BubblePay Privacy Policy

Last updated: January 5, 2021

BubblePay (“BubblePay,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how BubblePay collects, uses, discloses, and secures information about you through http://bubblepay.com/ (“Website”), our computer or mobile applications, and our electronic communications, including email and text messages, and the services that we provide to our Clients and their Customers (collectively, the “Service”).

By using the Service, you consent to the collection and handling of your information as set forth in this Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICE.

This Privacy Policy contains the following sections:

Information We Collect


BubblePay collects information from and about users of our Service in a variety of ways. We act as a service provider to organizations (“Clients”) who want to engage with individual consumers (“Consumers”) through the Service. In providing the Service to our Clients, we collect and obtain information about Consumers to, among other services, deliver commercial text messages to Consumers’ mobile phones that can also be used to make payments. The Service includes a feature that allows Consumers to complete transactions to purchase goods or services from merchants (the “Payment Service”). With respect to the Payment Service, we collect and obtain information about Consumers and the underlying transactions that are completed using the Payment Service.We also collect information from Clients, Consumers and individuals who are neither Clients nor Consumers when they visit our Website.

Information You Provide. We collect information you provide when you use the Service or otherwise communicate with us.

If you are a Client, we will collect the information you provide when you register for and contract to use the Service.

If you are a Consumer, we collect various information you directly provide when you use the Service, for example, when you:

Information about Consumers that Clients Provide to Us. Clients may provide us with information about their Consumers through the Service or offline for inclusion in the Service.  Such information may include Consumers’ name, email address, and telephone number. Our Clients are responsible for providing notice and obtaining appropriate consents necessary for us to process this information.

Information We Automatically Collect. Like most online services, we may automatically receive and store certain information about you through your device(s). As discussed further below, we and our service providers may use a variety of technologies, including cookies, to assist in this information.

Information We Collect When You Use the Payment Service. We collect information to help us verify and facilitate transactions completed using the Payment Service. This may include personal information about the buyer and seller participating in a transaction or information about the devices used to complete the transaction (e.g. names, email addresses, IP address, authentication methods), transaction-related communications (e.g. email subject line), history of actions that buyers and sellers take on a transaction (e.g. reviewing and approving transactions, providing payment method details), and the metadata associated with that transaction (e.g. automatically generated transaction identifiers).

Information We Collect from Social Media and Other Content Platforms. When you “like” or “follow” us on Facebook, Instagram, Twitter, LinkedIn, or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.

Information We Collect from Others. We may also receive information about you from service providers, advertisers, partners, and other third parties that we work with.  We may combine this information with other information we received about you through the Service.

How We Use Your Information

We, or our service providers, use your information for various business and operational purposes:

Combined Information. For the purposes discussed in this Policy, we may combine the information that we collect through the Service with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.

Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through the Service so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties in our discretion.

Cookies and Similar Technologies

To collect the information in the Information We Automatically Collect section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more personalized experience in the future (e.g. send Consumers personalized text messages such as shopping cart reminders), by understanding and remembering your particular browsing preferences.

As we adopt additional technologies, we may also gather information through other methods and technologies.

Please note that you can change your settings to notify you when certain cookies are being set or updated, or to block certain cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Service and that BubblePay does not control the choices that are available through above third party offerings.

For more information on the cookies we use and the purposes for which we use them, please refer to our Cookies Notice. By continuing to use our websites and/or our Service, you are agreeing to our use of cookies as described in our Cookies Notice.

Online Analytics and Interest-Based Advertising

Analytics. We may use third-party analytics services (such as those of Google Analytics) on our Service to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Interest-Based Advertising. When you use the Service, BubblePay may use the information collected from you in order to display advertising to you on other websites, such as Facebook or Google or on our Clients’ websites or mobile applications about products, services, and related features that we think may be of interest to you to improve and personalize your use of the Service. This type of advertising is called retargeting. These ads may be personalized based on various factors such as the features you are using, demographic and geographic data, and other information that we collect about you.  This advertising may be based on your current activity or your activity over time and may be tailored to your interests.

