Effective Date: 07/19/2019
BY ACCESSING, BROWSING, OR USING THE SERVICES, INCLUDING REGISTERING AN ACCOUNT WITH OUR SERVICES, YOU EXPRESSLY CONSENT TO THE COLLECTION, TRANSFER, USE, PROCESSING AND STORAGE OF YOUR INFORMATION (INCLUDING PERSONAL INFORMATION), AS DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY OR THE INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES DESCRIBED IN THIS POLICY, DO NOT USE THE SERVICES.
- INFORMATION COLLECTION PRACTICES
- General. If you register for an account, verify ownership of or request return of an item, or otherwise use a Service, we will collect some personally identifiable information from you, including your full name, email address, phone number, geographic location, occupation, employer, home or shipping addresses, phone, and a password that you select. We may also collect information relating to the item about which you have identified, inventoried, or of which you are seeking return, including characteristics, markings or other information necessary to identify the item. In connection with identifying, inventorying or returning an item, we may also collect information related to your stay or presence at one or more Hotel Customer locations, including the dates, duration, facility use and room type.
When you interact with the Services, we also receive and store certain additional types of information which, in general, does not directly identify you. For example, we automatically receive and record information on our server logs from your browser or device including your IP address, browser type and language, referring/exit pages and URLs, other browser history, device type, wi-fi network information, crash reports, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time. This Section of the Policy outlines the various ways that information is collected from the Services. Please fully review this Policy before you use the Services or submit information to us.
- Information that You Provide.
- Registration and Login. Certain Services may require you to register for an individual account or associated with the entity on whose behalf you use the Services (“Account”). When you register for an Account you will be asked to provide some personally identifiable information, including your full name, email address, phone number, occupation, employer, and a password that you select. When you register an Account and log in to a Service you must provide your current, complete, and accurate information. It is your responsibility to keep your information up to date. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.
- Uploads. If you upload, submit, or otherwise provide materials to the Services (including within your Account profile), we may collect personally identifiable information about you or other individuals that you submit and we may save the information in a profile specific to you or the entity on whose behalf you use the Services.
- Correspondence. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us information about your use of the Services, we may save the information in a profile specific to you.
- Support. If you speak or correspond with our sales associates or support associates, we may collect information from you and may save that information in a profile specific to you.
- Information We Receive from Others.
We also obtain data from third parties or use third parties to assist us with data collection. For example, we may supplement or confirm the accuracy of the data we collect as described in this Policy by collecting data from third parties.
- Our Hotel Customers. We may receive information about you from our Hotel Customers or their affiliates, in connection with a missing item or your stay or presence at the Hotel Customer’s premises. For example, if you have been contacted in connection with the identification and return of an item, we may collect information from you related to your presence or stay at a Hotel Customer and compare and supplement, verify, or aggregate that information with information from the Hotel Customer.
- Our Service Providers. As provided in Section 4, we may provide information to Third Party Providers in connection with the Services. We may also receive information about you from these Third Party Providers, such as Shipo, when you complete or fulfill a shipping transaction.
- Automatically Collected Information. We will collect some information about you and any product or device you use to access or use the Services automatically using a variety of technologies. In general, automatically collected information about the use of the Services does not directly identify you and the information may include, as applicable, your diagnostic log information, device IDs, metadata associated with content stored on the Services, IP address, browser and device type and language, the components of the Services you requested and viewed, the amount of time spent on particular parts or pages of the Services, Service navigation, usage history, IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, and the date and time. We collect this information for the purposes described in this Policy, including to better understand our customer base and to improve the quality of our Services.
- Pixels (aka web beacons/web bugs/java script). Pixels are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a user’s computer hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. If you are accessing the Services through a web browser, our third-party analytics provider may place pixels on our Services that track what other websites you visit (both before and after visiting the Services). Our third-party analytics provider uses information obtained from pixels to help us improve our business and the Services. We do not control the use of pixels by third parties. See Section 4 (Third Party Providers) for more information and review the privacy policies of each of the third party providers for more information on third party pixels.
