PRIVACY POLICY
Date Last Updated September 26, 2024
This Privacy Policy describes the practices of burble, Inc. and our subsidiaries and affiliates (collectively, the ”Company," "we," "us," or "our") in connection with the Personal Information we collect from or about you when you access, use and/or subscribe to the burble mobile application (“burble App”), other online products and/or services offered by us (collectively, the ”Services”) and/or or otherwise interact with us.
From time to time, we may change and/or update this Privacy Policy. Please refer to the “Date Last Updated” to make sure you are aware of the current policies in place in connection with the Personal Information.
Please review this Privacy Policy from time to time. If you do not wish to provide us with such Personal Information or have it processed by us or any of our Service Providers (as defined below), please do not access, use, subscribe and/or otherwise interact with the burble App and/or the Services.
■ SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Policy, 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. For our full privacy policy please scroll down.
What personal information do we process? When you visit, use, or navigate the Services including the burble App, we may process Personal Information depending on how you interact with the burble App and/or the Services, the choices you make, and the products and features you use. Scroll down to this section to learn more.
Do we process any Personal Information? We may process Personal Information when necessary with your consent or as otherwise permitted by applicable law. Scroll down to this section to learn more.
Do we receive any Personal Information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Scroll down to this section to learn more.
How do we process your Personal Information? We process your Personal Information to provide, improve, and administer our Services and/or the burble App, communicate with you, for security and fraud prevention, and to comply with law. We may also process your Personal Information for other purposes with your consent. We process your Personal Information only when we have a valid legal reason to do so. Scroll down to this section to learn more.
In what situations and with which types of parties do we share Personal Information? We may share Personal Information in specific situations and with specific categories of third parties. Scroll down to this section to learn more.
How do we keep your Personal Information safe? We have 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 Personal Information. Scroll down to this section to learn more.
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. Scroll down to this section to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here: https://www.myburble.com/contact-us, or by contacting us. 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 Personal Information we collect? Scroll down to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. WHAT ARE THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW DO WE HANDLE YOUR SOCIAL MEDIA LOGINS?
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO RESIDENTS OF CERTAIN STATES HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE PERSONAL INFORMATION WE COLLECT FROM YOU?
15. INFORMATION FOR INDIVIDUALS IN EEA, SWITZERLAND AND UK
1. WHAT INFORMATION DO WE COLLECT?
The nature of the information we collect from you is dependent on how you engage with the burble App and/or the Services, and general consists of:
• Personal Information, which is information that can be used to identify you, including your name, email address and telephone number.
• Anonymous information, which is data about you, your device, your activities that does not by itself identify you.
When, and to the extent, anonymous information is combined with Personal Information, such information also becomes Personal Information and is treated and protected as such in accordance with the terms of this Privacy Notice.
We collect Personal Information and anonymous information that you directly provide to us as well as Personal Information you indirectly provide to us as you use the burble App and/or the Services. We may also collect Personal Information about you from third parties.
Personal Information You Disclose To Us
In Short: We collect Personal Information that you provide to us.
We collect Personal Information that you voluntarily provide to us when you subscribe to any of our Services including, without limitation, the burble App, participate in any interactive features in connection with the Services, request customer support, provide us with feedback and/or suggestions and/or otherwise communicate or interact with us.
Personal Information Provided by You. The Personal Information that we collect depends on the context of your interactions with us including, without limitation, through the Services and/or the burble App, the choices you make, and the products and features you use. The personal information we collect (“Personal Information”) may include the following:
■ full name;
■ email address;
■ username;
■ password;
■ contact preferences;
■ telephone number;
■ contact or authentication data;
■ demographic data;
■ mental wellness service usage data; and/or
■ purchase buying behavior related to wellness.
Payment Data.
The burble App utilizes third party products including Apple Pay and Google Play (collectively, “Payment Processors”) to securely process all subscription payments. By using Payment Processors, burble does not collect or store any payment details, such as credit card information. All transactions are handled directly by Apple or Google, ensuring your sensitive financial data is protected under their privacy and security policies.
For more information, please review the Payment Processors’ privacy policies below:
The Company, may when user so elects, collect[1] data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Paypal[2] . You may find their privacy notice link(s) here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full#personalData.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use the burble App, we also may collect the following information if you choose to provide us with access or permission:
■ Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, calendar, camera, contacts, microphone, reminders, sensors, sms messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
■ Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
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.
Information Automatically Collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services and/or use the burble App.
