This privacy policy ("Policy") pertains to all individuals engaged in various interactions with us within the scope of our business activities. Such interactions may arise when you visit our website (”https://www.townscript.com” and “https://www.townhall.co”) and the Townhall Hybrid Event Management Platform( Hence, referred to as “Platform”), whether you are a visitor, end user, customer, prospective customer, observer of our operations, a potential or existing business partner, an employee, a job applicant, an investor, or a supplier. By voluntarily using our Platform or creating an account to access it, you assume the role of an authorized user ("User," "You," or "Your") and are expected to use our Platform in accordance with our Terms of Use.This Policy is designed to provide You with information regarding the collection, processing, storage, sharing, organisation, utilisation, retention, and deletion of information ("Personal Data" or "Personal Information"), whether obtained directly or indirectly from You. Additionally, it outlines the protective measures we employ to safeguard your data and explains how you can exercise your associated rights.If you do not agree with the terms outlined in this policy, we kindly request that you refrain from accessing or using our Services or engaging with any other aspect of our business operations.Please note that this Policy does not encompass information collected by third parties, including data collected through third-party applications or content (such as advertising) that may be linked to or accessible from our applications or websites.
“Dyulok Technologies Private Limited” and its corporate affiliates ("Townhall" or "We," "Us," "Our"), are dedicated to safeguarding your privacy and protecting Your Personal Data in accordance with this Policy. We adhere to a range of data protection regulations and industry best practices to ensure the security of Your information and to provide You with continuous access and control over it. This Policy furnishes comprehensive details on how Townhall gathers information, in addition to outlining the privacy and security protocols implemented on the Platform.
In the event of any changes in how Your information is utilized, we will supply You with further information during our communications with You through various channels, such as email. You may also review updates or revisions to this Policy by visiting the Platform at https://townhall.co .
Townhall has developed the world's most comprehensive and user-friendly platform for hosting virtual, In-person and hybrid events. Through our Townhall application ("Services"), Customers (as defined below) can license Townhall's application to connect with Attendees (as defined below).When Townhall directly collects information from you, Townhall operates as the Data Controller (as defined below). However, if Townhall receives information from its Customer, Townhall serves as a Data Processor (as defined below) and processes data in accordance with the instructions provided by the Data Controller. If you have any inquiries concerning the handling of Your Personal Data by Townhall or wish to exercise Your privacy rights, please contact us at privacy@townhall.co
"Account" refers to the self-service account created by the Customer on the Townhall Platform for utilizing the Services.
"Data Subject" or "Data Owners" refers to a natural person whose Personal Data is processed by a Data Controller or Data Processor.
"Customer Data" encompasses all data submitted, displayed, and/or uploaded by the Attendee,Sponsors , Booth Representatives, Authorized Administrator(s), and/or the Customer during registration, access, event hosting, and/or other usage of the Platform.
"Customer," "Data Controllers," refers to the Organizer who has a service agreement with Townhall to access the Townhall Platform for hosting in-person , virtual events and hybrid events. This includes employees, independent contractors, consultants, Affiliates, successors, and assigns using/accessing the Platform/Services. Data Controllers are responsible for data safekeeping, transportation, storage, and the implementation of business rules. They are the entities determining the purposes and means of processing Personal Data. If the purposes and means of processing are established by national or community laws or regulations, the controller or specific criteria for nominating the controller may be designated by such laws.
"Customer Personal Data" denotes any Personal Data shared by the Customer with or authorized for access, storage, hosting, modification, sharing, deletion, and further Processing by Townhall and/or its Affiliates for performing the Services.
"Personal Data" encompasses information related to a Data Subject, where an identifiable natural person is one who can be directly or indirectly identified, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes any special categories of Personal Data as defined in Art. 9 of the GDPR, data related to criminal convictions and offenses or related security measures as defined in Art. 10 of the GDPR, and national security numbers as defined in Art. 87 of the GDPR and national supplementing law.
"Attendees" denotes the clients and all individuals attending or participating in events organized by the Customer via Townhall Services.
“Sponsors” refers to the organisations who have an agreement with the Customer to display the organisation’s relevant information inside the Platform during the event.Sponsors shall only have access to add/modify relevant data as defined by the Customer in the event creation flow.
