Privacy Policy

C'mon By (cmonby.com) is run by Insapio LC, a Missouri limited liability company doing business as C'mon By (“C'mon By,” “we,” “us” or “our”). This policy explains what personal information we collect through our website, the owner dashboard, and the Apple Wallet passes and hollers we provide (together, the “Service”), how we use and share it, and the choices you have.

It covers three groups of people:

• Owners and crew, who run a business on C'mon By and have accounts;
• Followers, who add a business's pass to Apple Wallet and don't have accounts; and
• Visitors to our website.

Questions? Email boss@cmonby.com.

What we collect

• Account details. When you sign up or join a crew, our sign-in provider, Clerk, collects your email address, and your name, username and profile photo if you add them. If you sign up with Apple, Facebook or Google instead, that company shares your basic profile with Clerk, like your name, email address and photo. If you set a password, Clerk handles it; we never see it. Clerk also records security details when you sign in, like your IP address, browser and device, and when you signed in.
• Your business. Its name, what you run (truck, cart or counter), what you sell, your home base and your logo if you add one; who's on the crew and their roles; and the email addresses you send crew invitations to.
• Your plan and billing. Your plan, billing period, and payment status and history, through Clerk Billing. Stripe processes payments: your card number goes to Stripe and never reaches us. Billing screens may show limited card details, like the brand and the last four digits.
• Your location while you're live. When you or your crew go live from the dashboard, your browser asks for permission to use your phone's location. While you're live and the Go live page is open with the screen on, it sends us that location (latitude and longitude, how accurate your phone says it is, and the time) about every 20 seconds, and more often while the rig is on the move. That's your rig's location. We keep only the latest one, as your phone sent it, and clear it the moment the session ends: when you stop, after 10 minutes without a location, or after 12 hours. Nobody sees it on the dashboard, and a holler tells followers only about how many minutes away the rig is. We don't collect your phone's location at any other time.
• Your live sessions. Who went live (your account ID, and your first name, or your username if you haven't added one), the rig's name if you gave it one, when the session started, was last heard from and ended, why it ended, and how many locations it sent. Your business's owner and crew see recent sessions on the dashboard: who went live, the rig, when, for how long, and how many followers were hollered, said they're coming and were served.
• What happens in the Service. Hollers, followers' “I'm coming” requests and their numbers, the numbers you serve, your promo and whether it's for first visits only, and an activity log of these events (see What businesses see).
• The ad that brought you, if one did. If you came to C'mon By from one of our ads on Facebook or Instagram and set up a business, we keep an attribution record for that business, so we can tell Meta if it later starts a paid plan: a SHA-256 hash of your email address, a SHA-256 hash of your account ID, the ad's click ID (from our ad-click cookie; see Cookies), and the IP address and browser (user agent) you signed up from. We keep it for 90 days at most (see How long we keep it).
• Messages. Whatever you send us when you get in touch.

How we use it

• to create and secure your account and let you sign in;
• to run your business's dashboard, passes and hollers, including working out which followers your rig is close to, and to show your business's name and promos to your followers;
• when just one of your rigs is live, to let someone at your window save where it's parked as their spot, rounded like any other spot;
• to manage your plan, take payments and keep billing records;
• to answer you, fix problems, and keep the Service safe, including preventing fraud and abuse;
• to tell you about your account, your plan, and changes to the Service or our terms;
• if you came to us from one of our ads, to tell Meta when you set up your business and when it starts its first paid plan, so we can see which ads work and Meta can show them to folks more likely to sign up (more on that below); and
• to meet our legal obligations.

Our ads on Facebook and Instagram

We advertise C'mon By on Facebook and Instagram. If you came to us from one of those ads (or another link there carrying Meta's click ID; see “Ad clicks” in Website visitors) and set up a business, our server tells Meta Platforms, the company behind them, about two things, through Meta's Conversions API:

• Setting up your business (“CompleteRegistration,” in Meta's terms): the first time you save your business's details in step 1 of setup.
• Starting a paid plan (“Subscribe”): when your business's first paid plan starts, as Clerk Billing reports it, or, if you picked it before setting up your business, when you set it up. That's a plan with a fee, not a free plan or a free trial. Only the first one counts: we don't report renewals or plan changes.