We automatically collect certain information when you visit, use, or navigate the Services and/or the burble App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
■ Device Data. We automatically collect device data such as information about your mobile device, computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your Internet Protocol (IP) address (or proxy server), device (including model and manufacturer) and application identification numbers, location, browser type and version, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Information Collected From Other Sources
In Short: We may collect limited Personal Information from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain Personal Information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This personal information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive Personal Information about you such as your name, email address, and gender. Any Personal Information that we collect from your social media account depends on the privacy settings on your social media account.
Information You Provide to Third Party Artificial Intelligence Tools Including ChatGPT
In connection with using the Services and/or the burble App, you may be interacting with third party artificial intelligence and large language model tools including, without limitation, ChatGPT. ChatGPT is an artificial intelligence program that generates dialogue by using machine learning algorithms to process and analyze large amounts of data to generate responses to user inquiries. We are not responsible for any information that you provide and/or otherwise disclose to ChatGPT, and we have no control over the manner in which ChatGPT uses or shares information. Prior to disclosing or communicating any personal information utilizing the Services and/or the burble App, in addition to reviewing the policies set forth herein, you should also review ChatGPT’s privacy policy at https://openai.com/policies/privacy-policy/.
2. WHAT ARE THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION?
In Short: We process your information to provide, improve, and administer our Services and/or the burble App, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes permitted by applicable law, with your consent.
We process your Personal Information for a variety of reasons, depending on how you interact with our Services and/or the burble App, including:
■ To personalize your experience and delivering content, products and services relevant to your stated and inferred interests, needs, location or other preferences.
■ To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
■ To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
■ To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
■ To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
■ To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services and/or the burble App.
■ To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
■ To send you marketing and promotional communications and deliver targeted advertising to you. We may process the personal information you send to us for our marketing purposes including, without limitation, to develop and display personalized content and advertising to your interests, location and more, if you affirmatively consent to same when you subscribe to any of the Services including, without limitation, the burble App. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
■ To post testimonials. We post testimonials on our Services and/or the burble App that may contain personal information.
■ To protect our Services. We may process your information as part of our efforts to keep our Services and/or the burble App safe and secure, including fraud monitoring and prevention.
■ To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, the burble App, products, marketing, and your experience.
■ To identify usage trends. We may process information about how you use our Services and/or the burble App to better understand how they are being used so we can improve them.
■ To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
■ 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 categories of third parties.
The Company will never sell or rent your Personal Information to any third party under any circumstances and will[3] only share or disclose your Personal Information with third parties as set forth in this Privacy Notice and for legitimate business reasons.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("Third Parties") who perform services for us or on our behalf and require access to such information to do that work. The categories of Third Parties we may share personal information with are as follows:
■ Communication & Collaboration Tools;
■ Data Analytics Services;
■ Data Storage Service Providers;
■ Finance & Accounting Tools;
■ Order Fulfillment Service Providers;
■ Payment Processors;
■ Performance Monitoring Tools;
■ Product Engineering & Design Tools;
■ Retargeting Platforms;
■ Sales & Marketing Tools;
■ Social Networks;
■ Testing Tools;
■ User Account Registration & Authentication Services; and
■ Website Hosting Service Providers.
We also 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.
■ Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
■ Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
■ Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please be sure to review the privacy notices of any such third party advertisers to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) in connection with the Services and/or the burble App for various purposes including authenticating you and recognizing your preference when you visit the burble App, customizing your experiences with the Services and/or burble App, analyzing website analytics and such other purposes as set forth elsewhere in this Privacy Notice. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services and/or the burble App.
5. HOW DO WE HANDLE YOUR SOCIAL MEDIA LOGINS?
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Services and/or the burble App offer you the ability to register and log in using your third-party social media account details (like your Google, Apple, Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal Information by your third-party social media provider. We recommend that you review their privacy notice(s) to understand how they collect, use, and share your Personal Information, and how you can set your privacy preferences on their sites and apps.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In Short: We keep your Personal 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 reasonably necessary to fulfill the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting periods. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we maintain and process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Please note that by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they cease being customers for tax purposes.
We may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes and use this information indefinitely without further notice to you.
7. HOW DO WE KEEP YOUR PERSONAL 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. 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 and/or the burble App within a secure environment.
8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
In Short: We do not knowingly solicit or collect data from children under 18 years of age.
We do not knowingly solicit or collect data from from children under 18 years of age. 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 the age of 18, please contact us at support@myburble.com.[4] [5]
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account or uninstall the burble App at any time.
