Buddy Tech US - Privacy Policy

Privacy Policy Applicability

This Privacy Policy applies when you use or access the Services or share information with Buddy. By accessing or using the Services and/or opting into this Privacy Policy (as applicable in your jurisdiction), you consent to this Privacy Policy. Buddy may update this Privacy Policy at any time. If you do not consent to this Privacy Policy for any reason, please do not access or use the Services or share your information with us. Please note that this Privacy Policy applies only to the Services and not to any other third-party website linked to or from it, or any third-party website in which Buddy’s content or functionality is embedded. We do not control the privacy policies or practices of others.

Information We Collect from You

In general, we receive and collect all information you provide via the Services, including through website input fields, advertisements, phone, email (including email campaigns), user reviews, or other such ways. This includes personal information that can identify or relates to you, including, but not limited to:

How We Use Your Information

We process your personal information with your consent or as needed to provide you the Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Buddy as described in this Privacy Policy.

More specifically, we may use your personal information to: 

• Facilitate your access and use of the Services. We use your personal information to provide you with access to the Services and to manage your preferences. We may vet or assess you as a new user, including to perform screening related to anti-money laundering, anti-terrorism, sanctions, fraud, or other relevant industry standards. 
• Optimize and improve the Services. We continually try to improve the Services based on the information and feedback we receive from you and our other users, including by optimizing the content on or functionalities of the Services.
• Personalize the user experience. We may use your information to measure and optimize engagement with the Services and to understand how you and our other users interact with and use the Services and other resources we provide.
• Improve customer service. Your information helps us to more effectively develop the Services and respond to your support needs.
• Process transactions. We may use the information you provide to fulfill your requests. We do not share this information with outside parties except to the extent necessary to provide the Services and related activities.
• To send periodic communications. The communication methods you provide through our contact forms will be used to send information and updates pertaining to the Services. It may also be used to respond to your inquiries or other requests. If you opt into our mailing list, you may receive emails that include Buddy news, updates, product offerings and service information, and marketing material. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via the contact information below. Please note that if you unsubscribe from promotional emails, you may still receive communications related to your subscription, your purchase, or other necessary functionalities of the Services.
• To send periodic SMS messages. We may occasionally send you SMS messages through the number you provided to us. The messages will be sent based on Buddy’s legitimate business needs and in furtherance of us providing the Services. If at any time you would like to unsubscribe from receiving future SMS messages, we include detailed unsubscribe instructions for how to do so or you may contact us via the contact information below.
• Carry out other legitimate business interests. We may use the information you provide to carry out other legitimate business purposes, as well as other lawful purposes. 

We may use any aggregated information (as described below) for any purpose. 

How We Share Your Information

We share your information with our partners, service providers, contractors, agents, and third-party vendors indicted in the “Information We Collect from You” section as needed to fulfill Services. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, or respond to a request you submit.

Third-party vendors who provide products, services or functions on our behalf may include cloud database providers, data analytics companies, customer service vendors, communications service vendors, logistics service providers, marketing vendors, and security vendors. Third-party vendors have access to and may collect personal information only as needed to perform their functions, may only use personal information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose.

We also may share your information:

• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our customers, or others; or in connection with our End User License Agreement and other agreements with customers of which you may be affiliated.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.

Personal Information You Post in Public Areas. When you send another user a chat message or post a review, or customer feedback, the information you post may be accessible to other users of the Services and the public. If you post personal information anywhere on the Services that is accessible to other users or the public, you are advised that such personal information can be read, collected, used, or disseminated by others and could be used to send you unsolicited information or for other purposes. Accordingly, you assume full risk and responsibility for posting such information and agree that Buddy is not responsible in any way for personal information you choose to post in these public areas.

Aggregated Information.  We may use, publish, share, distribute, or disclose personal information that has been aggregated with information from other users and otherwise anonymized and de-identified in a manner that does not allow third parties, including Buddy partners, customers, and vendors, to de-identify the data or identify it as originating from you. Such information may help Buddy identify and analyze training, demographic, and psychographic trends and information and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, or other materials. We may also use such data for research purposes and optimizing the Services’ functionality.

How We Store and Secure Your Information

Personal information collected by Buddy may be stored and processed in your region, in the State of California (the “Applicable Location”), and in any other country where Buddy or its affiliates, subsidiaries, or service providers operate facilities. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

Buddy takes technological and organizational measures designed to protect your personal information against loss, theft, and unauthorized access, use, disclosure, or modification. For example:

• We transmit data over secured communication channels using SSL Login credentials;
• All personal information is stored by trusted third party providers (e.g., Amazon Web Services (AWS), Railway, Intercom, Twilio, and others);
• All systems used to provide the Services are password protected;
• All Services usage is restricted on a per-user basis on the principle of least privilege; and
• All data is encrypted during transfer and while at rest.

We rely on the security policies of AWS’ and other trusted third party providers to protect personal information while stored in their respective controlled facilities. 

Buddy complies with applicable data protection laws, including applicable security breach notification requirements.

Data Retention

Buddy will retain your information as long as necessary for the purposes outlined in this Privacy Policy, in a manner consistent with our data retention policy discussed in this section, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes or as permitted by applicable law. Buddy will retain your personal information consistent with the original purpose of collection or as long as necessary to comply with our legal obligations; maintain accurate accounting, financial and other operational records; resolve disputes; and enforce our agreements. We will never retain your information for a period longer than permitted by law.