“Booth Representatives” denotes the person/s assigned by Sponsors to interact and collect relevant information from Attendees in the Booth section of the Platform. Booth Representatives shall only have access to the “Booth Representative” App.
"Data Processor" refers to a natural or legal person, public authority, agency, or other entity processing Personal Data on behalf of the Data Controller and in accordance with the Data Controller's instructions, typically for specific purposes and services accessible to the Data Controller.
"Commercial Purposes" and "Sell" bear the meanings ascribed to them in section 1798.140 of the CCPA.
"Applicable Data Protection Laws" collectively includes all data protection laws and regulations, encompassing United States federal and state privacy laws, European Union Data Protection Laws, including but not limited to the General Data Protection Regulation ("GDPR"), and any other laws concerning data protection worldwide that may apply to the processing of Personal Information (also known as “Personal Data”) under the Privacy Policy.
"CCPA" stands for the California Consumer Privacy Act of 2018, including amendments and final regulations.
"Data Protection Officer" (DPO) signifies, where applicable, an individual responsible for the protection of Personal Data at Townhall.
"Sub-processor" or "Third-Party Service Provider" means any natural or legal person, public authority, agency, or body appointed by or on behalf of the Processor, or by or on behalf of an existing Sub-processor, to process Personal Data on behalf of the Controller, as defined in Art. 4(10) and further explained in 28(4) of GDPR.
"Supervisory Authority" carries the meaning assigned to it under the GDPR.
When connecting to and navigating our Platform, we will gather information about you to enhance the quality of our Services as part of Townhall's regular business operations. In our capacity as a Data Controller, Townhall collects this data from you for various purposes, including product demonstrations, marketing activities, job vacancies and career applications, or other purposes when you provide explicit consent for such use.Below is a general list of categories of Personal Information that we collect from you:
Types of Personal Data Collected by Townhall as a Data Controller:
As a Data Processor, Townhall offers tailored/customized service options to customers that include built-in features within Townhall Services. Customers may choose to collect the Personal Data of attendees who will be participating in events organized by the customer on our Platform. This collection is carried out in accordance with the customer's privacy policy.
Customers may collect the following Personal Data of attendees:
Types of Personal Data Collected by Townhall as a Data Processor During an Event:
The purpose for the collection of Personal Data when the customer acts as the Data Controller is determined by the customer. Townhall acts solely on the instructions of the customer and does not control the data or define the purpose of its collection.
In certain situations, the customer may opt to collect sensitive Personal Information about you. When this occurs, we implement enhanced safeguards to protect your privacy. Any collection of sensitive Personal Data is entirely at the discretion of the customer.
When you connect to our Platform and utilize our Services, we gather Personal Information about you for the following purposes:
Purposes for Which We Use Your Personal Data:
In addition to the purposes mentioned above, we also collect Personal Information to provide you with a secure, seamless, efficient, and personalized experience on the Platform. We process your Personal Information and non-Personal Information to create, develop, operate, deliver, and enhance the Platform and the Services. We will not collect additional categories of Personal Information or use the Personal Information we collect for significantly different, unrelated, or incompatible purposes without obtaining your explicit consent.
Townhall Global Data Processing Policy
This Policy is applicable globally and extends to all individuals, regardless of their place of residence. In this section, we elucidate the legal justifications, often referred to as the "legal basis," for the processing of Your Personal Information in connection with our primary processing activities.
Please take note that the legal requirements governing the use of specific legal bases to justify the processing of Your Personal Information, including cross-border transfers, may vary depending on Your country of residence. For instance, the GDPR mandates obtaining consent to process Personal Information when interacting with Us. Thus, we will seek Your consent before processing such Personal Information in jurisdictions where this is required. In the case of International Data transfers, which may be required when we partner with third party vendors ,we only partner with third-parties who adhere to the standard contractual clauses for international data transfer as outlined by GDPR.
Below, we provide an explanation of Townhall's legal bases for processing Your Personal Information:
Legal Basis for Processing Activities and Purposes of Personal Information Use:
This Policy ensures compliance with global data protection regulations and serves as a framework for the lawful and ethical processing of Personal Information, prioritizing the protection of individual privacy rights.