Uninstall the burble App or Terminate Your Account. You can stop all further collection of information by the Services and/or burble App by uninstalling the burble App and/or terminating your account. You may use the standard uninstall process available as part of your mobile device or via the mobile application marketplace or network. In addition, you may terminate your account by contacting us as set forth below.
If you uninstall the burble App or terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information including, without limitation, Personal Information in our files including, without limitation, any scripts generated by the Services and/or the burble App as set forth herein including, without limitation, to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements and obligations.
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 by 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 of your Personal Information before your withdrawal of consent, nor when applicable law allows, will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
Opting Out of Marketing and Promotional Communications. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
10. 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.
11. DO RESIDENTS OF CERTAIN STATES HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, Connecticut, Montana, Oregon Texas, Utah, Virginia and/or Nevada, you are granted specific rights regarding access to your Personal Information as set forth in more detail below.
California Residents’ Rights Under the California Consumer Privacy Act
This section supplements the information contained in this Privacy Notice and applies solely to visitors, users, consumers and others who reside in the State of California (“California Consumers"). The provisions within this section have been adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and its regulations. Any terms defined in the CCPA have the same meaning when used in this section.
We collect from California Consumers. In the past twelve (12) months, we have collected the following categories of Personal Information:
• Identifiers (including, name, email address and phone number) and personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e). This information is collected directly and indirectly from you, and from third parties for the purpose of fulfilling or meeting the reason you provided the information and for such other purposes as may be described in the section titled “What Are The Purposes For Which We Process Your Personal Information.” For example, if you share your name to participate in the services provided by the burble App, we will use that Personal Information to facilitate your participation in the services. For more information on our collection and sharing of this type of information, please refer to the section titled “When And With Whom Do We Share Your Personal Information”.
• Protected classification characteristics under California or federal law. You may provide us with your gender in response to censuses or surveys of our users or in connection with your enrollment in one of our events or programs. We may also infer such information based on our interactions with you. You may also directly provide us with certain health-related information in order for us to accommodate your special needs or ensure your suitability for certain in-person events or programs.
• Commercial information (e.g., products or services purchased, purchase history). This information may be collected from third parties in order to better understand our users for marketing and product and service development purposes. We will also collect and store your purchases of our products and services to provide you with easy access to such offerings.
• Internet or other electronic network activity (e.g., browse or search history). This information is collected indirectly from you including through the use of tracking technology. This information is collected to assist us in operating and improving our products and services and for security purposes as well as for other purposes described in the section entitled “What Are The Purposes For Which We Process Your Personal Information.” This information may collected by or shared with our vendors and other third parties as further described in the section titled “When And With Whom Do We Share Your Personal Information”.
• Geolocation data (e.g., latitude or longitude). This information may be collected indirectly from you through our vendors. We use such information in order to better understand our users for marketing and product and service development purposes.
• Audio, electronic, visual, or similar information (e.g., recording of service calls). While we may record your customer service and sales calls, we only use such data to respond to your service issues and improve the provision of our services.
• Inferences drawn from any of the above (e.g., preferences or characteristics). Such personal information may be collected directly and indirectly from you, and from third parties. The inferences drawn therefrom helps us improve our ability to offer and deliver products that are tailored to your interests and needs. We may also use these inferences in assessments and reports provided to you as part of our services and as requested by you. This information may be shared with our vendors and third parties as further described in the section titled “When And With Whom Do We Share Your Personal Information”.
We may also collect other personal information outside of these categories 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.
The Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we endeavor to enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the relevant service on our behalf.
Non-Personal Information
Pursuant to the CCPA, personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Use and Sharing of Personal Information
We may use or disclose the Personal Information we collect as set forth in the section titled “What Are The Purposes For Which We Process Your Personal Information” or as otherwise set forth in the CCPA. We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
We collect and share your Personal Information through:
• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags
We may disclose your Personal Information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
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" your Personal Information.
We have disclosed the following categories of Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months:
■ Category B. Personal information, as defined in the California Customer Records law, such as your name, email address and telephone number.
The categories of third parties to whom we disclosed Personal Information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".
Your Rights and Choices
If you are a California Resident, You Have the Following Rights Under the CCPA:
• Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request to us via email at support@myburble.com, we will disclose to you:
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• In addition, if we disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that each category of recipient obtained.
• Right to Correct. Correction Request Rights. You may request that we correct any inaccurate Personal Information we maintain about you.