Each one sends Meta only:

• the event's name and time, an event ID so Meta doesn't count it twice, the page address, and our website as its source;
• a SHA-256 hash of your email address and a SHA-256 hash of your account ID;
• the ad's click ID, and the IP address and browser (user agent) you signed up from; and
• for a paid plan, the amount charged for it and the currency.

We never send Meta anyone's name or phone number; your business's name, what it sells, its home base or its logo; your crew; your rigs' live locations; anything about followers (their spots, passes, hollers or numbers) or from follower pages; or anything from Apple Wallet. There's no Meta code on C'mon By at all: no Meta Pixel, no Meta JavaScript and no _fbp cookie. It all goes from our server to Meta's.

Hashing scrambles your email address, but Meta can still match the hash, and the click ID, to Meta accounts. Meta uses these events to measure which of our ads led to sign-ups and paid plans, and to show our ads to folks more likely to sign up. Some state privacy laws count this as “sharing” personal information for targeted (cross-context behavioral) advertising. If your browser sends a Global Privacy Control signal when you arrive or when you set up your business, we don't set the ad-click cookie, send these events or keep an attribution record. You can also opt out any time by emailing boss@cmonby.com (see Your choices and rights).

Following a business doesn't take a name, an email address, a phone number or an account. To us, a follower is a pass, not a person. Here's what we keep, and why.

What we collect

• Your spot. A business's sticker opens its follow page, a cmonby.com/f/ address. There you choose where you want to hear from the business:
  • Use my location: your phone asks whether to share your location, and if you say yes, sends us where you are;
  • Use where they're parked, offered when just one of the business's rigs is live: we use where that rig is; or
  • Save my spot later: you add the pass with no spot, and save one later from “Your spot” on the back of the pass. Until you do, you won't get hollers.
  We round the location to about 100 meters, roughly a block, before we save it, and note when you set it. You can move your spot any time from “Your spot.” We don't keep how accurate your phone said its location was, and we get your location only when you save or move your spot, never in between.
• Your pass. A random ID for you as a follower and random codes for your pass: its serial number, the code Apple Wallet uses to fetch updates, and the code in the pass's own links (“Your spot” and “Stop and delete my spot”). Also what the pass says right now, whether you've used a first-visit promo, when you followed, when Apple Wallet last checked in for the pass, and when it was removed from Wallet. None of it says who you are.
• Your Wallet registration. When you add the pass, Apple Wallet registers it with us. It sends an ID that Wallet uses for passes on your device and a push token, which lets us ask Apple to tell your Wallet the pass changed. We keep them, with when they were first and last sent, until that device removes the pass.
• Hollers. Each time a business hollers you, we record which live session it came from, about how many minutes away the rig was, and when. If you say you're coming, we record when and, depending on the business's plan, the 3-digit number you got to show at the window and any promo that came with it. When the window serves you, we record that too. Each holler also gets two random codes, for the “I'm coming” link and the QR code on your pass, and a time when it runs out. A holler doesn't record where you or the rig were.
• An activity log. A plain-words record of what happens with a business's passes, like when one was downloaded, added to or removed from Wallet, hollered or served, and error messages Apple Wallet sends us. It never includes a spot, and it refers to followers, passes and devices only by the first six characters of their random IDs.
• Logs, analytics and abuse limits. Our host records each request your phone or Wallet makes, and we count requests to stop abuse. See Website visitors.

How we use it

• to put the pass in your Wallet and keep it up to date;
• to tell you when a business you follow is close, and to let the business know when you're coming. Hollers go out only while one of its rigs is live and about 5 minutes from your spot: at most one per live session, none within 3 hours of your last holler from that business, and none in your first 15 minutes after following;
• to give you a number to show at the window and keep track of first-visit promos;
• to fix problems and keep the Service secure; and
• to meet our legal obligations.