Townhall Data Retention Policy
Townhall will retain Your Personal Data only for the duration necessary to fulfill the purposes outlined in this Policy.
For users who have provided their Personal Data on our Platform, we will retain the collected Personal Data for as long as required to provide our Services through the Platform and to meet any legal obligations (e.g., compliance with applicable legal, tax, or accounting requirements and for archival purposes).
Customer Personal Data will be retained by Townhall for 60 months from the date of termination of the agreement(s) with our Customers. This retention period is solely for repurposing and/or reusing Customer Data for any future events hosted by the Customer on the Platform. Townhall will not utilize this data for any purpose other than retaining it for the sake of convenience to the Customer. After the conclusion of the specified retention period, Townhall will automatically delete all data provided by the Customer from the Townhall database, unless otherwise requested by the customer or any other contractual obligations which will be dealt with on a case to case basis by Townhall.
Below, you will find details about data retention, legal basis, and purpose for each category of Personal Data:
Platform User Data, including name:
Purpose: To provide and enhance the Townhall Platform and Services.
Legal Basis: Consent (e.g., cookies, newsletters, providing demos) and Legitimate Interest (e.g., responding to queries about Townhall products and services).
Customer Personal Data:
Purpose: To engage with You and provide related offers as a Customer, manage the (pre-) contract or Your user account, and for administrative or billing purposes.
Legal Basis: Contract (e.g., providing products and services for fulfillment, administrative or billing purposes), Legitimate interest of Townhall, and Consent.
Customer Data (as defined by the Customer):
Purpose: As defined by the Customer.
Legal Basis: Townhall acts as the processor, and the legal basis is defined by the Customer, relying on Townhall's legal and contractual obligation to its Customer.
Data Retention, Return, and Deletion:
Where Townhall lacks a legitimate business interest to continue processing Your Personal Data or if You request deletion and/or return of Your Personal Data, we will either irrevocably delete, anonymize it, or, if not possible (e.g., if Personal Data is stored in secured archives), securely store and isolate Your information from further processing until deletion becomes feasible. We will employ advanced industry-certified technology and other methods to protect Your data and mitigate risks, including obfuscation, blanking, or encryption.
For Attendees' data provided to us by our Customers, we will retain the data for 36 months after the contract's expiration, unless the Customer requests earlier deletion or return. Customers can request Townhall to delete all data via a written request or instruction, for instance, when the data is no longer necessary for the specified processing purposes. Townhall will address such requests within 15 days of receipt.
Upon the expiration of the retention period, all Customer and Attendee data will be automatically deleted by Townhall from all Townhall databases, including those of Third-Party Service Providers.
Townhall Employees
Access to Your Personal Data is restricted to duly authorized Townhall employees who require such access on a need-to-know basis.
Disclosure of Personal Data to Third-Party Service Providers
In certain limited situations, authorized Third-Party Service Providers external to our organization may have access to Your Personal Data. These scenarios may include:
You explicitly consent to the disclosure of Your Personal Data to relevant Third-Party Service Providers whose services Townhall utilizes for various purposes, including but not limited to marketing, analysis, advertising, contract management, billing, consent management, data subject rights management, and cloud service management.
When we engage Third-Party Service Providers, we establish agreements with them to ensure that the processing of Your Personal Data aligns with our instructions, maintaining confidentiality, security, transparency, and adherence to privacy rights, all in compliance with Applicable Data Protection Laws. We do not partner with any third-party Services who do not meet the terms of Townhall’s privacy policy.
Cookies or similar tracking technologies may be used on the site to automatically collect certain information about Your device. We usually do not collect Your Personal Data, however, should it happen, this may include Personal Data as explained in this section. We may collect the following 3 types of cookies from you when you visit our website or use the platform :
To the extent allowed and practicable, and in order to safeguard your privacy rights, Townhall will undertake reasonable measures to eliminate or anonymize data that could identify you directly or indirectly. We will also minimize, to the greatest extent possible, the volume of Personal Information we utilize, transmit, or share with Third-Party Service Providers.
If Townhall processes your Personal Data based on your consent, you have the right and can choose to withdraw your consent at any time. Please notify Townhall of this withdrawal by contacting us privacy@townhall.com.