• Right to Delete. You have the right to request that the Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider to:
• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with any legal obligations.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Right to Opt Out. You have the right to request that we opt you out of the sale of your Personal Information or sharing your Personal Information for target or behavioral advertising.
• Right to Non-Discrimination. You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
• Right to Restrict or Limit the Use of Sensitive Personal Information. You have the right to restrict the use and disclosure of sensitive personal information to certain purposes related to the offering of goods or services as listed in the California Privacy Rights Act (“CPRA”).
• Exercising Access, Data Portability, and Deletion Rights. You may manage your information and preferences regarding our communications with you by changing your preferences or sending a request to us via email to support@myburble.com. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us via email at support@myburble.com
• Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To designate an authorized agent, please download, complete and return this form or provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also require verification of the identity of your designated agent.
• You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We consider requests made through an email address previously provided by you and associated with your account as sufficiently verified.
• Your verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or the authorized representative of such person and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• You can designate an authorized agent to make a request under the CCPA 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 the CCPA.
• Response Timing and Format. We endeavor to respond to verifiable California Consumer CCPA requests within forty-five (45) days of receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the email address associated with that Account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option, following verification. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
• We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. 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. We will delete such additionally provided information as soon as we finish verifying you.
Other California Privacy Rights
Under California’s “Shine the Light Law,” Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request via email to support@myburble.com or by mail to:
Burble, Inc.
1420 Walnut Street
Suite 1212
Philadelphia, PA 19102
United States
Attention: Privacy
To exercise these rights, you can contact us by email at alexandra@myburble.com[6] , or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Connecticut, Montana, Oregon, Texas, Utah and Virginia Residents
If you are a Connecticut, Montana, Oregon, Texas, Utah, or Virginia resident, you have certain rights related to your personal information. If you or an authorized agent wish to exercise these rights, you can submit a request using the methods listed below:
• Access Requests: email us at support@myburble.com
• Do Not Sell My Personal Information and Do Not Use My Information for Targeted Advertising Requests: email us at support@myburble.com
You may appeal our decision with respect to a request you have submitted by emailing us at support@myburble.com.
Nevada Residents
If you are a Nevada consumer, you have the right to request that a company not sell your personal information for monetary consideration to certain other parties. This right applies even if your personal information is not currently being sold. If you wish to exercise this right, you can submit a request by emailing us at support@myburble.com.
12. 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 the “Date Last Updated” and will be effective as soon as posting. 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.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
For more information about our privacy practices, if you have questions about this Privacy Policy, or if you wish to exercise your rights or make a complaint about how we handled personal information about you, please contact us using the contact details below for further assistance:
burble, Inc.
1420 Walnut Street
Suite 1212
Philadelphia, PA 19102
United States
support@myburble.com
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE PERSONAL INFORMATION WE COLLECT FROM YOU?
Based on the applicable laws of the jurisdiction in which you reside, you may have the right to request access to the Personal Information we collect from you, change that information, or delete it. To request to review, update, or delete your Personal Information, please visit: https://www.myburble.com/contact-us or contact us at support@myburble.com.
15. INFORMATION FOR INDIVIDUALS IN EEA, SWITZERLAND AND UK
If you use the Services and/or the burble App while in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”). The Company is a “data controller” subject to the General Data Protection Regulation (the “GDPR”) only insofar as we are offering goods or services to individuals in the EEA or where our digital assets may be used to monitor individuals' behavior as far as it takes place in the EEA.
Data Retention
We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.
Data Subject Requests
Subject to certain limits and conditions provided under law, in addition to the privacy rights described above, you have the right to:
• Object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).
• Withdraw any consent you have provided.
• Request that we transfer certain data to another data controller.
• File a complaint regarding our data protection practices with a supervisory authority.
• Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en.
• If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
• If you are in the United Kingdom, please see this site for contact details: https://ico.org.uk/global/contact-us/.
If you would like to exercise any of these rights and can't do so directly via the Services or your device, you may contact us as indicated above.
Above, we are stating the we are not collecting payment information. Are there any circumstances where burble will store credit card information (ie, future sales)?
Doesn’t this need to be changed to Apple Pay Google Pay
Alex, confirm accuracy of this statement. Or, do you sell or otherwise profit from personal information?