In order to provide this interest-based advertising, we may use third party service providers who, on our behalf, may place cookies or other tracking technologies, such as cookies and SDKs on your computer browser, mobile phone applications, or other devices to collect information about your use of the Service in order to provide interest-based advertising to you both on the Service and on other websites.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party providers. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each third-party service provider, not us.

If you are interested in more information about interest-based advertising and how you can generally control cookies and other tracking technologies from being put on your device to deliver such advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link, or TrustArc’s Advertising Choices Page. To opt out of the display of interest-based advertising from Google, please visit the Google Ads Settings page. Facebook also offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. For more information, you will need to log in to Facebook via the Sign In link and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app).

Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising even if you opt-out as described above. In that case, the advertising will just not be based on your interests.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals. Learn more about Do Not Track.

How We Share Your Information

We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:

From time to time, we may share aggregate or de-identified information about use of the Service and individuals. We may share or disclose such aggregate or de-identified information with any third party, including advertisers, promotional partners, and sponsors.

Protection of Information

We take a variety of physical, technical, administrative, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.  These measures are commensurate with the sensitivity of the information that we maintain about you.  Unfortunately, no online activity can be guaranteed to be 100% secure.  While we strive to protect your information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide to us.  We do not accept liability for unintentional disclosure.

Retention of Information

We retain your information for as long as your account is active or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect BubblePay and our users, and enforce our agreements.

Children’s Privacy

The Service is intended for general audiences and not for children under the age of 13. If we become aware that we have collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without legally valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Your Rights and Choices

We respect your right to make choices about the ways we collect, use, and disclose your information.

Your Legal Rights. Depending on the laws of your local jurisdiction, you may have certain rights and choices with respect to your information. For example, under local laws, you may be able to ask us to:

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests, to comply with a legal obligation, or if you are a resident of a country or state that does not provide the rights you have requested. We will let you know where this is the case or if certain rights don’t apply in your country or state of residence. We may request you provide us with information necessary to verify your identity before responding to your request as required or permitted by applicable law.

Marketing Communications. You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, and promotions that might appeal to your interests by contacting us using the information below:

Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Information for California Residents and California Notice at Collection

This section applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements the information in the rest of our Privacy Policy. Data about individuals who are not residents of California may be handled differently and is not subject to the same California rights described below. In addition, this section does not apply to personal information we collect in the following circumstances:

CCPA Categories of California Personal Information We Collect

Throughout this Privacy Policy, including in theInformation We Collect section, we discuss in detail the specific pieces of personal information n we collect about individuals. Under the CCPA, we are also required to provide you with the CCPA “categories” of personal information we collect. The categories we collect are: identifiers (such as name, address, phone number, email address); commercial information (such as transaction data); internet or other network or device activity (such as browsing history or IP address, including the city and state based on IP address); and other information that identifies or can be reasonably associated with you.

How We Use and Disclose These Categories of Personal Information

We and our service providers may use and disclose (and in the past 12 months have used and disclosed) all of the personal information we collect for the business purposes described in this Privacy Policy, and in accordance with our disclosures in the How We Use Your Information and How We Share Your Information sections above.

Sale of Personal Information

The CCPA also provides California residents with the right to opt out of the “sale” of personal information.  Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months.  We provide information on a variety of ways in which you can prevent cookies and other tracking technologies from being used on your devices in the Online Analytics and Interest-Based Marketing section.

Please note that we also do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.

Your California Privacy Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. You also may have the right to receive information about the financial incentives that we offer to you (if any).

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Service to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, phone number, email address, and other account information. You are also permitted to designate an authorized agent to submit certain requests on your behalf.  If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at privacy@bubblepay.com.

California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products from us, you may submit a request to opt out of any potential future sales under Nevada law by email to privacy@bubblepay.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Information for International Users

BubblePay is based in the United States and, regardless of where you use our Service, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Service, you consent to this collection, transfer, storage, and processing of information to and in the United States.

Privacy Policy Updates

We may update this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our Service, or advances in technology. We will make the revised Privacy Policy accessible through use of the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Updated” date included at the beginning of this Privacy Policy. If we make a material change to the Privacy Policy, you will be provided notice in accordance with legal requirements. Your use of this Service following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.

Contact Us

If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact our Data Protection Officer at: privacy@bubblepay.com.