If you choose not to provide your consent or later decide to withdraw it, we kindly request that you refrain from accessing the Platform and using our Services. Additionally, we reserve the right to withhold Services or information on the Platform in such cases of consent withdrawal. Upon withdrawal of your consent, Townhall may either delete your information (whether personal or otherwise) or de-identify it to ensure it becomes anonymous and unattributable to you, except to the extent detailed in the "LEGAL BASIS FOR PROCESSING YOUR INFORMATION" section of this Policy.
When Townhall acts as a Data Processor, we solely process Personal Data based on the instructions provided by our Customers and have no direct control or ownership of the Personal Data we process.
Customers are responsible for adhering to any regulations or laws that necessitate notice, disclosure, or consent before transferring data to Townhall for further processing purposes. Attendees of an event seeking to access, correct, or delete data should direct their requests to the Customer. If a Customer requests Townhall to delete, rectify, or access an Attendee's Personal Data to comply with Applicable Data Protection Laws, Townhall will process this request within the specified timeframe as required by the Applicable Data Protection Laws.
Please note that Townhall will not process a Data Subject request to alter information that may render it incorrect, fraudulent, misrepresented, or in violation of any applicable law or legal statute. In such instances, we will inform the Customer about the legal obligations that prevent us from fulfilling the request.
We have implemented appropriate technical and organizational controls to safeguard Your Personal Data, which we possess, with the aim of preventing unauthorized Processing, data loss, disclosure, use, alteration, or destruction. When deemed necessary, we employ protective techniques such as encryption, anonymization, pseudonymization, de-identification, and other technologies that enhance the security of information related to You. These measures include mechanisms for restoring access to Your Personal Information. Additionally, we ensure that our Third-Party Service Providers adhere to reasonable and recognized data privacy, confidentiality, integrity, availability, and security standards.
We regularly conduct assessments and reviews of our technologies and processes, including evaluations of our business partners and vendors, to maintain the effectiveness of our security controls. Furthermore, we commit to anonymizing Your Personal Data or deleting it when it is no longer required for the original purpose for which we collected such Personal Information from You.
Security Measures Implemented by Townhall to Protect Your Personal Information:
We have configured our systems to apply industry-standard information security measures and have adopted recognized security frameworks to safeguard Your Personal Information. Our technical and organizational security measures are comprehensive and designed to prevent any form of loss, destruction, unauthorized access or use of our systems, software, or Personal Data. We also take measures to prevent unauthorized alterations to our systems, software, or Personal Data.
In addition to these precautions, we maintain strict access controls for Your Personal Data, limiting access only to employees, contractors, and other Third-Party Service Providers with a legitimate business need to access this information.
When engaging Third-Party Service Providers to assist us with information security measures, we ensure their commitment to adhering to stringent security, data protection, and privacy requirements. These requirements not only align with industry best practices but also comply with Applicable Data Protection Laws to ensure the utmost confidentiality, integrity, and availability of Your Personal Data.
When we receive information about You, whether it's for applying to Townhall or engaging in information exchange with us, we will collect, process, and store Your Personal Data in accordance with Applicable Data Protection Laws and as outlined in this Policy. In most cases, You voluntarily provide this Personal Data to us through our Platform, forms, and emails, typically for the purpose of entering into a contract with Townhall or based on Your explicit consent.
When You exchange information with other Third-Party Service Providers, it's important to acknowledge that Personal Data concerning You or other data subjects may be transferred outside Your country of residence. This may necessitate the implementation of appropriate, supplementary, or additional safeguards to comply with Applicable Data Protection Laws.
Please be aware that Townhall is committed to maintaining an appropriate level of protection and deploying all necessary safeguards when transferring data that includes confidential information and/or Personal Data. Additionally, for transfers to countries that do not guarantee an adequate level of data protection, Townhall will ensure that the transfer occurs through one of the following mechanisms:
i) In alignment with the Swiss-U.S. and EU-U.S. Privacy Shield Framework and Principles issued by the U.S. Department of Commerc (referred to as the "Privacy Shield Principles"), or
ii) By utilizing the Standard Contractual Clauses as set forth and approved by the European Commission.