Your spot is location information, even rounded. We use it only for hollers: to tell you when a business you follow is close, and to count, for the business, how many followers are about 5 minutes from its live rig, without showing where. We don't use it, or anything else about you, for advertising, and we don't build a profile of you.

We don't collect followers' names, email addresses, phone numbers, contacts or payment details, and our database doesn't store followers' IP addresses.

On its dashboard, a business you follow sees:

• Follower counts. How many followers it has, how many have the pass in Wallet, and how many haven't saved a spot yet.
• Followers 5 minutes out. For each rig that's live, how many followers with the pass in Wallet have a spot within about 825 meters (0.5 miles) of it right now. Below 3, it just says “fewer than 3,” so nobody can be picked out by driving around and watching the count.
• Recent hollers. For its recent live sessions, how many followers were hollered, said they're coming and were served.
• Who's coming, on plans with a waiting list. Each “I'm coming” waiting to be served: its number, how long ago they tapped, about how many minutes out they were when hollered, any promo that came with it, and, when more than one rig is live, which rig hollered them. On plans with promos but no waiting list, it sees only how many numbers are out.
• Behind the scenes, for the owner only. The latest entries in the activity log described above.

The number check. When you're coming with a number, the QR code on your pass opens a page with the business's name, your number and promo, whether it's still good, and how long ago you said you were coming. Anyone with that link can open it, and crew signed in to the business can serve the number there, so show it only at the window.

That's all. A business never sees a follower's name, email address or phone number (we don't have them), and never sees where a follower's spot is: not as coordinates, a pin on a map or an address, and not even rounded.

Owners, crew and followers visit our website too, so this applies to everyone.

• Server logs. Our host, Vercel, keeps its own logs of each request, like your IP address, browser and device type, the address requested and the time. The addresses of follower pages and of Apple Wallet's requests include a pass's serial number or link codes, or Wallet's ID for the device, but never a spot. We use the logs to run the site, fix problems and prevent abuse.
• Analytics. We use Vercel Web Analytics to count visits. It records things like the address of each page viewed (with the private code taken out of follower pages' addresses, and an ad's click ID taken out of any address that has one), the site that sent you, and your country, browser, operating system and device type. It doesn't use cookies, and we don't use it to identify you or follow you around the web.
• Abuse limits. To stop abuse, we count requests over short periods: by a keyed hash of your IP address (never the address itself), by the device ID Apple Wallet sends, or, for owners and crew, by account ID. Each counter holds only that key, a count and when the period started, and we delete them after 2 days.
• Ad clicks. Links from our ads on Facebook and Instagram, and some other links there, add Meta's click ID (“fbclid”) to the page's address. When you open our home, pricing, about or sign-up page with one, our server puts that click ID in a first-party cookie named _fbc, which lasts 90 days, so we can tell Meta if you go on to set up a business (see Our ads on Facebook and Instagram). We don't set the cookie if your browser sends a Global Privacy Control signal, and we never set it on follower pages.
• Cookies. Clerk's, which keep owners and crew signed in, and the ad-click cookie above. See Cookies.

We share personal information only as described here.

Companies that run parts of the Service for us

• Clerk: accounts, sign-in, business and crew details, and subscription billing.
• Stripe: payment processing, through Clerk Billing.
• Vercel: hosting, server logs and web analytics.
• Neon: our Postgres database, which holds the follower, holler, live session, activity log and abuse-limit records described here. We use it through Vercel.
• Apple: Apple Wallet and the Apple Push Notification service deliver passes and pass updates to followers' phones. When a pass changes, we send Apple's push service the pass's push token and an empty message, and your Wallet then fetches the updated pass from us. We don't send Apple your spot. Apple's own privacy policy covers what Apple does with Wallet on your device.
• Apple, Facebook or Google, if you choose to sign in with one of them: that company confirms who you are to Clerk, and knows you signed in to C'mon By.

