Effective Date: May 25th 2018
Please read this document carefully. If you do not understand it or do not agree to be bound by this Privacy Notice, you must immediately cease using or accessing this website.
Our practices strive to implement the following principles:
- Accountability: We are responsible for the protection of the personal data you entrust to us.
- Transparency: We inform users about the collection and processing of their personal data and use it fairly.
- Legitimate Use: We collect and use personal data for specific legitimate purposes.
- Choice: We offer users choices regarding the use of their personal data, and honor their preferences for contacting them.
- Security & Retention: We use technical, physical, and organizational safeguards to provide an appropriate level of security for the personal data in our control. We retain it as needed for its intended purposes.
- Third Parties: We carefully choose vendors, service providers, and other third parties who act as Data Processors (defined below) or who assist us in providing services (more information provided below). Each third party is solely responsible for having their own compliant privacy policies and terms of service.
Third River Marketing, LLC, dba Whir•Local Neighborhoods provides a variety of products and services to its Customers. Our customers, in turn, use the Platform (defined below) to also provide a variety of products and services to their customers.
In connection with the promotion of our products and services, Third River Marketing, LLC, dba Whir•Local Neighborhoods uses and operates the Third River Marketing, LLC, dba Whir•Local Neighborhoods website, provides content, uses social media pages, and other means of interacting with individuals about our products and services, such as emails, newsletters, phone calls, and marketing events. All such methods of promotion and sale of our products and services are designated as the “Platform.”
The operator of the Platform is:
Third River Marketing, LLC, dba Whir•Local Neighborhoods
1436 Commercial St. NE Salem Oregon
- “Visitor” means an individual who visits the Platform, and who may be seeking information about the Services.
- “Lead” means a visitor who has expressed interest in our products or services, or that of our customers using the platform, for example by filling out a form online to request information, or interacts with us in any manner about our Service, for example in emails, phone calls or through in person interaction.
- “Reviewer” means a visitor who has submitted an online review for the purpose of providing feedback to Third River Marketing, LLC, dba Whir•Local Neighborhoods on products and services provided.
- “Customer” means an individual or business who has purchased products or services from Third River Marketing, LLC, dba Whir•Local Neighborhoods.
- “User” or “you” or “your” means a visitor, lead or a customer.
- “Data Subject” means a visitor, lead, reviewer, or customer.
- “Data Controller” is an organization that collects and controls data from visitors, leads, reviewers and customers.
- “Data Processor” is an organization that processes and stores data on behalf of the Data Controller.
Third River Marketing, LLC, dba Whir•Local Neighborhoods identifies as a Data Controller and also works with third party vendors who identify as Data Processors. Third River Marketing, LLC, dba Whir•Local Neighborhoods also identifies as both a Data Controller and Data Processor on this Platform, while our customers who use the platform would be identified as Data Controllers.
What information do we collect?
When accessing the website at whirlocal.net, Third River Marketing, LLC, dba Whir•Local Neighborhoods will learn certain information about you during your visit. We collect a variety of information as needed to operate our business, to provide products and services to you and to our customers, and for the legitimate interest of our business, including for marketing purposes, to the extent permitted by applicable law.
The legal basis for using your personal information includes:
- Explicit, informed consent via our various online forms
- Contractual relationship to fulfill your service contract
- Legitimate interest
Use of “Cookies”:
An IP address is a number used by your computer every time you connect to the internet. IP addresses are automatically collected by our web server as part of general demographic data known as “traffic data”.
Additionally, we collect the following data:
Anonymous Log Data
When a user visits or interacts with our website, or clicks on a link that directs the user to our website, the user’s browser automatically provides, and we automatically collect and store, certain information about the user’s device (computer, tablet, smartphone) and the user’s activities. This includes:
- Preferences and settings: time zone, language, and character size.
- Identifiers: IP address
- Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution.
- Coarse geographic information: geographic location derived from the IP address.
We collect this data for the proper operation of our Platform. However, until the user becomes a “lead” this data cannot be linked to a specific individual.
Anonymous Traffic Data
Data generated by the use of the Platform also include:
- Information about use of the Platform: date stamp, URL of the visited page, URL of the last web page visited before visiting our Platform or a website using our Platform.
- History of interaction with our web pages: pages viewed, time spent on a page, click through, clickstream data; queries made, search history, search results selected; comments made, type of service requested, purchases made.
We collect this data to understand how our Platform is used and to create statistics on the use of our Platform. Until the user becomes a “lead” this data cannot be linked to a specific individual.
If a Visitor interacts with us or our customers using the platform, for example, to inquire about a product or service by filling out a form, the Visitor then becomes a Lead. In these cases, we will collect information provided to us through the form or questionnaire used to make the request. The information is provided directly and voluntarily by the individual. Depending on the circumstances, the information may include:
- First and Last Name
- Name of the business
- Email address
- Street address, city, state, province and/or country
- Telephone number
- Website URL
- Social Media Handles
- Mobile Number
- And additional relevant or applicable information
We collect this data for sales and marketing purposes to allow us to respond to a request from a Lead so that we may provide information about our products and services, or to process data for our customers.
What do we use your information for?
We use your data in a variety of ways, including:
- To personalize your experience on our platform; your information helps us to better respond to your individual needs
- To process transactions and communicate about your orders; no payment information, such as credit card numbers, is stored on our website or servers
- To deliver products or services; your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of providing and processing data for our customers and for ourselves on the platform. Our customers using the platform will have access to any data they collect as the Data Controller.
- To improve customer service; your information helps us to more effectively respond to your customer service requests and support needs
- To improve our website; we continually strive to improve our website offerings based on the information and feedback we receive from you
- To administer a contest, promotion, survey or other site features; These features are used by both us and our customers using the platform.
- To send periodic emails; we may send occasional company news, product or service updates, special offers and promotions, marketing emails, and related product or service information, etc.
- To send periodic SMS texts; we only send SMS text messages to users who have explicitly given us permission to do so.
- To Process for other purposes for which we obtain your consent.
How long do we keep your data?
We retain different types of personally identifiable information for various periods of time, depending on the purposes for processing the information, our legitimate business purposes, as well as in accordance with legal requirements under the applicable law.
For example, we will need to keep the information about the payment transactions that you made for several years due to tax related requirements, for accounts settling, record keeping, archiving and legal issues.
We will also maintain your contact details to help us stay in contact with you.
You Have Choices Regarding Your Data
If you no longer wish to receive future periodic emails from us, you can unsubscribe at any time.
If you receive a marketing email from us, sent from an email marketing platform, it should have a clear unsubscribe link at the bottom of the email. You may also contact our office using the information below to be taken off our mailing list.
With respect to keeping your account information current, you may update, correct, or delete information that you provided to us by contacting us at any time using the contact information provided on this page.
Right to Request Data
You have a right to know what online data we have collected about you. If you would like to request this data, please contact Third River Marketing, LLC, dba Whir•Local Neighborhoods and we will respond within 30 days. We will use a verification process to validate your request based on your email address.
Right to Erase Your Data
You have the right to request that we erase any data that we have collected about you from our Platform. If you would like to request erasure of your data, please contact Third River Marketing, LLC, dba Whir•Local Neighborhoods and we will respond within 30 days. We will use a verification process to validate your request based on your email address.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.
We may offer the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology. Any payment information is submitted and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.
Despite its use of encryption, Third River Marketing, LLC, dba Whir•Local Neighborhoods cannot guarantee any method of transmission of information over the internet is 100% secure.
What happens in case of a data breach?
In the event of a data breach, our Data Protection Officer will implement our Data Breach Response Plan, which is available upon written request.
Do we disclose any information to outside parties?
We generally do not sell, trade, or otherwise transfer your personally identifiable information, such as full name, email address, phone number, IP address, address, etc. to outside parties, other than our own customers who use the platform and are identified as Data Controllers, unless express or implied permission is granted for a specific purpose such as a petition or survey. Another exception is for trusted third parties who assist us in operating our Platform or conducting our business (Data Processors), or assist us in providing services to you. Each third party is solely responsible for having their own compliant privacy policies and terms of service.
One further exception may occur in the event that we dispose of or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Third River Marketing, LLC, dba Whir•Local Neighborhoods or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
A list of third parties that have access to your data is available upon request. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
International Transfer of Data
Third River Marketing, LLC, dba Whir•Local Neighborhoods is a U.S. company and stores your information in the U.S. Third River Marketing, LLC, dba Whir•Local Neighborhoods may disclose or transfer your personal information to countries other than the country in which you live, for purposes described above. Whenever Third River Marketing, LLC, dba Whir•Local Neighborhoods transfers personal information originating from the EEA to other countries not deemed adequate under applicable data protection law, it will do so on the basis of the EU Standard Contractual Clauses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
Terms and Conditions
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at https://whirlocal.net/blog/policies/terms-of-service/
Third River Marketing, LLC, dba Whir•Local Neighborhoods
1436 Commercial St. NE Salem Oregon