Last updated: January 5, 2021
- Information We Collect
- How We Use Your Information
- Legal Basis for Use of Your Information
- Cookies and Similar Technologies
- Online Analytics and Interest-Based Advertising
- How We Share Your Information
- Protection of Information
- Retention of Information
- Third Party Links and Features
- Children’s Privacy
- Your Choices and Rights
- Information for California Residents
- Information Nevada Residents
- Information for International Users
- Contact Us
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:
- Send messages with Clients via the Service, we will collect your messaging history and any information included in those messages.
- Interact with content on one of our Clients’ websites or mobile applications and submit your email address, phone number, and/or any additional information that you choose to provide.
- Contact us with questions or for customer service, we will collect contact information such as your name, email address, and phone number, and any information you provide in connection with your question.
- Participate in a contest, sweepstakes, research study, or email survey, we will collect basic contact information and any other information you provide in connection with these activities.
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.
- Device Information. We collect technical information associated with the device(s) you use to access our Service, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.
- Usage Information. We collect a variety of information to better understand use of our Service. This may include the webpage that you were visiting before accessing our Service, the pages or features of our Service you use, how much time you spend there, date and time of use, and information about your usage preferences.
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:
- Administer your account, including to verify your information and to collect payments;
- Provide, manage, support, and improve our Service;
- Respond to your requests for information and provide you with more effective and efficient customer service;
- Conduct internal business operations in support of our Service, such as auditing, security, resolving crashes, preventing fraud, invoicing and accounting, sales and marketing, analytics, and research and development;
- Contact you regarding BubblePay and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you (in accordance with any privacy preferences you have expressed to us);
- Customize content, preferences, and advertising on the Service, across the Internet and elsewhere;
- Comply with applicable laws, regulations, and other legal processes and procedures;
- Establish, exercise, or defend our legal rights;
- Conduct cross-device tracking for our Clients by using information such as IP addresses and unique mobile device identifiers to identify the same unique users across multiple browsers or devices (such as smartphones or tablets), in order to save Consumers’ preferences across devices and analyze usage of the Service.
- Process payments you have authorized using the Payment Service and provide related services, including to communicate about products and services you have purchased using the Payment Service, take and handle orders for products and services, and respond to your inquiries.
- For any other purpose with your consent.
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.
Legal Basis for Use of Your Information
The legal basis for using your information as set out in this Policy are as follows:
- Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service for use of our Service which you accept by browsing the websites/registering; and/or our contract to provide our Service to you);
- Where use of your information is necessary for our legitimate interests or the legitimate interests of others for example, to provide security for our website and applications; operate our business and our Service; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing our Service;
- Where you have authorized us to use your information to help you make and receive payments using the Payment Service, including to manage the daily operations of BubblePay, validate payment transactions completed using the Payment Service and verify our ongoing compliance with applicable agreements, laws and regulations; or
- Where required by law, and in some other cases, we handle personal data on the basis of consent.
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.
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.
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.
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:
- provide access to and/or a copy of certain information we hold about you;
- prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
- update or rectify information which is out of date or incorrect;
- delete certain information which we are holding about you;
- oppose, cancel, or restrict the way that we process and disclose certain of your information;
- transfer your information to a third-party provider of services; or
- revoke your consent for the processing of your information.
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:
- You can opt-out of receiving further promotional emails from us by following the unsubscribe instructions provided in the promotional email you receive from us or by contacting us directly at the email address listed below.
- Our Clients may send you emails or text messages using our services. If you would like to opt-out of receiving such further communications, you need to exercise your rights with our Clients by, for example, unsubscribing to Client emails or by responding to an BubblePay generated text message from our Clients with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.
Information for California Residents and California Notice at Collection
- From employees or job applicants in their capacity as employees or job applicants;
- Personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; and
- Information that we process as a service provider on behalf of other businesses, such as our Clients.
CCPA Categories of California Personal Information We Collect
How We Use and Disclose These Categories of Personal Information
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:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
- Provide access to and/or a copy of certain personal information we hold about you.
- Delete certain personal information we have about you.
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 email@example.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 firstname.lastname@example.org. 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.