@nksinghesq@gmail.com In the terms end user agreement we say: 1. Age of Majority. You must be sixteen (16) years or older to use the Services. If You are under the age of majority in the jurisdiction where You reside, You may only use the Services if Your parent or legal guardian agrees to these Terms and any other policies governing the Services. In that regard, Your parent or legal guardian agrees that they are responsible for Your activity and any use of the Services.
_Assigned to nksinghesq@gmail.com_
Thanks for pointing that out. We should change this to 18 years of age since collecting information from minors is subject to higher scrutiny.
Should this email be used throughout instead of support@myburble.comPRIVACY POLICY
Date Last Updated September 26, 2024
This Privacy Policy describes the practices of burble, Inc. and our subsidiaries and affiliates (collectively, the ”Company," "we," "us," or "our") in connection with the Personal Information we collect from or about you when you access, use and/or subscribe to the burble mobile application (“burble App”), other online products and/or services offered by us (collectively, the ”Services”) and/or or otherwise interact with us.
From time to time, we may change and/or update this Privacy Policy. Please refer to the “Date Last Updated” to make sure you are aware of the current policies in place in connection with the Personal Information.
Please review this Privacy Policy from time to time. If you do not wish to provide us with such Personal Information or have it processed by us or any of our Service Providers (as defined below), please do not access, use, subscribe and/or otherwise interact with the burble App and/or the Services.
■ SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Policy, 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. For our full privacy policy please scroll down.
What personal information do we process? When you visit, use, or navigate the Services including the burble App, we may process Personal Information depending on how you interact with the burble App and/or the Services, the choices you make, and the products and features you use. Scroll down to this section to learn more.
Do we process any Personal Information? We may process Personal Information when necessary with your consent or as otherwise permitted by applicable law. Scroll down to this section to learn more.
Do we receive any Personal Information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Scroll down to this section to learn more.
How do we process your Personal Information? We process your Personal Information to provide, improve, and administer our Services and/or the burble App, communicate with you, for security and fraud prevention, and to comply with law. We may also process your Personal Information for other purposes with your consent. We process your Personal Information only when we have a valid legal reason to do so. Scroll down to this section to learn more.
In what situations and with which types of parties do we share Personal Information? We may share Personal Information in specific situations and with specific categories of third parties. Scroll down to this section to learn more.
How do we keep your Personal Information safe? We have 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 Personal Information. Scroll down to this section to learn more.
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. Scroll down to this section to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here: https://www.myburble.com/contact-us, or by contacting us. 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 Personal Information we collect? Scroll down to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. WHAT ARE THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW DO WE HANDLE YOUR SOCIAL MEDIA LOGINS?
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO RESIDENTS OF CERTAIN STATES HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE PERSONAL INFORMATION WE COLLECT FROM YOU?
15. INFORMATION FOR INDIVIDUALS IN EEA, SWITZERLAND AND UK
1. WHAT INFORMATION DO WE COLLECT?
The nature of the information we collect from you is dependent on how you engage with the burble App and/or the Services, and general consists of:
• Personal Information, which is information that can be used to identify you, including your name, email address and telephone number.
• Anonymous information, which is data about you, your device, your activities that does not by itself identify you.
When, and to the extent, anonymous information is combined with Personal Information, such information also becomes Personal Information and is treated and protected as such in accordance with the terms of this Privacy Notice.
We collect Personal Information and anonymous information that you directly provide to us as well as Personal Information you indirectly provide to us as you use the burble App and/or the Services. We may also collect Personal Information about you from third parties.
Personal Information You Disclose To Us
In Short: We collect Personal Information that you provide to us.
We collect Personal Information that you voluntarily provide to us when you subscribe to any of our Services including, without limitation, the burble App, participate in any interactive features in connection with the Services, request customer support, provide us with feedback and/or suggestions and/or otherwise communicate or interact with us.
Personal Information Provided by You. The Personal Information that we collect depends on the context of your interactions with us including, without limitation, through the Services and/or the burble App, the choices you make, and the products and features you use. The personal information we collect (“Personal Information”) may include the following:
■ full name;
■ email address;
■ username;
■ password;
■ contact preferences;
■ telephone number;
■ contact or authentication data;
■ demographic data;
■ mental wellness service usage data; and/or
■ purchase buying behavior related to wellness.
Payment Data.
The burble App utilizes third party products including Apple Pay and Google Play (collectively, “Payment Processors”) to securely process all subscription payments. By using Payment Processors, burble does not collect or store any payment details, such as credit card information. All transactions are handled directly by Apple or Google, ensuring your sensitive financial data is protected under their privacy and security policies.