- Location Data. We collect data about the location of the computer or device that you use to access the Services (“Location Data”) using IP address, GPS, cellular towers and other information from your mobile service provider, Bluetooth address, Wi-Fi access points and information made available by you or others that indicates the current or prior location of the user. How we collect Location Data depends on how you access the Services. The Services may collect Location Data even when you are not actively using the Services. If you do not want us to collect Location Data from your mobile device, please turn off the location settings.
- USE OF INFORMATION
- General. How we use information depends on how you use the Services. We use information:
- To administer your Account and provide the Services to you
- Create and manage your Account.
- Provide you with customer support and respond to your requests.
- Complete your transactions.
- Communicate with you about our products and services, including order management and billing.
- To improve the Services and develop new ones
- Administer focus groups and surveys.
- Conduct research and analysis of users’ behavior to improve the Services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior).
- Develop new products and services.
- To prevent, detect and fight fraud
- Analyze data to better understand and design countermeasures against fraudulent activities.
- To ensure legal compliance
- Comply with legal requirements.
- Assist law enforcement.
- Enforce or exercise our legal rights.
- Resolve disputes.
- Any other purpose described in this Policy or that we describe to you at the time of collection
- Email Communications. We may use your personally identifiable information to send you emails, notifications, or other communications related to your Account or the Services, or in response to your inquiries or requests. You may not opt-out of receiving service-related messages that are not promotional in nature. We may also send you marketing emails, surveys, or newsletters to notify you about products or services that may be of interest to you. If you would like to stop receiving marketing emails from us, please click on the unsubscribe link at the bottom of any marketing email you receive. If you opt-out, you will continue to receive service-related emails.
- Non-identifying Information. We may use non-identifying information for any lawful purpose, including analyzing trends, research, Services administration, tracking users’ movements around the Services, and to improve our business and the Services.
- Retaining Your Information. In general, we will retain your information indefinitely, or as long as legally required or allowed. If you cancel your Account or your Account is otherwise terminated, we may, but are not obligated to, delete information we have collected or obtained from third parties and we may continue to use and disclose it in accordance with this Policy.
- Basis of Processing. To process your information as described above, we rely on the following legal bases:
- Legitimate interests. We may use your information where we have legitimate interests to do so. For example, we use your information to provide the products and services that you request and to market similar products and services.
- Consent. From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Policy.
- INFORMATION SHARING
- Generally. We will not sell or rent any of your personal information to third parties for their marketing purposes. However, we may disclose your information: (a) to any affiliated entity or organization and to agents, (b) service providers (including internal and external app developers), (c) shipping providers, carriers and payment processors as necessary to facilitate your requested shipping transaction; and (b) the Hotel Customer on whose behalf you access the Services or in connection with which you have been contacted regarding the identification and return of an item. We may share non-identifying information with third parties for any lawful purpose, including analyzing trends, research, Services administration, tracking users’ movements around the Services, and to improve our business, products, services, and the Services. Use of information by affiliated entities and organizations will be subject to this Policy or an agreement that is at least as restrictive as this Policy. For information on the use of information by agents and service providers see Section 4 (Third Party Providers).
- Legal Requirements. In some cases, we may disclose your personally identifiable information as required by law; if we believe that disclosure is needed to protect our rights; to government regulators; to law enforcement authorities; in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Services; and to respond to a physical threat to you or another person.
- Insolvency and Business Transitions. If we ever file for bankruptcy or engage in a business transition such as a merger with another company or if purchase, sell, or reorganize all or a part of the Services or our business or assets, we may disclose your personal information, including to prospective or actual purchasers in connection with one of these transactions.
- Disclaimer. We cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Policy. For example, we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Services. No transmission of data over the internet can be 100% secure.
