Last Updated: 01/08/2026
This Privacy Policy ("Policy") describes how Leadbridge Solutions, LLC d/b/a TowSpark ("Company," "we," "us," or "our") collects, uses, and discloses Personal Data. This Policy applies to the TowSpark dispatching, fleet management, and invoicing services (collectively, the "Service").
This Policy distinguishes between two types of Personal Data:
Subscriber Account Data: Personal Data we collect from and about our Subscribers and their authorized users ("Subscriber Users") to manage accounts, process payments, and provide customer support. For Subscriber Account Data, TowSpark is the Data Controller.
Subscriber Service Data: Personal Data that our Subscribers (or their customers) upload, submit, or otherwise provide to the Service. This includes, but is not limited to, customer names, phone numbers, dispatch locations, and invoice details. For Subscriber Service Data, the Subscriber is the Data Controller, and TowSpark is the Data Processor.
This Privacy Policy is incorporated into and subject to the TowSpark Terms of Service ("Terms") and, where applicable, the Data Processing Addendum ("DPA").
"Subscriber" means the legal entity that has subscribed to the Service by agreeing to the Terms.
"Personal Data" means any information relating to an identified or identifiable natural person.
"Controller" means the entity that determines the purposes and means of processing Personal Data.
"Processor" means the entity that processes Personal Data on behalf of the Controller.
This section applies to the Subscriber Account Data for which we are the Data Controller.
Account Registration: When a Subscriber signs up for the Service, we collect information including, but not limited to, business name, Subscriber User's name, email address, and phone number.
Billing Information: When a Subscriber purchases a paid plan, our third-party payment processor will collect and process payment information (e.g., credit card details, billing address). TowSpark only stores a tokenized representation of this data.
Support and Communications: When you contact us for support or other communications, we collect your name, email address, and the content of your message.
Usage Data & Cookies: We automatically collect technical information about how Subscriber Users interact with our Service. This may include IP address, browser type, device type, pages visited, and timestamps. We use cookies and similar technologies to operate the Service, remember preferences, and maintain session security.
Location Data: We collect your approximate location based on your IP address. If in the future you use our features that require precise location (e.g., driver tracking) and you explicitly grant us permission via your device or browser settings, we may collect precise geolocation data to facilitate dispatching.
We process Subscriber Account Data for the following purposes and on the following legal bases:
| Purpose | Legal Basis for Processing |
|---|---|
| To provide and maintain the Service: To create and manage your account, provide the core functionality of the Service, and process transactions. | Performance of a Contract |
| To process payments: To bill you for the Service. | Performance of a Contract |
| To communicate with you: To send Service-related updates, security alerts, and support messages. | Legitimate Interest (to manage our Subscriber relationship) |
| To improve our Service: To analyze usage patterns and improve the Service's functionality and user experience. | Legitimate Interest (to develop our business) |
| To prevent fraud and enforce our Terms: To secure our platform and protect our legal rights. | Legitimate Interest (to protect our Service and users) |
| For marketing: To send you information about new features or promotions (with your prior consent, where required by law). | Consent or Legitimate Interest |
This section applies to the Subscriber Service Data for which the Subscriber is the Controller and we are the Processor.
(a) Subscriber as Controller: The Subscriber is the Data Controller for all Service Data and is solely responsible for ensuring it has a lawful basis for collecting and processing that data.
(b) TowSpark as Processor: TowSpark will only process Service Data on behalf of and in accordance with the Subscriber's lawful, documented instructions, as set forth in the Terms and the DPA.
(c) Data Processing Addendum (DPA): The processing of all Subscriber Service Data is governed by the DPA, which is incorporated by reference into the Terms. The DPA details our obligations regarding security measures, sub-processors, data breach notification, and assistance with data subject rights.
(d) Prohibited Data: Subscribers agree not to upload any sensitive or special categories of Personal Data (e.g., health information, government IDs, genetic data) not required for the ordinary use of the Service.
(e) SMS Dispatching: The Service allows Subscribers to trigger SMS notifications (e.g., dispatch details, receipts) to their customers or drivers via the web interface. By using this feature, the Subscriber instructs us to transmit the phone number and message content to our third-party SMS gateway providers. We do not use this data for our own marketing purposes.
We do not sell your Personal Data. We may share Personal Data in the following limited circumstances:
(a) Sub-processors and Service Providers: We share Personal Data with third-party service providers (sub-processors) who assist us in operating the Service. These include:
We maintain a list of our sub-processors, and our agreements with them require they protect Personal Data to at least the same standard as this Policy and the DPA.
(b) Legal Compliance: We may disclose Personal Data if required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is necessary to protect our rights, prevent fraud, or ensure the safety of our users.
(c) Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, Personal Data may be transferred as part of that transaction. We will notify Subscribers of any such change in control.
(a) For Subscriber Account Data: Subscriber Users may have rights to access, correct, or delete their own Personal Data. You can exercise these rights by logging into your account settings or by contacting us at [email protected].
(b) Marketing Communications: You may opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of any marketing email, or by contacting us at [email protected]. Please note that even if you opt out of marketing emails, we may still send you transactional emails related to your account and use of the Service (such as invoices, dispatch notifications, and security alerts).
(c) For Subscriber Service Data: As TowSpark is the Processor, any data subject (i.e., the Subscriber's customer) wishing to exercise their data protection rights must direct their request to the Subscriber (the Data Controller). TowSpark will, to the extent legally permitted, provide reasonable assistance to the Subscriber to help them respond to such requests, as further detailed in the DPA.
We implement and maintain appropriate technical and organizational measures to protect the Personal Data we collect and process. These measures are designed to provide a level of security appropriate to the risk of processing. In the event of a security incident resulting in a breach of Subscriber Service Data, we will notify the Subscriber without undue delay, in accordance with the terms of our DPA and applicable law.
(a) Subscriber Account Data: We retain Subscriber Account Data for as long as the Subscriber's account is active and for a reasonable period thereafter as necessary to comply with our legal obligations (e.g., tax and accounting), resolve disputes, and enforce our agreements.
(b) Subscriber Service Data: We retain Subscriber Service Data for as long as directed by the Subscriber (as the Controller) or as necessary to provide the Service. Upon termination of the Subscriber's account, we will delete or return all Service Data as specified in the Terms and the DPA.
Your Personal Data may be transferred to, and processed in, countries other than the one in which you reside. We utilize approved data transfer mechanisms, such as Standard Contractual Clauses, to ensure that any transfers of Personal Data (particularly from the EEA, UK, or Switzerland) are compliant with applicable data protection laws. Further details are provided in our DPA.
The Service is not directed to individuals under the age of 18, and we do not knowingly collect Personal Data from children. If we become aware that a child has provided us with Personal Data, we will take steps to delete such information.
We reserve the right to modify this Policy at any time. If we make material changes, we will notify Subscribers via email or through the Service. Your continued use of the Service after such notice constitutes your acceptance of the modified Policy.
If you are a resident of California, the California Consumer Privacy Act ("CCPA") provides you with specific rights:
(a) Right to Know & Delete. You may request details about the Personal Data we have collected and request that we delete it, subject to certain legal exceptions.
(b) Right to Opt-Out. We do not sell your Personal Data. However, we use third-party analytics tools (like Google Analytics) that may constitute "sharing" under the CCPA. You may opt out of this via your browser settings or by installing the Google Analytics Opt-out Browser Add-on.
(c) How to Exercise. To submit a request, email us at [email protected]. If you are a customer of a towing company using TowSpark, please direct your request to that company directly, as we act only as a Service Provider for their data.
(d) "Do Not Track" Policy. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there is no industry or legal standard for recognizing or honoring DNT signals, we do not currently respond to them.
If you have any questions or concerns about this Policy or our data practices, please contact us at:
Leadbridge Solutions, LLC (TowSpark)
8605 Santa Monica Blvd PMB 522267
West Hollywood, California 90069-4109
Email: [email protected]