For more information, please review the Payment Processors’ privacy policies below:
The Company, may when user so elects, collect[1] data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Paypal[2] . You may find their privacy notice link(s) here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full#personalData.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use the burble App, we also may collect the following information if you choose to provide us with access or permission:
■ Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, calendar, camera, contacts, microphone, reminders, sensors, sms messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
■ Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
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.
Information Automatically Collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services and/or use the burble App.
We automatically collect certain information when you visit, use, or navigate the Services and/or the burble App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
■ Device Data. We automatically collect device data such as information about your mobile device, computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your Internet Protocol (IP) address (or proxy server), device (including model and manufacturer) and application identification numbers, location, browser type and version, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Information Collected From Other Sources
In Short: We may collect limited Personal Information from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain Personal Information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This personal information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive Personal Information about you such as your name, email address, and gender. Any Personal Information that we collect from your social media account depends on the privacy settings on your social media account.
Information You Provide to Third Party Artificial Intelligence Tools Including ChatGPT
In connection with using the Services and/or the burble App, you may be interacting with third party artificial intelligence and large language model tools including, without limitation, ChatGPT. ChatGPT is an artificial intelligence program that generates dialogue by using machine learning algorithms to process and analyze large amounts of data to generate responses to user inquiries. We are not responsible for any information that you provide and/or otherwise disclose to ChatGPT, and we have no control over the manner in which ChatGPT uses or shares information. Prior to disclosing or communicating any personal information utilizing the Services and/or the burble App, in addition to reviewing the policies set forth herein, you should also review ChatGPT’s privacy policy at https://openai.com/policies/privacy-policy/.
2. WHAT ARE THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION?
In Short: We process your information to provide, improve, and administer our Services and/or the burble App, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes permitted by applicable law, with your consent.
We process your Personal Information for a variety of reasons, depending on how you interact with our Services and/or the burble App, including:
■ To personalize your experience and delivering content, products and services relevant to your stated and inferred interests, needs, location or other preferences.
■ To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
■ To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
■ To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
■ To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
■ To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services and/or the burble App.
■ To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
■ To send you marketing and promotional communications and deliver targeted advertising to you. We may process the personal information you send to us for our marketing purposes including, without limitation, to develop and display personalized content and advertising to your interests, location and more, if you affirmatively consent to same when you subscribe to any of the Services including, without limitation, the burble App. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
■ To post testimonials. We post testimonials on our Services and/or the burble App that may contain personal information.
■ To protect our Services. We may process your information as part of our efforts to keep our Services and/or the burble App safe and secure, including fraud monitoring and prevention.
■ To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, the burble App, products, marketing, and your experience.
■ To identify usage trends. We may process information about how you use our Services and/or the burble App to better understand how they are being used so we can improve them.
■ To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
■ 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 categories of third parties.
The Company will never sell or rent your Personal Information to any third party under any circumstances and will[3] only share or disclose your Personal Information with third parties as set forth in this Privacy Notice and for legitimate business reasons.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("Third Parties") who perform services for us or on our behalf and require access to such information to do that work. The categories of Third Parties we may share personal information with are as follows:
■ Communication & Collaboration Tools;
■ Data Analytics Services;
■ Data Storage Service Providers;
■ Finance & Accounting Tools;
■ Order Fulfillment Service Providers;
■ Payment Processors;
■ Performance Monitoring Tools;
■ Product Engineering & Design Tools;
■ Retargeting Platforms;
■ Sales & Marketing Tools;
■ Social Networks;
■ Testing Tools;
■ User Account Registration & Authentication Services; and
■ Website Hosting Service Providers.
We also 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.
■ Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
■ Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
■ Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please be sure to review the privacy notices of any such third party advertisers to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) in connection with the Services and/or the burble App for various purposes including authenticating you and recognizing your preference when you visit the burble App, customizing your experiences with the Services and/or burble App, analyzing website analytics and such other purposes as set forth elsewhere in this Privacy Notice. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services and/or the burble App.
5. HOW DO WE HANDLE YOUR SOCIAL MEDIA LOGINS?
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Services and/or the burble App offer you the ability to register and log in using your third-party social media account details (like your Google, Apple, Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal Information by your third-party social media provider. We recommend that you review their privacy notice(s) to understand how they collect, use, and share your Personal Information, and how you can set your privacy preferences on their sites and apps.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In Short: We keep your Personal 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 reasonably necessary to fulfill the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting periods. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we maintain and process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Please note that by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they cease being customers for tax purposes.
