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Privacy Policy

Last modified July 5, 2019.

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.



All references to “Company” or “WhirLocal” herein mean and refer to Third River Marketing LLC, dba as WhirLocal, and Third River Marketing’s owner(s), parent company, affiliated entities, and employees, and assigns.

All references to “Members” or “Affiliates” herein mean and refer to users who have signed up for a membership on this website.

Your privacy and data are very important to us. Accordingly, we have developed this policy in accordance with recent industry norms, including the General Data Protection Regulation (GDPR) of the European Union, in order for you to understand how we collect, use, communicate, and make use of your personal information. The following outlines our privacy policy.

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. This includes our members who are using our Platform.



The Company provides a variety of products and services to its Users, Members, and Affiliates. Our Members and Affiliates, in turn, use the Platform (defined below) to also provide a variety of products and services to their prospects and customers. 

Our Platform

In connection with the promotion of our products and services, the Company uses and operates the website, provides Software as a Service (SaaS) to our Members, which includes means of interacting with users, leads, reviewers, and contacts (“Contacts”). All website and communication services are designated as the “Platform.”


The operator of the Platform is:

Third River Marketing, LLC, dba WhirLocal
1436 Commercial St. NE Salem Oregon
[email protected]

Terms of Use

This Privacy Notice is incorporated into our Terms of Use for visitors of our Platform, which is available at

Further Definitions:

For the purpose of this Privacy Policy:

  • “Visitor” means an individual user who visits the Platform, and who may be seeking information about the Services from either the Company or a Member.
  • “Lead” means a visitor who has expressed interest in products or services, either of the Company or a Member, and has filled out a form on the Platform to request more information. A Lead may also have interacted with the Company or a Member via email, phone calls, or through in-person interaction.
  • “Reviewer” means a visitor who has submitted an online review for the purpose of providing feedback to either the Company or a Member using the Platform.
  • “Customer” means an individual or business who has purchased products or services either the Company or a Member using the Platform.
  • “User” or “you” or “your” means a Visitor, Lead, Reviewer, Customer, Member, or Affiliate.
  • “Data Subject” means a Visitor, Lead, Reviewer, Customer, Member, or Affiliate.
  • “Data Controller” is either the Company or a Member 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.

The Company and Members are identified as a Data Controller and also works with select third parties who identify as Data Processors. The Company also identifies as a Data Processor on this Platform. 

What information do we collect?

When accessing the website at, the Company will learn certain information about you during your visit. We collect a variety of information as needed to operate the platform, to provide products and services to You and to our Members using the Platform, 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”:

Similar to other commercial websites, our website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used. To see our full Cookie Policy,

IP Address:

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, nor is it available to any Member.

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, nor is it available to a Member.

Lead Data

If a Visitor interacts with either the Company or a Member when using the Platform, for example by filling out a form, the Visitor then becomes a Lead or Contact and certain data is now available to both the Company and the corresponding Member. In these cases, we will collect information provided to us through the form use 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

The Company and/or our Members 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 process data for our customers. 

What Is The Information Used For?

Your data may be used 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 inquiries or orders; no payment information, such as credit card numbers, is ever stored on our website or servers
  • To deliver products or services; The Company or a Member may use your data to deliver products or services. However, your data is never sold, exchanged, transferred, or given to any other 3rd party company for any reason whatsoever without your consent.
  • To improve customer service; your information helps us to more effectively respond to your customer service requests and support needs
  • To improve our Platform; we continually strive to improve our Platform 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.
  • 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 WhirLocal 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 the erasure of your data, please contact Third River Marketing, LLC, dba WhirLocal 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.

SSL Technology

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 WhirLocal 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 Members who use the platform and are identified as Data Controllers for their own Leads and Contacts, 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, including our Members, are 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 WhirLocal 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 WhirLocal is a U.S. company and stores your information in the U.S. Third River Marketing, LLC, dba WhirLocal 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 WhirLocal 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

Changes to our Privacy Policy

We reserve the right to change our privacy policy from time to time at our discretion. We will post those changes on this page.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below.

Third River Marketing, LLC, dba WhirLocal
1436 Commercial St. NE Salem Oregon
[email protected]