Others

• Businesses you follow, only as described in What businesses see, and anyone you let scan the QR code on your pass (see “The number check” there).
• Your crew. Owners and crew of a business see the same business information on its dashboard.
• Meta Platforms (Facebook and Instagram), to measure our ads and show them to folks more likely to sign up, and only about owners who came to us from one of them. When such an owner sets up their business, and when it starts its first paid plan, we send Meta the event's name, time and ID, the page address and our website as its source; SHA-256 hashes of the owner's email address and account ID; the ad's click ID, and the IP address and browser they signed up from; and, for a paid plan, the amount charged and the currency. Nothing about followers, ever. See Our ads on Facebook and Instagram. Meta's own terms and privacy policy cover what Meta does with it.
• For legal reasons, if we believe in good faith that the law or legal process requires it, or that it's needed to protect the rights, property or safety of C'mon By, our users or others.
• In a business transfer, if C'mon By is involved in a merger, acquisition, financing or sale of assets, as part of that deal and still subject to this policy.
• With your permission.

We don't sell personal information. We do share the limited owner sign-up and paid-plan events described above with Meta, which some state privacy laws treat as sharing for targeted advertising. To opt out, use a browser that sends a Global Privacy Control signal, which we honor automatically, or email boss@cmonby.com (see Your choices and rights). There are still no ads on C'mon By and no third-party trackers on its pages.

C'mon By uses two kinds of cookies:

• Clerk's sign-in cookies. They're strictly necessary: they keep owners and crew signed in and protect their accounts. Clerk may set some of them when you visit even if you never sign in, so it can tell whether you're signed in. Following a business doesn't depend on them.
• Our ad-click cookie, _fbc. This one is for advertising. It's first-party: our own server sets it, and only when you open our home, pricing, about or sign-up page with Meta's click ID in the address, as links from our ads on Facebook and Instagram have (see Website visitors). It holds that click ID and when you arrived (as fb.1.<time>.<click ID>, the format Meta uses). It lasts 90 days and is HttpOnly, so scripts on the page can't read it. It's never set on follower pages. See Our ads on Facebook and Instagram for what we do with it.

There are no analytics cookies: Vercel Web Analytics doesn't use cookies at all. And with no Meta code on C'mon By, Meta sets no cookies here, not even its usual _fbp cookie.

We honor Global Privacy Control automatically. If your browser sends the signal when you arrive, we don't set the ad-click cookie, and if it sends it when you set up your business, we don't send Meta anything or keep an attribution record. We don't act on the older Do Not Track signal; Global Privacy Control is the one we go by.

We keep personal information only as long as we need it for the reasons in this policy.

Followers, hollers and live sessions

Your spot

While the pass is in your Wallet. We delete it right away when you tap “Stop and delete my spot,” when the last device with the pass removes it, or when Apple tells us the pass's push token no longer works.

A pass removed from Wallet

Its spot and hollers go right away. The rest (its random IDs and codes and what it says, nothing that locates anyone) goes after 1 day, unless a device adds the pass back first.

A pass never added to Wallet

Deleted after 1 day.

A pass Wallet stops checking

Deleted after 400 days without Apple Wallet checking in for it.

Wallet registrations

Until that device removes the pass, or Apple tells us its push token no longer works.

Hollers, numbers and served marks

30 days. They go right away when the pass is removed from Wallet or you tap “Stop and delete my spot.”

Live sessions

30 days. The rig's location is cleared the moment a session ends.

The activity log

30 days.

Abuse-limit counters

2 days.

A deleted business

Everything we hold for it, including its followers, their spots and its hollers, goes once we notice it's gone, usually within about a week.

A cleanup job runs every day, so something can outlast its time here by up to a day.

Accounts, billing, ad clicks and logs

• Accounts and businesses: as long as the account or business is on C'mon By. After it's deleted, we delete its information within a reasonable time, except anything we need to keep for the reasons below.
• Billing records: as long as we need them for taxes, accounting and the law.
• The ad-click cookie: 90 days in your browser from when it's set, unless you clear it first.
• Ad attribution records: up to 90 days. We delete one as soon as we've told Meta about the business's first paid plan, or when its owner opts out, and a cleanup job runs every day to remove any that have run out.
• Server logs and analytics: kept by Vercel for a limited time.