We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed; the purpose for which it was collected; the potential risk of harm from unauthorized use or disclosure of the personal information; whether we can achieve the purposes of the processing through other means; and applicable legal requirements.

After expiration of the applicable retention periods, your personal information will be deleted. As discussed below, you may have the right to request we delete this information earlier.

Accessing and Updating Your Information

To the extent provided by the law of your jurisdiction, you may: 

• Have the right to access certain personal information we maintain about you and request details about how we process it; 
• Request certain information regarding our disclosure of personal information to third parties; 
• Request that we update or correct inaccuracies regarding your personal information; 
• Object to our use of your personal information; 
• Ask us to block or delete your personal information from our database; 
• Request to download the information you have shared on the Services; and 
• Confirm whether Buddy stores your data in the Applicable Location. 

You may make these requests and any other inquiries about this Privacy Policy by emailing privacy@tradebuddy.io. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the requested information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Additional Privacy Information

Data Transfer. Our databases are currently located in the Applicable Location. Buddy makes no claim that its Services are appropriate or lawful for use or access outside the Applicable Location. If you access the Services from outside the Applicable Location, you are consenting to the transfer of your personal information from your location to the Applicable Location. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By providing us your information, you further consent to its storage within the Applicable Location.

Collection of Data from Children. The Services are not directed to children, and you may not use the Services or provide any personal information to Buddy if you are under the age of 18 or if you are not old enough to consent to the processing of your personal information in your country. We do not collect or process personal information of individuals under the age of 18 unless we receive all necessary consents from the individual’s parent or guardian.

California Resident Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or contact us through the methods stated above.

Your Rights Under National Law

European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Switzerland, Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation or the Swiss Federal Act on Data Projection (“FADP”), (collectively, the “GDPR”), as applicable, with respect to your Personal Data. The following discusses these rights.

For this section, the GDPR definition of “Personal Data” and “processing” are used. Generally, “Personal Data” means information that can be used to individually identify a person, and “processing” relates to actions that can be performed in connection with collecting, using, storing, and disclosing such data. Buddy is the controller of your Personal Data processed in connection with the Services.

If a conflict exists between this this section and any other provision of this Privacy Policy, the more protective policy or portion shall govern to resolve such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@buddytech.io. 

We may also process Personal Data of our customers’ end users in connection with our provision of services to our customers. In this case, we are the processor of Personal Data. If you have any questions regarding Personal Data when Buddy is the data processor, please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect. The “Information We Collect from You” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds. The “How We Use Your Information” section above explains how we use your Personal Data. We will only process your Personal Data as explained in this Privacy Policy and if we have a lawful basis for doing so. The lawful bases include receiving your consent, having a contractual necessity, and furthering our legitimate interests or the legitimate interest of others. The following sections describe these in greater detail.

Consent

We process Personal Data based on the consent you expressly grant to us at the time we collect the data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Contractual Necessity

We may process the Personal Data as a matter of “contractual necessity”. This means that we need to process the data to perform under our agreement with you and enable us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services.

Legitimate Interest  

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties providing products or services in connection with the Services:

• Profile or Contact Data
• Commercial Data
• Device/IP Data
• Web Analytics
• Geolocation Data
• Professional or Employment-Related Data
• Financial and Payment Data
• Social Network Data
• Sensory Data
• Inferences Drawn from Other Personal Data Collected
• Other Identifying Information that You Choose to Provide
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We may also de-identify and anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above in the “How We Use Your Information” section):

• Providing, customizing, and improving the Services.
• Marketing the Services.
• Corresponding with you.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.
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Other Processing Grounds

Occasionally, we may also need to process Personal Data to comply with legal obligations, to protect the vital interests of you or other data subjects, or to carry out a task necessary for the public’s interest.

Sharing Personal Data. The “How We Share Your Information” section above details how we share your Personal Data with third parties.

EU and UK and Swiss Data Subject Rights

EU and UK and Swiss data subjects have certain rights with respect to Personal Data. This is further set forth below. For more information about these rights or to submit a request, please email us at privacy@buddytech.io. Please note that in some circumstances, Buddy may be unable to fully comply with your request, including if the request is frivolous, extremely impractical, jeopardizes other’s rights, or not required by law. In those circumstances, we will still notify you of such a decision. Generally, we may also need you to provide us additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include:

• Access: You can request information related to the Personal Data we store about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we store about you is incorrect or incomplete, you can request we supplement or correct such Personal Data.
• Erasure: You can request we erase part or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based upon your consent (as indicated at the time of collection of such data), you have the right to withdraw consent at any time. However, please note that if you change or withdraw consent, you may have to then provide express consent on a case-by-case basis if use or disclosure is necessary to enable you to use the Services.
• Portability: You can request for a copy of your Personal Data in a machine-readable format. You can also request we transmit the Personal Data to another controller to the extent such transmission is technically feasible.
• Objection: You can contact us to object to our further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes, by contacting us as described above.
• Restriction of Processing: You can request Buddy restrict further processing your Personal Data.
• Right to File Complaint: You have the right to submit a complaint about Buddy's practices with respect to your Personal Data to the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data. The “Data Transfer” information in the “Additional Privacy Information” section above details how and where we transfer your data. Most significantly, our databases are currently located in the Applicable Location, and you are consenting to Buddy transferring your Personal Data to the Applicable Location.