We may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes and use this information indefinitely without further notice to you.
7. HOW DO WE KEEP YOUR PERSONAL 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. 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 and/or the burble App within a secure environment.
8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
In Short: We do not knowingly solicit or collect data from children under 18 years of age.
We do not knowingly solicit or collect data from from children under 18 years of age. 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 the age of 18, please contact us at support@myburble.com.[4] [5]
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account or uninstall the burble App at any time.
Uninstall the burble App or Terminate Your Account. You can stop all further collection of information by the Services and/or burble App by uninstalling the burble App and/or terminating your account. You may use the standard uninstall process available as part of your mobile device or via the mobile application marketplace or network. In addition, you may terminate your account by contacting us as set forth below.
If you uninstall the burble App or terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information including, without limitation, Personal Information in our files including, without limitation, any scripts generated by the Services and/or the burble App as set forth herein including, without limitation, to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements and obligations.
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 by 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 of your Personal Information before your withdrawal of consent, nor when applicable law allows, will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
Opting Out of Marketing and Promotional Communications. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
10. 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.
11. DO RESIDENTS OF CERTAIN STATES HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, Connecticut, Montana, Oregon Texas, Utah, Virginia and/or Nevada, you are granted specific rights regarding access to your Personal Information as set forth in more detail below.
California Residents’ Rights Under the California Consumer Privacy Act
This section supplements the information contained in this Privacy Notice and applies solely to visitors, users, consumers and others who reside in the State of California (“California Consumers"). The provisions within this section have been adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and its regulations. Any terms defined in the CCPA have the same meaning when used in this section.
We collect from California Consumers. In the past twelve (12) months, we have collected the following categories of Personal Information:
• Identifiers (including, name, email address and phone number) and personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e). This information is collected directly and indirectly from you, and from third parties for the purpose of fulfilling or meeting the reason you provided the information and for such other purposes as may be described in the section titled “What Are The Purposes For Which We Process Your Personal Information.” For example, if you share your name to participate in the services provided by the burble App, we will use that Personal Information to facilitate your participation in the services. For more information on our collection and sharing of this type of information, please refer to the section titled “When And With Whom Do We Share Your Personal Information”.
• Protected classification characteristics under California or federal law. You may provide us with your gender in response to censuses or surveys of our users or in connection with your enrollment in one of our events or programs. We may also infer such information based on our interactions with you. You may also directly provide us with certain health-related information in order for us to accommodate your special needs or ensure your suitability for certain in-person events or programs.
• Commercial information (e.g., products or services purchased, purchase history). This information may be collected from third parties in order to better understand our users for marketing and product and service development purposes. We will also collect and store your purchases of our products and services to provide you with easy access to such offerings.
• Internet or other electronic network activity (e.g., browse or search history). This information is collected indirectly from you including through the use of tracking technology. This information is collected to assist us in operating and improving our products and services and for security purposes as well as for other purposes described in the section entitled “What Are The Purposes For Which We Process Your Personal Information.” This information may collected by or shared with our vendors and other third parties as further described in the section titled “When And With Whom Do We Share Your Personal Information”.
• Geolocation data (e.g., latitude or longitude). This information may be collected indirectly from you through our vendors. We use such information in order to better understand our users for marketing and product and service development purposes.
• Audio, electronic, visual, or similar information (e.g., recording of service calls). While we may record your customer service and sales calls, we only use such data to respond to your service issues and improve the provision of our services.
• Inferences drawn from any of the above (e.g., preferences or characteristics). Such personal information may be collected directly and indirectly from you, and from third parties. The inferences drawn therefrom helps us improve our ability to offer and deliver products that are tailored to your interests and needs. We may also use these inferences in assessments and reports provided to you as part of our services and as requested by you. This information may be shared with our vendors and third parties as further described in the section titled “When And With Whom Do We Share Your Personal Information”.
We may also collect other personal information outside of these categories 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.
The Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we endeavor to enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the relevant service on our behalf.
Non-Personal Information
Pursuant to the CCPA, personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Use and Sharing of Personal Information
We may use or disclose the Personal Information we collect as set forth in the section titled “What Are The Purposes For Which We Process Your Personal Information” or as otherwise set forth in the CCPA. We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
We collect and share your Personal Information through:
• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags
We may disclose your Personal Information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
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" your Personal Information.
We have disclosed the following categories of Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months:
■ Category B. Personal information, as defined in the California Customer Records law, such as your name, email address and telephone number.
The categories of third parties to whom we disclosed Personal Information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".
Your Rights and Choices
If you are a California Resident, You Have the Following Rights Under the CCPA:
• Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request to us via email at support@myburble.com, we will disclose to you:
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• In addition, if we disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that each category of recipient obtained.
• Right to Correct. Correction Request Rights. You may request that we correct any inaccurate Personal Information we maintain about you.
• Right to Delete. You have the right to request that the Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider to:
• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with any legal obligations.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Right to Opt Out. You have the right to request that we opt you out of the sale of your Personal Information or sharing your Personal Information for target or behavioral advertising.
• Right to Non-Discrimination. You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
• Right to Restrict or Limit the Use of Sensitive Personal Information. You have the right to restrict the use and disclosure of sensitive personal information to certain purposes related to the offering of goods or services as listed in the California Privacy Rights Act (“CPRA”).
• Exercising Access, Data Portability, and Deletion Rights. You may manage your information and preferences regarding our communications with you by changing your preferences or sending a request to us via email to support@myburble.com. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us via email at support@myburble.com
• Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To designate an authorized agent, please download, complete and return this form or provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also require verification of the identity of your designated agent.
• You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We consider requests made through an email address previously provided by you and associated with your account as sufficiently verified.
• Your verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or the authorized representative of such person and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• You can designate an authorized agent to make a request under the CCPA 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 the CCPA.
• Response Timing and Format. We endeavor to respond to verifiable California Consumer CCPA requests within forty-five (45) days of receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the email address associated with that Account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option, following verification. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
• We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. 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. We will delete such additionally provided information as soon as we finish verifying you.
Other California Privacy Rights
Under California’s “Shine the Light Law,” Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request via email to support@myburble.com or by mail to:
Burble, Inc.
1420 Walnut Street
Suite 1212
Philadelphia, PA 19102
United States
Attention: Privacy
To exercise these rights, you can contact us by email at alexandra@myburble.com[6] , or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Connecticut, Montana, Oregon, Texas, Utah and Virginia Residents
If you are a Connecticut, Montana, Oregon, Texas, Utah, or Virginia resident, you have certain rights related to your personal information. If you or an authorized agent wish to exercise these rights, you can submit a request using the methods listed below:
• Access Requests: email us at support@myburble.com
• Do Not Sell My Personal Information and Do Not Use My Information for Targeted Advertising Requests: email us at support@myburble.com
You may appeal our decision with respect to a request you have submitted by emailing us at support@myburble.com.
Nevada Residents
If you are a Nevada consumer, you have the right to request that a company not sell your personal information for monetary consideration to certain other parties. This right applies even if your personal information is not currently being sold. If you wish to exercise this right, you can submit a request by emailing us at support@myburble.com.
12. 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 the “Date Last Updated” and will be effective as soon as posting. 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.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
For more information about our privacy practices, if you have questions about this Privacy Policy, or if you wish to exercise your rights or make a complaint about how we handled personal information about you, please contact us using the contact details below for further assistance:
burble, Inc.
1420 Walnut Street
Suite 1212
Philadelphia, PA 19102
United States
support@myburble.com
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE PERSONAL INFORMATION WE COLLECT FROM YOU?
Based on the applicable laws of the jurisdiction in which you reside, you may have the right to request access to the Personal Information we collect from you, change that information, or delete it. To request to review, update, or delete your Personal Information, please visit: https://www.myburble.com/contact-us or contact us at support@myburble.com.
15. INFORMATION FOR INDIVIDUALS IN EEA, SWITZERLAND AND UK
If you use the Services and/or the burble App while in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”). The Company is a “data controller” subject to the General Data Protection Regulation (the “GDPR”) only insofar as we are offering goods or services to individuals in the EEA or where our digital assets may be used to monitor individuals' behavior as far as it takes place in the EEA.
Data Retention
We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.
Data Subject Requests
Subject to certain limits and conditions provided under law, in addition to the privacy rights described above, you have the right to:
• Object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).
• Withdraw any consent you have provided.
• Request that we transfer certain data to another data controller.
• File a complaint regarding our data protection practices with a supervisory authority.
• Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en.
• If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.
• If you are in the United Kingdom, please see this site for contact details: https://ico.org.uk/global/contact-us/.
If you would like to exercise any of these rights and can't do so directly via the Services or your device, you may contact us as indicated above.