We may keep information longer when the law requires it, or to resolve disputes, enforce our agreements or protect against fraud and abuse.

• Everything between your device and C'mon By travels over HTTPS.
• Passes are signed with our Apple-issued certificate, and each pass has its own random access code that Apple Wallet must present to get updates.
• Owners and crew sign in through Clerk, and only the owner can change a business's billing.
• Card details are handled by Stripe and never touch our servers.
• We limit access to personal information to the people who need it to run the Service.

No system is perfectly secure, so we can't promise yours will never be compromised. If a breach affects your information, we'll tell you as the law requires. Spot a security problem? Email boss@cmonby.com.

C'mon By isn't meant for children under 13, and we don't knowingly collect personal information from them. Accounts are only for people 18 and older. If you think a child under 13 has given us personal information, email boss@cmonby.com and we'll delete it.

Owners and crew

• Update your name, email, photo and sign-in details from the account menu in your dashboard.
• Owners can edit the business's details from the dashboard, and manage crew, logo and billing in Business settings. Crew can leave a business there too.
• Location is only used while you're live. End the session or leave the Go live page to stop it, and you can turn off location access for the site in your browser's settings.
• To delete your account or a business, use Business settings or email us.

Followers

• To stop the hollers and delete your spot, tap “Stop and delete my spot” on the back of the pass. Opening that page doesn't delete anything. Its one button deletes your spot, your pass's holler history and its link to your Wallet, right away. Then remove the pass from Wallet: open it, tap ⋯, then Remove Pass.
• Or just remove the pass from Apple Wallet. Wallet tells us, and we delete your spot and holler history right away, and the rest after 1 day.
• To move your spot, use “Your spot” on the back of the pass.
• Can't use the pass? Email us with the name of the business you follow and about when you followed, and we'll do what we reasonably can to find your pass and delete it.

Everyone

Wherever you live, you can ask us what personal information we have about you, ask us to correct it, or ask us to delete it, by emailing boss@cmonby.com. We'll answer within 45 days, or sooner if the law requires. We may need to confirm the request is really from you, for example by having you reply from your account's email address. Since we don't know who followers are, the links on the back of the pass are the surest way for a follower to move or delete their spot; for anything else, we'll do what we reasonably can to find the right pass.

U.S. state privacy rights

Depending on where you live, state privacy laws, like those in California, Colorado, Connecticut, Virginia and a growing number of other states, may give you the right to know what personal information we collect and how we use and disclose it; to get a copy of it; to correct it; to delete it; to opt out of its sale, its sharing for targeted advertising, and certain profiling; and not to be treated differently for using these rights. Where those laws apply to us, we'll honor them.

We don't sell personal information, use it for profiling that has legal or similarly significant effects, or share it with others for their own marketing. We do share a few details about owners who came to us from our ads with Meta (see Our ads on Facebook and Instagram), which some of these laws treat as sharing for targeted advertising. Wherever you live, you have the right to opt out of that sharing:

• Global Privacy Control. We honor it automatically. If your browser sends the signal when you arrive or set up your business, we don't set the ad-click cookie, send Meta any events or keep an attribution record. Turned it on after that? Email us.
• Email us. Write to boss@cmonby.com and ask to opt out. We'll send Meta no further events for your account and delete its attribution record.

We use location (followers' spots and live rigs) only to provide the Service.

You can have an authorized agent make a request for you; we may ask for proof that they're authorized. If we turn down your request, you can appeal by replying to our answer. If you're not satisfied with how we handle the appeal, you can contact your state's attorney general.

When our practices change, we'll update this policy, post the new version here and change the effective date at the top. If a change is significant, we'll also email owners before it takes effect. If we ever want to use personal information in a way that's materially different from what this policy says, we'll ask for consent where the law requires it.

Questions or requests about your privacy? Get in touch: