Privacy Policy

This Privacy Notice for MoreRoads ("we," "us," or "our"), a product of River Valley Group, Inc., describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://www.moreroads.org or any website of ours that links to this Privacy Notice
• Use MoreRoads. MoreRoads is a civic platform that helps towns and their residents coordinate on road issues, approved contractors, town permits, and government grants documentation. The Service lets citizens report road problems and upload photos, lets towns maintain lists of approved contractors and route matching requests, lets town road departments manage permits, and helps town administration assemble evidence (hours, materials, vendors, and equipment) for grant applications. Account access is managed through Amazon Cognito, and application data is stored using Amazon Web Services (AWS), including Amazon S3 and content delivered via Amazon CloudFront.
• Engage with us in other related ways, including sales inquiries, support requests, or marketing

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@moreroads.org.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. For citizens, this is intentionally minimal: we generally only need an email address to create an account and send critical notifications. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not collect biometric identifiers, health information, or device GPS location through the Services. The main category of sensitive information we process is account login and authentication data handled through Amazon Cognito. Learn more in the sections on personal information and United States residents' rights.

Do we collect any information from third parties? Account authentication information is managed through Amazon Cognito, which we operate as part of our own infrastructure — we do not receive your information from a third-party identity directory or a customer's internal systems. We also use infrastructure providers (such as AWS) and, where a town customer pays by that method, payment confirmations from PayPal, as described in this notice. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services (including road issue tracking, contractor matching, permits, and grants documentation), communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at privacy@moreroads.org. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. When and With Whom Do We Share Your Personal Information?
4. Do We Use Cookies and Other Tracking Technologies?
5. How Long Do We Keep Your Information?
6. How Do We Keep Your Information Safe?
7. Do We Collect Information From Minors?
8. What Are Your Privacy Rights?
9. Controls for Do-Not-Track Features
10. Do United States Residents Have Specific Privacy Rights?
11. Do We Make Updates to This Notice?
12. How Can You Contact Us About This Notice?
13. How Can You Review, Update, or Delete the Data We Collect From You?

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, and for citizens this is intentionally minimal.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as reporting a road issue), or otherwise when you contact us.

Citizens. To keep the platform accessible and low-friction, we do not ask citizens for their name, home address, or phone number. Account sign-in for citizens is handled through Amazon Cognito, and the only personal information we require is an email address, which is used to create your account and to send critical notifications about issues you have reported or followed (for example, status updates). Where you submit a road issue, you may provide a nearby address or map location — this describes the location of the road problem you are reporting, not a home address or residence profile, and is not required to include a specific building number.

Town and organization users. If you sign in as a town administrator, road department staff member, or approved contractor representative, we may collect additional information needed to administer your organization's use of the Services, such as your name, work email address, phone number, job title or role, and the name of the town or contractor business you represent.

Sales and support contacts. If you contact us through a sales or support form, we collect the information you choose to provide, which may include your name, email address, phone number, and the organization you represent, so that we can respond to your inquiry.

Approved contractor listings. Towns maintain their own lists of approved contractors. Where a contractor is listed, the Services may display public business contact information supplied by the town or the contractor (such as business name, service categories, and a business phone number or email) so that matching requests can be routed appropriately. This is business contact information, not a personal profile of an individual.

Sensitive Information. We do not collect biometric identifiers (such as fingerprints or face geometry), health information, or device GPS location through the Services. The primary sensitive category we process is account authentication data (such as your Cognito login credentials and session tokens) needed to keep your account secure.

Fees for town and organization customers. Town or organization customers that subscribe for platform access may be invoiced for fees under a written agreement with us. For the foreseeable future, we issue these invoices manually (for example, by email), and we may collect payment using PayPal. When a customer pays through PayPal, payment card numbers, bank details, and similar payment credentials are entered on PayPal's systems and are processed by PayPal under PayPal's privacy policy and user agreement — not in the MoreRoads web or mobile applications. We may receive and retain limited payment-related information from PayPal or from the customer (such as payer name or email, transaction or invoice identifiers, amounts, and payment status) for accounting, customer support, and legal compliance. We do not use the Services to store full payment card numbers or card security codes, and citizens are never charged through the Services — MoreRoads does not process payments or transactions between citizens and contractors.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Push notifications (possible future feature)

In Short: Mobile apps and push notifications are not required to use MoreRoads today. If we introduce them, and you opt in, we would collect the limited information needed to deliver notifications about issues you report or follow.

If a future mobile application offers push notifications and you choose to enable them, we may collect a device push token or similar identifier, your notification preferences, and limited device or app metadata (such as device type or app version) needed to deliver and troubleshoot notifications. Any such notifications would relate to updates on road issues or platform activity, not workplace time-tracking. Delivery would rely on push infrastructure provided by the relevant mobile platform (for example, Apple or Google), which processes technical data under its own policies.

Information collected from other sources

In Short: We primarily generate account and application data ourselves through Amazon Cognito and our AWS infrastructure, rather than receiving it from a customer's internal systems.

Because sign-in is handled through Amazon Cognito as part of our own infrastructure, we do not receive your account information from a third-party identity directory or from a customer's internal IT environment. We may receive technical data (such as IP addresses) in server logs and from our infrastructure providers (including AWS) when you use the Services. If a town or organization customer pays us through PayPal, we may receive payment confirmations and related metadata from PayPal as described under "Fees for town and organization customers" above. We do not routinely buy consumer marketing lists to profile individual citizens or contractors for unrelated advertising.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information (through Amazon Cognito) so you can create and log in to your account, as well as keep your account in working order.
• To operate the core platform. We process the information in road issue reports, photos, upvotes, and contractor matching requests so towns, citizens, and approved contractors can use the Services as intended.
• To support town permits and grants documentation. We process information submitted through the Services (such as permit applications and work evidence like hours, materials, vendors, and equipment) so town road departments can manage permits and assemble records for grant applications.
• To send critical account and issue notifications. We may process your email address to send you account-related messages and important updates about issues you have reported or followed.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To bill and collect fees from town and organization customers. We may process information to issue invoices, communicate about amounts due, and confirm or reconcile payments (including payments made through PayPal). We do not bill individual citizens.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Within the town community. Road issue reports, photos, and upvotes are generally visible to other users within the relevant town community so that neighbors, the town, and approved contractors can see where help is needed. The nearest address or location shown on an issue reflects the location of the road problem, not your personal address.
• Town administrators and approved contractors. Where a town routes a matching request or permit to an approved contractor or its own road department, relevant issue and request details are shared with that town or contractor so the work can be coordinated.
• Service providers. We use subprocessors to host and operate the Services, including Amazon Web Services (for hosting, storage in Amazon S3, and content delivery through Amazon CloudFront) and Amazon Cognito for authentication. We may also use providers for limited analytics on our website as described in the cookies section. We disclose personal information to those providers only as needed for them to perform services for us.
• Payment processors. When a town or organization customer pays MoreRoads through PayPal, PayPal receives and processes payment information as described in PayPal's own policies. We share with PayPal only what is needed to initiate or identify the transaction (for example, invoice details, amount, and contact information), and PayPal shares back limited confirmation and transaction data as described in this Privacy Notice.
• Mobile push delivery (if introduced). If we introduce push notifications, we would transmit push tokens and notification payloads to the push notification services operated by the relevant device platform provider (such as Apple or Google) or their subprocessors, who process data under their own terms and privacy notices.

4. Do We Use Cookies and Other Tracking Technologies?

In Short: We use cookies and similar technologies for essential operation and authentication. Analytics on our marketing website is currently limited, and we may configure additional tools such as Google Analytics in the future.

We use cookies and similar technologies when you interact with our Services. Some technologies are necessary to maintain security, keep you signed in through Amazon Cognito, prevent crashes, fix bugs, save preferences, and support basic functionality.

We do not currently run Google Analytics or comparable third-party analytics tools on our marketing website, but we may configure limited analytics (such as Google Analytics) in the future to understand aggregate traffic. If we do, this notice will be updated, and Google's use of information will be described in Google's own privacy documentation. We do not run third-party behavioral ad networks or retargeting across the MoreRoads product.

To the extent any online analytics is deemed a "sale" or "sharing" (including for targeted advertising, as defined under applicable US state laws), you can contact us as described below under section "Do United States Residents Have Specific Privacy Rights?" and you may use browser controls or opt-out tools that analytics providers offer where available.

5. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including relying on Amazon Cognito for authentication and Amazon Web Services for hosting and storage. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@moreroads.org.

8. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account, or contact us to request a change.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services, including staying signed in.

Push notifications (if available): If we introduce push notifications, you would be able to stop receiving them by turning off notifications for the MoreRoads app in your device settings. Turning off push notifications does not delete your account; it only stops delivery of messages through the push channel.

If you have questions or comments about your privacy rights, you may email us at privacy@moreroads.org.

9. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

10. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we may collect. Because citizens are not required to provide a name, home address, or phone number, several categories below are marked "LIMITED" to reflect that they are collected only in specific contexts, such as sales and support forms or approved contractor business listings, and are not required to use the Services as a citizen. For a fuller description of what we process, please refer to the section "What Information Do We Collect?"

Note on Categories B, I, and L. We mark these categories "LIMITED" because the information involved is collected only in specific, non-citizen contexts (such as sales inquiries, town or contractor administrator accounts, and account authentication) rather than from the general population of citizens using the Services. The statutory examples in the table are illustrative of each category under the law and do not mean we collect every example type — for instance, we do not collect government-issued ID numbers, biometric data, or health information.

We process sensitive personal information (as defined by applicable privacy laws) only where permitted by law and where it is necessary to operate the Services — for example, account authentication data. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information under certain state laws. We do not use sensitive personal information to infer characteristics about you for unrelated profiling.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - As long as the user has an account with us
• Category B - As long as the relevant town/contractor administrator account is active, or as needed for a sales or support inquiry
• Category D - As long as needed for billing, accounting, tax, and contract administration (which may extend beyond the life of a specific user account)
• Category F - As long as the user has an account with us, and for a limited period in logs as described in this notice
• Category H - As long as the user or town retains the underlying content in the Services
• Category I - As long as the relevant town/contractor administrator account is active
• Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in "What Information Do We Collect?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "How Do We Process Your Information?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "When and With Whom Do We Share Your Personal Information?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We do not sell personal information for money. We may disclose personal information to service providers (such as Amazon Web Services and analytics providers, if configured) as described in this Privacy Notice to operate the Services. We do not share personal information for cross-context behavioral advertising as a business practice. If our practices change in a material way, we will update this notice.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at privacy@moreroads.org, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@moreroads.org. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided in the section "How Can You Contact Us About This Notice?"

11. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@moreroads.org.

13. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To make a request, email us at privacy@moreroads.org.