In the event that European Union authorities or courts determine that the Privacy Shield is an unsuitable basis for such transfers, Townhall, its Customers, and, as applicable, Townhall Sub-processors, agree to promptly execute an approved Standard Contractual Clause to govern these transfers.
User Rights and Complaints
As a user of our Services and Platform, and subject to the laws of your country of residence, you may have the right to exercise your rights and file complaints with the competent data protection authority or supervisory authority.
Access, Restriction, Rectification, Erasure
Under applicable data protection laws, you have the right to control your data. You may request a copy of information about you held by us. Additionally, you have the right to rectify, restrict, or erase/delete such information, subject to limited legal and regulatory restrictions.
Objection to Processing and Additional Rights
According to applicable data protection law, you can formally object to the processing of your Personal Data. In certain circumstances, you have the additional right to restrict or suspend aspects of the processing of your information or request a copy of your Personal data in a digital and machine-readable format (portability).
Objection to Direct Marketing
You have the right to object to certain processing of your information, including processing for direct marketing purposes. If we process your information based on our legitimate interests, you can object to this processing, unless there are compelling legitimate grounds or legal reasons for such processing. You can always object and opt-out of future marketing messages for our own services using the unsubscribe link provided in such communications.
US State Privacy Laws
Under specific US state laws, you may have certain rights related to our use of your Personal Data. Particularly, if you are located in a US state that regulates the sale of your information, we do not sell or disclose your information to third parties for their commercial benefit when you are in these US states. You can contact us for more information.
California-Specific Rights
Under specific US state laws, you may have certain rights related to our use of your Personal Data. Particularly, if you are located in a US state that regulates the sale of your information, we do not sell or disclose your information to third parties for their commercial benefit when you are in these US states. You can contact us for more information.
California-Specific Rights
Under the California Consumer Privacy Act of 2018 (CCPA) and its upcoming amendments such as the California Privacy Rights Act (CPRA), California residents have specific rights regarding their Personal Information held by private companies. Specifically, we do not:
(i) sell any Personal Information from individuals located in California,
(ii) share any such Personal Information with third parties for their own commercial benefit, nor
(iii) discriminate against you in any way.
In addition to the aforementioned rights under California law, you have the right to (subject to statutory restrictions):
Request access/disclosure of the Personal Information, including Townhall's collection and use of your Personal Information over the past 12 months from the date we receive the request;
Request the deletion of all Personal Information collected from you;
Opt-out from the "sale" of your Personal Information;
Opt-out of the "sharing" of your Personal Information for cross-context behavioral advertising (applicable from January 1, 2023).
All Personal Information collected from you is in accordance with this Policy, including the use of different categories of your Personal data collected from you, and the disclosure of your Personal Information is as per this Policy.
Rights of European Individuals to Complain to Data Protection Authorities
If you are an individual located in the EEA countries, UK, or Switzerland and believe that we have processed your information unlawfully or in breach of your rights, or in violation of the General Data Protection Regulation (GDPR), the Information Commissioner's Office (ICO) in the UK, or the Swiss Federal Data Protection Act, you have the right to file a complaint directly with the competent data protection authority.
You have the right to exercise your rights of access, rectification, restriction of processing, and erasure by submitting a request through the provided channels. If you are a resident of California, you can exercise your rights by submitting your request through the designated process.
Please be aware that we may request you to verify your identity before we can respond to your requests. Upon receiving a request, we will make every effort to respond promptly and within the time frame specified by applicable data protection laws.
We may update this Policy from time to time. You are advised to review the updated Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page and any modifications can be ascertained by referring to the date that is displayed at the top of the page marked as, “ Last updated”.
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website : https://prighter.com/q/18397273422
We provide easily accessible information via our Platform or on request. If You have any questions or requests related to this Policy or Your Personal Information, please contact us at the following contact details. We will revert back to you within 2 Business Days (48 Hrs).
Townhall
Dyulok Technologies Inc,
Office No. 315/316, 3rd Floor, City Space, S. No 198/1A, Nagar Road,
Near CTR Industries, Viman nagar,
Pune - 411014
Maharashtra ,India
Email: sales@townhall.com
Townhall Data Protection Officer
Name: S.Vignesh
Email: privacy@townhall.co
Townhall EU Representative
PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG
Address:
Kriegerstraße 44
30161 Hannover
Germany
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