- THIRD-PARTY PROVIDERS
- General. We use third parties to help us operate and improve the Services. We may provide these third parties information we collect and they may collect information from you and about your use of the Services. We may provide information we collect to third parties and it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the Services and provide services to us. We do not control the information collected by third parties and are not responsible for their use of that information. Please review their privacy policies for more information on their information collection, use, and sharing practices.
- ONLINE TRACKING AND YOUR CHOICES
- INFORMATION SECURITY MEASURES
Keeping secure personal information that we collect is of great concern to us. While we have mechanisms in place to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When you provide information to the Services, you do so at your own risk.
- The Services are not for or Directed Toward Children. Our primary audience is adults. We do not intend to and will not knowingly collect any personal information from children under the age of 13; children under the age of 13 are prohibited from using the Services without parent/guardian supervision. If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers (subject to applicable law and this Policy). If you believe Content from a child under the age of 13 has been posted to the Services, please contact us using the contact information in the Privacy Questions section at the bottom of this Policy. We also recommend that children over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the internet.
- California Minors. If you are a California resident who is under age 18 and you are unable to remove publicly-available Content that you have submitted to us, you may request removal by contacting us using the contact information in the Privacy Questions Section at the bottom of this Policy. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. REMOVAL OF YOUR CONTENT OR INFORMATION FROM THE SERVICES DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the Content or information posted by you; our obligations under California law are satisfied so long as we anonymize the Content or information or render it invisible to other users and the public.
- CALIFORNIA SHINE THE LIGHT LAW
California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request you may contact us using the contact information in the Privacy Questions Section at the bottom of this Policy.
- ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
- Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law). If you are accessing the Services on behalf of your employer, please first request access to your personal data with your employer. Your employer will then be in touch with us with respect to your request.
- Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
- Portability: If you reside within the European Union, you have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to the only personal data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures. If you are accessing the Services on behalf of your employer, please first request access to your personal data with your employer. Your employer will then be in touch with us with respect to your request.
- THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
If you reside within the European Union you may be entitled to other rights under the GDPR. These rights are summarized below. We may require you to verify your identity before we respond to your requests to exercise your rights. If you are entitled to these rights, you may exercise these rights with respect to your personal data that we collect and store:
- the right to withdraw your consent to data processing at any time (please note that this might prevent you from using certain aspects of the Portal, the Services, or the Portal or Services altogether);
- the right of access your personal data;
- the right to request a copy of your personal data;
- the right to correct any inaccuracies in your personal data;
- the right to erase your personal data;
- the right to data portability, meaning to request a transfer of your personal data from us to any other person or entity as chosen by you;
- the right to request restriction of the processing of your personal data; and
- the right to object to processing of your personal data.
You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above listed rights may be made to: [INSERT EMAIL].
If you reside within the European Union, you have the right to lodge a complaint with a Data Protection Authority about how we process your personal data at the following website:
If you live in the European Union, the data controller for the information you provide or that we collect is: Bounte, LLC, 222 E. Wisconsin ave. suite 3. Lake Forest, IL. 60045
- INTERNATIONAL TRANSFERS
Personal information collected by us may be stored and processed in your region, in the United States or in any other country where we, our affiliates, clients, or contractors maintain facilities, including outside the European Union. Please be aware that any information you provide to us maybe transferred to, processed, maintained, and used outside your jurisdiction of residence where the privacy and data protection laws may not be as protective as those in your jurisdiction.
- LINKS TO OTHER WEBSITES AND SERVICES
The Services may include links to third-party websites and services that are not operated by us. When you click on these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of the information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Policy does not apply to any personal information that you provide to those other websites and services.
- MODIFICATION OF THIS POLICY
The Effective Date of this Policy is set forth at the top of this webpage. We reserve the right to change this Policy as business needs require. If we make material changes to the way we use Personal Information, we will provide advance notice to you by email or by posting a message on the Services. Your continued use of the App after the Effective Date constitutes your acceptance of the amended Policy. The amended Policy supersedes all previous versions.
- PRIVACY QUESTIONS
If you have any concerns or questions about these policies, please contact us at: firstname.lastname@example.org