under 16: sorry, but please leave the Services. If you’ve already sent us information, please contact us first so we can delete it.
If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with information, please contact us.

7. Third Party Services
   Some areas of the Services contain links to third-party websites, resources and advertisers. These third parties are not part of the Services. We do not control (and are not responsible for) third party content or privacy practices. Information you provide to them is not covered by this Policy. These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and where they store information. We encourage you to familiarize yourself with their privacy policies and terms of use.
8. Contact us
   If you have any questions or feedback about this Policy, email us at team@manytown.com.

LAST UPDATED 11/15/2024.