PRIVACY POLICY AGREEMENT
Effective as of 8-Oct-23
Heart of Sentience, LLC (“HOS,” the “Data Controller” or the “Company”) and RAELBUL.COM (collectively, “RA EL BUL”, “we” or “us”) are committed to protecting the personal information (“personal information” or “information”) we collect from all individuals who use RAELBUL.COM (the “Site”), visit our online sites, or use our facilities and services. It’s part of our mission to keep your information accurate, confidential, secure and private. If you have any questions, visit the page entitled Contact.
This Privacy Policy Agreement (the “Agreement” or “Privacy Policy“) has been designed to ensure the users of the Site and our other sites, products and services, and those third parties engaged by, or contracting or affiliated with us, of our commitment to superior privacy standards. This Agreement applies to the Site, all HOS sites and services, and governs any and all data collection and usage relating to those sites and services. All of the linked content, attachments, schedules and exhibits referred to in this Agreement are a part of this Agreement.
By using HOS’s sites and services, you (hereafter, “you” or “user”):
* acknowledge and agree that RA EL BUL’s collection, usage and disclosure of your personal information is governed by this Privacy Policy; and
* consent to RA EL BUL’s personal information collection and usage procedures and other policies, terms and conditions expressed within this Agreement.
Click on the following links to jump directly to the respective part of the Privacy Policy:
· What Information’s Collected
· Email and Newsletter Unsubscribe or Opt-Out
· Other Choices You Have Regarding Your Information
· Security
· Change of Ownership and/or Control
Other key sections of this Privacy Policy include:
¨ COOKIES AND SIMILAR TRACKING TECHNOLOGIES
¨ AFFILIATES AND THIRD PARTIES
¨ USAGE OF PERSONAL INFORMATION
¨ OTHER DATA PROTECTION RIGHTS
What Information’s Collected
The information RA EL BUL collects includes:
· Voluntarily provided information, which may include:
· general account and registration items such as your name, user name, address, telephone number, email address, and other account identifiers, some of which are compulsory (official identification, nickname, password, mobile phone contact number and email address);
· transaction, order fulfillment and experience information which may be used when you purchase products or services, and for delivery of requested products and services, such as general account and registration items, other official identification items (passport, driver’s license, etc.), Google account, gender, billing and/or credit card information, details about other financial instruments used in RA EL BUL transactions, amounts paid, sent and/or received, mobile or other device information, mobile or internet service provider, technical usage data and geolocation data;
· RA EL BUL may collect anonymous demographic information such as age, gender, household income, political affiliation, race and religion at a later time.
· Information automatically collected when you use App or use other Company sites or services, which may include:
· your phone number, mobile device identification number, e-mail address, and advertising identification technology information (such as ADID/IDFA) for providing customized mobile service, customer support, in-game advertising system and checking for duplicate memberships;
· information derived by plugins, cookies, server logs, and other tracking or similar technologies. See COOKIES AND SIMILAR TRACKING TECHNOLOGIES; and
· information to assist in providing and maintaining superior quality and service, including information about your mobile device, mobile service provider, browser, IP address, operating system, game play record, service use history, abusing or cheating action record, download history and payment history. See COLLECTED INFORMATION for more details.
· Information personally collected by RA EL BUL related to your use of App and other Company sites and services, which may include additional information from or about you when you communicate with RA EL BUL; and
· Other information as more fully described here: COLLECTED INFORMATION.
RA EL BUL only collects personal information consistent with the provisions of this Agreement.
RA EL BUL’s AFFILIATES AND THIRD PARTIES also collect various types of personal information about you, including the kinds of information collected by RA EL BUL and other information necessary for the use of COOKIES AND SIMILAR TRACKING TECHNOLOGIES and for other purposes described below.
Retaining Your Information
RA EL BUL retains personal information for its legitimate business purposes, including the fulfillment of your orders for products and services, and in order to comply with RA EL BUL’s legal and/or regulatory obligations. RA EL BUL may retain personal information for longer periods than required by law if it is in RA EL BUL’s legitimate business interests and not prohibited by law. If your account is closed, RA EL BUL may take steps to mask personal information, but RA EL BUL reserves its ability to retain and access the information for so long as required to comply with applicable laws. For so long as your information is held, RA EL BUL will continue to use and disclose it only in accordance with this Privacy Policy.
¨ In general, RA EL BUL will retain your personal information until your account is terminated by you or the RA EL BUL. Your personal information will be irreversibly discarded if you request its deletion or you do not use the service for certain period of time. The time periods vary with the reason for the personal information’s collection, and may vary with your place of residence, legal status or other application of law. See OTHER DATA PROTECTION RIGHTS.
How We Collect Information
We collect information on the Site and during calls or written communication with you. We also obtain information about you directly from you and from third parties. This includes information:
· You Provide Us—for instance, when you make an online purchase, visit or contact us, register an account, respond to a survey or questionnaire, sign up for a newsletter or consent to marketing, advertising or promotional efforts;
· From Our AFFILIATES AND THIRD PARTIES—which may include various service providers that we use, including marketers, advertising support services, analytics companies, demographic companies, and other third parties with which we collaborate or engage. The Affiliates and Third Parties may acquire information about you and your usage of their sites by means of various technologies such as plugins (including “Like” or “Send” buttons), cookies, and other tracking or similar technologies. While RA EL BUL selects or approves these third-party technologies which are placed on or otherwise interactive with the Site, the technical processes and interactions of those technologies are governed by the privacy policies, cookie statements and similar agreements or disclosures provided by the respective Affiliates and Third Parties;
· From Social Media Platforms and Networks that you use in connection with the Site or other Company sites or services, or that share or allow you to share information with us, such as Facebook, Instagram, Pinterest and Twitter. As an example, if you use widgets, tools, plugins or other functions or features from social media companies in connection with the Site or other Company sites or services (logging into an account or sharing product listings, for instance), we may collect the information that you share with us or that the social media sites share with us. For more information about social media platform and network privacy practices, please review the respective privacy policies, terms and conditions, and settings of the social media platforms and networks that you use;
· Automatic collection methods and tracking technologies. RA EL BUL, its AFFILIATES AND THE THIRD PARTIES may collect information from your computer, tablet, phone, or other device: that you use to access the Site or other Company sites or services; that you use to access your email; on which you install our mobile application (if and when available); or that your use to respond to an advertisement from us. This category of information typically doesn’t include personal information unless you choose to share it with us or provide it through our mobile application. More information about these methods and tracking technologies, including cookies, can be found here.
How Your Information’s Used
RA EL BUL does not now, nor will it in the future, sell, rent or lease any of its customer lists and/or names to any third parties. However, RA EL BUL may collect and may make use of personal information to assist in the operation of RA EL BUL and to ensure delivery of the services you need and request.
At times, RA EL BUL may find it useful to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from RA EL BUL or HOS. With your consent, RA EL BUL may contact you with regard to such products or services, or with regard to completing surveys and/or research questionnaires related to your opinion of current or potential future products or services that may be offered. Optional information items for such purposes include mobile phone contact number and email address.
Further, RA EL BUL may deem it useful to follow features and offerings on the Site which our users may frequent in an effort to glean what types of services and/or products may be the most popular to customers or the general public; such information collecting and tracking is done only with your consent.
Compulsory information for event and service marketing purposes includes—
For the delivery of goods or prizes and billing: full name, mobile phone contact number and address; and
For taxes and the public utilities’ charge(s) relating to event winners: official identification (passport, driver’s license, etc.), full name and address.
Optional advertising identification technology information, which may be used to check duplicate event participants and for in-game advertising systems generally, include the Identifier for Advertisers (IDFA) and the advertising industry standard unique identifier Ad-ID.
The Affiliates and Third Parties may collect and may make use of personal information for purposes similar to those for which RA EL BUL collects and uses information.
For more detailed information, see USAGE OF PERSONAL INFORMATION.
RA EL BUL, the Affiliates and Third Parties may disclose your personal information without prior notice to you only if:
(a) required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:
i. Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any process which may be served upon RA EL BUL, the Company, or the Affiliates and Third Parties;
ii. Maintain, safeguard and/or preserve all the rights and/or property of RA EL BUL, the Company, the Affiliates and Third Parties; or
iii. Take action under extraordinary circumstances in an effort to safeguard the personal safety of users of RA EL BUL, the Company, the Affiliates, the Third Parties and/or the general public; and/or
(b) otherwise in accordance with this Agreement. See USAGE OF PERSONAL INFORMATION.
OPTIONAL
Email and Newsletter Unsubscribe or Opt-Out
All users and visitors of the Site and Company sites and services have the option to discontinue receiving communication from RA EL BUL; you also reserve the right to discontinue receiving communications by way of email or newsletters. To discontinue or unsubscribe to RA EL BUL (or any of the Company sites or services) please send an email with UNSUBSCRIBE in the subject field to the email address provided in the HOW TO CONTACT US section. If you wish to unsubscribe from or opt-out of any Affiliate or Third Party website(s)s, you must go to that/those specific website(s) to unsubscribe and/or opt-out.
Other Choices You Have Regarding Your Information
The following are some additional principles and considerations about your options relating to personal information:
· You may decline to give your information when it’s requested, but some or all of RA EL BUL’s services may not be available to you.
· The hardware device you use to access the Site and Company sites and services may collect information about you, including geolocation information and usage data that RA EL BUL and the Affiliates and Third Parties may then collect and utilize. The settings options for your hardware device may allow you to restrict the collection and use of such information.
· RA EL BUL, the Affiliates and Third Parties may serve you personalized (“targeted”) advertising using ad-related cookies, pixels, SDK’s and/or web beacons. You may be able to opt-out of such tracking technologies to terminate such advertising; however, you may continue to see such advertising on Affiliate and Third Party websites. For more information on Affiliate and Third Party advertising-related cookies and targeted advertising, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit About Ads and Understanding Online Advertising. Additionally, you may opt-out of tracking and receiving targeted advertisements delivered to your mobile device and generated by some mobile advertising companies and other similar entities, by downloading the App Choices app or similar software.
· If you authorize an account connection to an Affiliate or Third Party account or platform, including social media accounts, you may be able to set and control your connection preferences from your account with RA EL BUL or the Affiliate or Third Party account or platform. For more information on your choices, see the Privacy Policy or similar notice that governs the Affiliate or Third Party platform. See also generally Affiliates and Third Parties.
· Most browsers and internet connective hardware allow you to manage your cookies preferences, including the abilities to delete, disable, or block certain cookies and other tracking technologies. For more information, visit allaboutcookies.org. If you delete, disable or block certain cookies, you may lose the ability to engage RA EL BUL, and the Affiliate and Third Parties’ sites as you wish and lose access to important features and functions.
· In some cases, you may have the option of enabling cookies and other tracking technologies when you visit or use certain of the Site’s features or the Company’s other sites or services. For instance, you may be asked if you want the service or site to “remember” certain of your information, and the Site or the Sites or services may then use cookies and other tracking technologies to the extent that you permit them.
· For more information about cookies, go here.
· If you have an account with RA EL BUL or its Affiliates, you generally may review and edit some or all of your personal information by logging in and updating the information directly or by contacting RA EL BUL or the Affiliate. You may also edit your information by contacting RA EL BUL by using the information provided in the HOW TO CONTACT US section.
· With your consent, RA EL BUL may send you marketing content about RA EL BUL’s services and sites, including services and products RA EL BUL jointly offers with the Affiliates and Third Parties by various means, including email newsletters. In most cases, you may opt-out of these communications by following the included instructions.
· RA EL BUL may send you communications that are required or necessary for users of the Company’s services and sites to have, and other communications that you may request from RA EL BUL. Opting-out of these communications is not possible; however, you may be to adjust the settings in the media, format and hardware through which you receive these notices.
For additional data protection rights, see OTHER DATA PROTECTION RIGHTS.
Security
RA EL BUL retains personal information at its own premises and elsewhere, in some cases with the assistance of Third Parties, including by means of cloud services and similar technologies. RA EL BUL endeavors to take every reasonable precaution to maintain adequate administrative, physical, procedural and technical security with respect to all personal information, including information held in RA EL BUL’s offices and information storage facilities and elsewhere, so as to prevent any loss, theft, misuse, unauthorized access, disclosure, destruction or modification of the personal information under its control.
The Company use encrypted network(s) to protect your personal information.
The Company restricts the number of staff members and other personnel who handle personal information. Such persons generally include the Company’s Marketing manager, Event manager, Support Team manager, Development Team director and the Company’s Chief Privacy Officer; however, the Company may allow other persons to handle personal information under certain circumstances and with appropriate safeguards.
The Company also provides regular personal information handling training to its employees in order to emphasize the importance of complying with this Privacy Policy. Where any handling of personal information is not aligned or inconsistent with the terms of this Privacy Policy, the Company will address and correct the mishandling promptly.
Where Third Parties and/or cloud services or similar technologies for storage and retrieval are involved, RA EL BUL requires such Third Parties to employ at least the same level of security that RA EL BUL uses to protect your personal data.
The Company encrypts your password, account information, e-mail and mobile phone information. If you wish to have all personal information about you deleted, the procedure for doing so is described below, in OTHER DATA PROTECTION RIGHTS.
For your security, we reserve the right to contact you to confirm and verify your request to correct or delete personal information, including the right to request additional information to confirm your identity and that you have the right to correct or delete personal information tied to a particular account. If we request additional information and it is not provided to us, we will not act on the request to correct or delete personal information. Users in certain jurisdictions may have additional rights and obligations in connection with verification matters, as described below in OTHER DATA PROTECTION RIGHTS.
The Company has installed security programming and regular backups and upgrades. The Company regularly inspects its security, backup and upgrading measures.
However, the nature of the internet, and digital information and communications technologies in general, does not make absolute security possible; consequently, RA EL BUL does not guarantee absolute security of the transmission, reception or storage of your information. The Company cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We strongly recommend that you take steps to maximize the security of your personal information, such as not sharing your login information and logging out of your account after you are done using the Site or other Company sites or services.
All users should be aware that, when they disclose personal information to others through or using RA EL BUL in an expressly public manner, the disclosed personal information may be made publicly available and may be collected and used by others outside of the control of the Company. Such public disclosure of personal information is done at the user’s own risk; the Company is not responsible for protecting the personal information that users choose to communicate publicly or to other users who use RA EL BUL, or for the actions of other users who receive or act upon the disclosed personal information.
By submitting your personal information, you agree to the above transfer, storing and processing.
Payments and Shipping
RA EL BUL and some of its Affiliates and Third Parties encrypt payment information and certain other information, including credit card, bank account and similar items using secure socket layer technology (“SSL”). While RA EL BUL, the Affiliates and Third Parties are very careful in their use of such information, no transmission of electronic data via the internet or other digital service is absolutely secure and it is therefore not possible to guarantee the complete security of such information.
Transaction information from credit card users who purchase products or services from RA EL BUL may be received by Affiliates and Third Parties such as Amazon Pay, Apple Pay or PayPal. Such information generally includes credit or debit card number, bank account information, purchase amount, and date/time of purchase. If you choose a direct payment gateway to complete your purchase, the Affiliates and Third Parties may store your credit card data.
While conducting fraud monitoring, prevention and detection activities, the Affiliates and Third Parties may also receive information about you from their business partners, financial service providers, identity verification services, and publicly available sources (for example, name, address, phone number, country); such information may be essential for such Affiliates and Third Parties to confirm the purchaser identity and generally prevent fraud. Such fraud monitoring, detection and prevention measures may employ technology that assists them in evaluating the risk of an attempted transaction, which’s enabled on an the Site or other Company site or service that collects information from the prospective purchaser.
Amazon’s Privacy Policy can be found here.
Apple Pay’s Privacy Policy can be found here.
PayPal’s Privacy Policy can be found here.
Changes to this Agreement
RA EL BUL reserves the right to update and change the terms of this Agreement; the Company will post those changes to the Site so that users and visitors always have notice of and access to the type of information RA EL BUL collects, how it will be used, and under what circumstances, if any, RA EL BUL may disclose such information. Such postings will notify you of the reason for the changes, the effective date and the last updated version of the Privacy Policy; and such postings will be available on the Site for a minimum of seven (7) days from the effective date.
By continuing to use the Site and other Company’s sites and/or services where such changes are posted, you agree to the changes to the Agreement.
If at any point in time RA EL BUL or the Company decide to make use of any personally identifiable information on file in a manner substantially different from that which was stated when this information was initially collected, the affected user or users will be promptly notified by email. Users at that time will have the option as to whether or not to permit the use of their information in this separate manner.
Change of Ownership and/or Control
In the event that RA EL BUL is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal information as transferred to the new entity.
Acceptance of Terms
Through the use of the Site and the Company sites and services, you hereby accept the terms and conditions described in this Privacy Policy. If you are not in agreement with all these terms and conditions, then you should refrain from further use of RA EL BUL and the Company’s sites and services. In addition, your continued use of App and Company sites and services following the posting of any updates or changes to the terms and conditions of this Agreement means you’re in agreement with and accept such changes, except to the extent applicable law requires otherwise.
How to Contact Us
If you have any questions or concerns regarding this Agreement, contact the Company’s CHIEF PRIVACY OFFICER
- Name: Ifeymerael
- E-mail: bulldragon909@gmail.com
- STREET ADDRESS FOR HOS: 8206 Louisiana Blvd NE Suite A Albuquerque NM 87113 USA
For More Information
For More Information about your data privacy rights, you may also contact the following:
European Union
European Union Data Protection Board
Postal address: Rue Wiertz 60, B-1047 Brussels
Office address: Rue Montoyer 30, B-1000 Brussels
https://edpb.europa.eu/about-edpb/more-about-edpb/contact-us_en
United States of America, California
California Attorney General's Office
California Department of Justice
Attn: Public Inquiry Unit
P.O. Box 944255
Sacramento, CA 94244-2550
(800) 952-5225
https://oag.ca.gov/privacy/ccpa
COOKIES AND SIMILAR TRACKING TECHNOLOGIES
RA EL BUL and its Affiliates and Third Parties may use various technologies to collect and store information when you visit their sites or use RA EL BUL products or services, which may include using cookies and similar tracking technologies such as pixels, SDK’s and web beacons. By using the Site and other Company sites and services and/or purchasing products or services from RA EL BUL, you permit RA EL BUL and its Affiliates and Third Parties to collect and use your information from your activity on the devices you use in accordance with this Privacy Policy. Some of the technologies discussed in this Attachment are set by RA EL BUL; others are set by the Affiliates or Third Parties acting on RA EL BUL’s behalf or otherwise consistent with this Privacy Policy. RA EL BUL and its Affiliates and Third Parties may begin collecting information about you and/or your activity beginning immediately with your initial use of the Site and visiting of the Company’s other sites and services. The Affiliates and Third-Parties that RA EL BUL engages are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.
Cookies are small data files that are stored on your hardware’s device memory, such as your computer, smartphone or tablet, when you use the Site, visit a Company site or service, or view a message sent by RA EL BUL, or its Affiliates and Third Parties. Certain cookies will persist in your device memory only for the duration of your App or web session and terminate when you close your browser or exit the Site or other service; other cookies serve to identify you when you return to a site or service previously visited or otherwise access or use the services of RA EL BUL, or its Affiliates and Third parties, and thus have a longer life in your device memory. Cookies serve a variety of functions, including registration support and integrity, retention of account settings and user preferences, and evaluation and compilation of user activity statistics. For more information and to learn how to block or delete cookies used in the Services, please visit your web browser’s security and privacy notices and agreements. Also see COOKIES AND SIMILAR TRACKING TECHNOLOGIES.
Cookies and similar technologies may collect the following information from you:
i) Browser and device data, including: device type; IP address; browser type; operating system; screen resolution; operating system name, version and type; device manufacturer and model; language; plug-ins; add-ons; and the language version of the pages you visit;
ii) Usage data, including: the time you spend on the Sites; the pages you visit; the links you clicked; your language preferences; and the pages that led or referred you to the respective sites;
iii) Other information, including a history of your online activities on websites and connected devices across the Affiliates and Third Parties’ sites, devices, apps and other online features and services. RA EL BUL and its Affiliates and Third Parties may use Google Analytics on their sites for various kinds of analysis and for technical diagnostic issues.
RA EL BUL, the Affiliates and Third Parties also may utilize web beacons to collect information, and software development kits (“SDK’s”) to enrich applications with advanced functionalities, including advertising. Web beacons are electronic images that may be used in the provision of services and in emails sent to you by RA EL BUL, and the Affiliates and Third Parties. They are used to deliver cookies, track user site visits and app usage, analyze and interpret customer usage and marketing campaign effectiveness, and learn when an email has been opened and acted upon. SDK’s are sets of software development tools that enable the creation of applications for specific software packages, software frameworks, hardware platforms, computer systems, video game consoles, operating systems, or similar development platform.
Cookies, web beacons, pixels, SDK’s and similar technologies may be used for the following purposes:
· Collection of anonymous statistical information about user activity such as session length and location of access in order to assess user satisfaction, user needs and desires and generally improve the provision of products and services;
· Collection of data about your interaction with RA EL BUL, including for the purposes of improving RA EL BUL’s marketing, advertising and promotion, which may entail the forwarding of such information to the Affiliates and Third Parties;
· Facilitation of the collection of data by Affiliates and Third Parties about your interaction with sites and services other than those of RA EL BUL;
· Detecting unique visitors and identifying return visitors so that capacity and resources remain sufficient to meet the demand for products and services;
· Enabling the Affiliates and Third Parties to use these tracking technologies to measure performance, analyze your engagement, and track your behavior on RA EL BUL’s behalf on the Site and the Company’s other sites and services across various devices you may use;
· For recognition of your device and the customization of your online experience, and/or your use of services provided by RA EL BUL, the Affiliates and Third Parties, and other online content and advertising;
· Shopping cart operation on the Site and the Company’s other sites and services;
· Tracking your prior visits other internet sites;
· Serving you targeted ads from RA EL BUL, the Affiliates and Third parties, including Google, Facebook, Bing and other vendors;
· Risk mitigation, fraud prevention, and promotion of trust and safety on the Site, across the Company’s other sites and services, and in connection with the services of RA EL BUL and its Affiliates and Third Parties; and
· Design, enhancement and customization of the Site and the Company’s other sites and services, including promotional layout and substantive content.
Most commercially-sold web and mobile device browsers by default will accept cookies and similar technologies. However, users can generally change browser settings to prevent the automatic acceptance of cookies, and in many cases require a notification before a cookie is set. Many browsers enable users to block cookies on different types of browsers and mobile devices. However, understand that by blocking or deleting cookies used in the services of RA EL BUL, the Affiliates and Third Parties, the Site’s (or other Company sites’ or Services’) functionality and features, and the level and quality of service may be diminished.
DO NOT TRACK DISCLAIMER: Please note that while RA EL BUL strives to offer you choices when you use our website(s) and mobile application(s), RA EL BUL cannot promise that it, or its Affiliates and Third Parties, will alter their information collection and processing practices when a browser Do Not Track signal is detected.
RA EL BUL, the Company, and the Affiliates and Third Parties rely on your consent in their deployment and usage of plugins, cookies, and other tracking or similar technologies for advertising, marketing and promotions purposes.
Apple use of cookies and other tracking technologies is discussed in Apple’s Use of Cookies.
PayPal’s use of cookies and other tracking technologies is discussed in more detail in their Statement on Cookies and Tracking Technologies.
Google Analytics’ use of cookies and other tracking technologies is discussed in their Data privacy and security policy.
Facebook’s use of cookies and other tracking technologies is discussed on their Cookies and Other Storage page.
Twitter’s (X’s) use of cookies and other tracking technologies is discussed on their Cookies and Similar Technologies page.
Instagram’s use of cookies and other tracking technologies is discussed on their About Cookies page.
Pinterest’s use of cookies and other tracking technologies is discussed in their Cookies policy.
YouTube’s use of cookies and other tracking technologies is discussed on Google’s Cookies page.
COLLECTED INFORMATION
The personal information that RA EL BUL, and the Affiliates and Third Parties may collect includes:
(i) User-Provided information: as a user you may provide RA EL BUL personal information when you sign up, register, consult with the Company or agents, employees or staff of RA EL BUL, telephonically contact RA EL BUL, electronically and/or wirelessly contact the Company, including via fax, email or text/SMS services, integrate products or services provided by RA EL BUL with other websites or services (including online payment, e-commerce, online subscription, email and online marketing services), or communicate with RA EL BUL in any other way.
Prior to collecting your personal information RA EL BUL will indicate whether the personal information is necessary for the use of the Site or other Company sites or services, or for the provision of the products and services you request, or is entirely optional, as well as explain the consequences, if any, of your decision not to provide the personal information. Your act of providing the personal information means that you agree to its collection, use and disclosures by RA EL BUL as described in this Agreement and as may be necessary or useful for the provision of the services and products you request.
User-Provided personal information may include:
· registration information (information typical for creating a website or mobile App usage account, such as name, email address, username, password, location, and phone number);
· billing and communications information (generally this consists of credit card details, billing address and security identifiers/authenticators). RA EL BUL may also maintain a record of your billing transactions and purchases, and any related communications and responses for a reasonable period of time; and
· information provided for the provision of services or products (this will include any personal information you disclose or cause to be disclosed to RA EL BUL in order to receive services or products of a unique or customized character, which information will be collected, used and processed in accordance with your instructions and RA EL BUL’s customary practices for receiving and handling such information).
(ii) Automatically-Collected information: RA EL BUL, the Affiliates and Third Parties may automatically collect certain personal information about your device, usage of the Site and the Company’s other sites and services, and/or obtaining products or services from RA EL BUL. the Site and the Affiliate and Third Party sites and applications may use cookies and other tracking technologies to collect some of this information.
Automatically-collected information may include:
· device information—information about the device and applications you use to access the respective sites or purchase products or services, including your IP address, your operating system, your browser ID, and other information about your system and connection;
· log data—the web servers of RA EL BUL, the Affiliates and Third Parties may create log files that record data each time a device accesses those servers, which log files may contain data about the nature of each access, including originating IP addresses. RA EL BUL, the Affiliates and Third Parties may also access metadata and other information associated with files that you and/or other users upload; and
· product usage data—RA EL BUL, the Affiliates and Third Parties may collect usage data of users who interact with them, which may include dates and times of access and browsing activities, and may also collect information regarding the provision of products and services you request. This information enables RA EL BUL, the Affiliates and Third Parties to improve the Site content and the provision of products and services, and facilitates research and analysis pertaining to the services and products offered by RA EL BUL, the Affiliates and Third Parties.
iii) Third-Party Source Information: from time to time, RA EL BUL may obtain information about you from the Affiliates and Third Parties such as public databases, social media platforms, third-party data providers, RA EL BUL’s strategic allies and other persons or entities engaged by RA EL BUL as joint marketing partners. RA EL BUL takes measures to ensure that the Affiliates and Third Parties are legally or contractually permitted to disclose such information to RA EL BUL.
The Affiliates and Third Parties’ source information may include:
· demographic information (gender, age, education, lifestyle, etc.);
· device information (IP addresses, unique device identifiers, etc.);
· location (region, city, state, country, etc.); and
· online behavioral data (information about users’ usage of social media, page view information, search results, links, etc.).
Such source information may be used alone or in combination with other information to enhance the ability of RA EL BUL, the Affiliates and Third Parties to provide relevant marketing and content to users and to develop and provide such users with more relevant products, features, and services.
AFFILIATES AND THIRD PARTIES
Partners, Allies and Affiliates (“Affiliates”)
RA EL BUL engages, coordinates and is affiliated with various partners, allies and affiliates (“Affiliates”) who assist RA EL BUL in RA EL BUL’s operations, including the provision of products and services and in improving and marketing RA EL BUL’s products and services. The Affiliates may provide you products or services in connection with RA EL BUL’s operations and, with your consent, send marketing or promotional material to you. Also, RA EL BUL may work jointly with the Affiliates in providing you products or services and may share your information with the Affiliates for purposes of marketing or promotions. In cases where an Affiliate cooperates with RA EL BUL in providing you products or services, it may be necessary or useful for RA EL BUL to share information related to the transaction with the Affiliates as a means of facilitating the transactions relating to the products or services; in these cases, RA EL BUL either has a legitimate interest in sharing and processing the information or deems the use of the information to be necessary for the provision of the ordered products or services. With respect to marketing, promotions, advertising and the sharing of your information for such purposes, RA EL BUL and the Affiliates rely upon your consent, which you may withdraw at any time.
RA EL BUL uses great care in ensuring that the information such Affiliates receive is limited to that which is necessary for the Affiliates to perform the functions for which they have been engaged, and the Affiliates are legally bound not to use such information for other purposes. In some cases, the services provided by the Affiliates are essential for RA EL BUL to provide its customers the products and services they require, including payment processing, shipping, operations and security. Other efforts and undertakings of the Affiliates are not strictly necessary for the provision of RA EL BUL’s products and services but are valuable to RA EL BUL in its mission to improve its operations; in such cases, RA EL BUL has a legitimate interest in working with RA EL BUL Affiliates to facilitate and improve operations.
Third Parties in General
RA EL BUL sites may contain links to Affiliate, Third Party and other websites. “Third Parties” means individuals or legal entities or associations that that interact or interface with RA EL BUL sites and/or services and may include some or all of the Affiliates. This Privacy Policy applies only and solely to the information collected by RA EL BUL, except to the extent it expressly indicates otherwise. It does not apply to the practices of Affiliates and Third Parties not owned or controlled by RA EL BUL or individuals who are not agents or employees of RA EL BUL. Be aware that when you use certain features or click on certain links in or own the Site, or on the Company’s other sites or services, those features or links may direct you to sites or services not managed or controlled by RA EL BUL. Once you leave the Site or the Company’s other sites or services, or are redirected to an outside site or application, you’re no longer governed by this Privacy Policy or RA EL BUL’s Terms of Service.
RA EL BUL does not control the privacy, information or security policies of the Affiliates, the Third Parties, or third parties generally, who may have different practices with respect to the use and disclosure of information you provide them. RA EL BUL is not responsible for the privacy or security practices of the Affiliates and Third Parties, even those contained in the Site or linked to or on the Company’s other sites or services. RA EL BUL neither claims nor accepts responsibility for any practices or procedures of other such websites or services, to the fullest extent permitted by applicable law.
The Company encourages you to read the privacy policies, cookie statements and similar agreements or disclosures provided by the respective Affiliates and Third Parties and ask them questions before disclosing your personal information to them.
For the purposes of the EU General Data Protection Regulation, such Affiliates and Third Parties are independent controllers and/or processors of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with your usage of the Site or the Company’s other sites or services.
Examples of Third Parties engaged by the Company include:
· RA EL BUL uses Facebook, Twitter, Instagram and Pinterest to advertise and market RA EL BUL products and services and for other sites and services of the Company.
· Facebook: To learn more about how Facebook uses your data please visit their Data Policy or log on to your Facebook account and access your settings. To understand more about Facebook advertising go here.
· Twitter: To learn more about how Twitter uses your data please visit their Privacy Policy.
· Instagram: To learn more about how Instagram uses your data please visit their Privacy Policy.
· Pinterest: To learn more about how Pinterest uses your data please visit their Privacy Policy.
· PayPal: PayPal is an online payment processor. To learn more about how PayPal uses your data please visit their Privacy Policy.
· Amazon Pay: Amazon Pay is an online payment processor. To learn more about how Amazon Pay uses your data please visit the Amazon Payments Privacy Notice.
In cases where a Third Party cooperates with RA EL BUL in providing you products and services, it may be necessary or useful for RA EL BUL to share information related to the transaction with the Third Party as a means of facilitating the transactions relating to the products or services. In these cases, RA EL BUL either has a legitimate interest in sharing and processing the information or deems the use of the information to be necessary for the provision of the products or services. With respect to marketing, promotions, advertising and the sharing of your information for such purposes, RA EL BUL, the Affiliates and Third Parties rely upon your consent, which you may withdraw at any time.
The following is a non-exclusive list of RA EL BUL’s Affiliates and Third Parties:
APPLE.COM
FACEBOOK.COM
TWITTER.COM
INSTAGRAM.COM
PINTEREST.COM
YOUTUBE.COM
AMAZON.COM
PAYPAL.COM
GOOGLE.COM
USAGE OF PERSONAL INFORMATION
RA EL BUL and the Affiliates and Third Parties use your personal information only for the purpose(s) for which it’s requested or for other purposes as described in this Agreement. In addition to the purposes described under How Your Information’s Used, above, RA EL BUL may collect and use personal information for the following purposes:
· Billing and collecting money you owe to RA EL BUL (including the sending to you of emails, invoices, receipts, notices of delinquency, and requests for credit card or billing information). For secure credit card transaction processing, RA EL BUL uses Third Parties, who may collect billing information to process your orders and credit card payments;
· Sending you App, site or system alerts or notices (including notices or alerts regarding changes to RA EL BUL’s products and services, or planned App or site outages, and account, security or compliance notices pertaining to matters such as new features, version updates, releases, abuse warnings, and changes to this Privacy Policy);
· Customer support communications (including answering questions you may have about current or future products or services, past orders, etc.);
· Enforcement of compliance with RA EL BUL’s agreements and applicable law (including the development of protective tools and algorithms);
· Protection of the rights and safety of RA EL BUL’s users and third parties, generally (including the development of protective tools and algorithms);
· Compliance with law and other legal requirements (including court orders, valid discovery requests and subpoenas, and other appropriate legal matters and processes);
· Provision of information to RA EL BUL’s representatives and advisors (including accountants, consultants and attorneys for financial, accounting, legal, tax, security and other legitimate business reasons);
· Prosecution and defense in legal proceedings (including court, ADR, mediation, arbitration and similar proceedings);
· Response to lawful requests or demands by governmental authorities (including for national security or law enforcement purposes);
· Provision, support and improvement of RA EL BUL’s services and products (including the sharing of your information with Third Parties in order to facilitate and/or improve RA EL BUL’s provision of products and services to you, or to make certain products or services available to you);
· Provision of suggestions, advice or instructions to you pertaining to products or services you obtain from RA EL BUL or the Company and other matters pertaining to your usage of RA EL BUL;
· Data analytics usage (including the use of personal information such as user access, browsing data, purchase history, etc., in data analytics projects designed to assist RA EL BUL in providing and improving RA EL BUL services);
· Combining personal information with other personal information or with other collected information for the purpose of serving users of RA EL BUL (including the delivery of a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Privacy Policy); and
· Legitimate interests and business reasons, and other lawful purposes, in general.
In addition to the purposes described under How Your Information’s Used, above, the Affiliates and Third Parties may collect and use personal information for the following purposes:
· Site operation and provision of their services, which may include: payment sending, requesting, initiation, and/or account depositing; authenticating account access; communicating with you about your account, their sites and/or services; account creation and account connections with third-party accounts, sites or platforms; evaluating creditworthiness and other financial standing checks, reviewing applications and performing accuracy and verification checks/analyses;
· Provision of personalized services provided by their third party websites and online services, including: presenting a targeted display, feature or offer to you on their third party websites; and using cookies and other tracking technologies to provide such online services and/or work with their third parties (for example, internet advertising and analytics companies);
· Marketing and delivery of marketing materials related to their products and services, or the products and services of their affiliates and unaffiliated third parties engaged for business reasons;
· Simplifying users’ locating and connecting with others, including suggesting connections to others, and similar social functionality and features intended to simplify users’ interaction with the Sites and services;
· Provision of location-specific options, functionality or offers to users who choose to share their geolocation information, including the enhancement of site and services security and provision of location-based services, such as search results, advertising and other personalized content;
· Management of their operational needs, such as monitoring, analyzing, and improving their services and site performance and functionality;
· Risk management and protection of sites and services by means of user identity verification, and detection and prevention of fraud and abuse;
· Customization of their sites and services in order to better meet your needs, increase your satisfaction and appeal to your interests;
· Compliance with their contractual and legal obligations, and enforcement of their rights pertaining to their sites and services; and
· Customer service outreach, response and general performance.
Sharing Your information
Generally, RA EL BUL may share your personal information for the following purposes and reasons:
· With other members of RA EL BUL Company group, Affiliates and Third Parties for the provision of the products and services you request, risk management, fraud and abuse detection and prevention, and technical reasons to ensure RA EL BUL’s operations.
· With Third Parties whom RA EL BUL engages in connection with RA EL BUL’s operations, including shipping service providers, security services, payment processors, marketers acting on RA EL BUL’s behalf, and general operational and/or customer support.
RA EL BUL may share your personal information with Affiliates and Third Parties for RA EL BUL’s legitimate interests and business purposes or as permitted or required by law, including:
· When it’s necessary for RA EL BUL to comply with a law, legal process or regulations, or where we have a good faith belief that doing so is required to cooperate with regulators or law enforcement authorities;
· When RA EL BUL determines that the disclosure of your information is necessary or appropriate to prevent physical harm or financial loss or protect other vital personal interests, or in connection with an investigation of suspected or actual illegal activity;
· When RA EL BUL investigates its own legal rights and obligations pertaining to its services or operations, or otherwise finds such sharing is necessary to protect RA EL BUL’s property, operations and interests, or the property, operations and interests of the Affiliates and Third Parties;
· When RA EL BUL chooses to facilitate a sale or purchase of all or part of RA EL BUL’s business or operations, or in connection with any other form of merger, acquisition, combination, or other consolidation;
· For shipping and delivery of goods you have requested;
· For RA EL BUL’s risk assessment and management measures, fraud detection and prevention measures, including fraud that occurs at or involves the Affiliates or Third Parties;
· For RA EL BUL’s banking and financial matters; and
· For RA EL BUL’s audit, compliance, and corporate governance functions.
RA EL BUL may share your information with your consent or at your direction, including if you authorize an account connection with an Affiliate and Third Parties’ account or platform. When we ask for your consent, it is your choice whether to grant it or not, though certain features, offers or functionalities of the Site or the Company’s other sites or services may be impaired depending on your choice.
Further, RA EL BUL may provide aggregated statistical data to the Affiliates and Third Parties, including other businesses and members of the public, about how, when, and why users use the Site or engage the Company’s other sites and services. Such information will not personally identify you or make you identifiable or provide specific information about your use of the Site, or such sites or services.
RA EL BUL does not share your information with the Affiliates and Third Parties for their marketing, advertising or promotional purposes without your consent.
The Affiliates and Third Parties may share your personal information with the Affiliates and Third Parties, or other third parties, for legitimate business purposes or as permitted or required by law, including the following:
· Certain Affiliates and Third Parties work with a variety of other third parties and service providers to help provide RA EL BUL with the needed services and may share personal information with those third parties to support the provision of those services. Further, such Affiliates and Third Parties may share RA EL BUL customer information in the following circumstances:
· to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service agreements or other agreements, or as otherwise required by law;
· if RA EL BUL directs an Affiliate or Third Party to transfer the information (for example, if RA EL BUL enables a third party app that accesses customer personal information); and
· to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).
Personal information may also be shared by the Affiliates and Third Parties with a company that acquires their business(es), whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding.
OTHER DATA PROTECTION RIGHTS
RA EL BUL takes reasonable measures to ensure that collected information is reliable for its intended use, accurate, complete and not out of date. However, in addition to your other rights, you have the following data protection rights:
All Users
Users and their legal representatives can request to view, edit or discard their personal information at any time.
Users and their legal representatives can view, edit or discard their personal information by using the edit member information and delete account menu on the “SETTINGS” screen.
For users who request the deletion of their personal information, RA EL BUL company will proceed with the procedure set forth in Retaining Your Information, Longer Retention Periods, above.
To access, correct, update or request deletion of your personal information: utilize the edit member information and delete account menu on the “SETTINGS” screen.
In error correction instances, we will not use or provide the personal information until correction is completed. Also, if the false personal information is provided to the Affiliates and Third Parties the Company will immediately correct the information and notice them.
Each user can disapprove the automatic collection of his or her phone number, mobile device identification number, e-mail address, and ADID / IDFA. However, RA EL BUL will not function optimally, and all features may not be available.
California, USA Residents
Under the California Consumer Privacy Act (“CCPA”), you have the following rights:
Right to Know, In General
You have the right to request that RA EL BUL disclose to you the personal information we collect, use, or disclose, and a general right to know information about our data practices, including:
· a link to RA EL BUL’S Privacy Policy;
· the categories of consumer personal information RA EL BUL collects;
· the purposes for which the categories of personal information will be used; and
· a description of the general CCPA consumer rights, which include the following—
¨ the CCPA business disclosure obligations;
¨ your disclosure request right;
¨ your deletion right;
¨ the CCPA’s explicitly mandated disclosure items;
¨ the CCPA consumer rights regarding personal information that RA EL BUL sells or shares, and the specifically mandated disclosure items for the 12-month period preceding a request from you regarding your data privacy rights which RA EL BUL has verified (a “verified consumer request” or “VCR”);
¨ the CCPA consumer rights regarding non-discrimination in connection with the exercise of CCPA rights;
¨ the CCPA consumer notification rights regarding financial incentives for consumer information rights;
¨ the CCPA consumer’s do-not-sell my personal information right and the right to revoke it; and
¨ the CCPA consumer right to be free from financial incentive practices that are unjust, unreasonable, coercive, or usurious.
Right to Know, Preceding 12 Months
You have the right to know certain details about RA EL BUL’S data practices in the preceding 12 months. In particular, you have the right to request copies of the following from us:
• the categories of personal information RA EL BUL collected about you;
• the categories of sources from which the personal information was collected;
• the categories of personal information RA EL BUL disclosed for a business purpose or sold;
• the business or commercial purpose of RA EL BUL’S use of your personal information;
• the categories of third parties with whom RA EL BUL shared your personal information; and
• the specific pieces of personal information RA EL BUL collected about you.
In the past 12 months, RA EL BUL has collected the following categories of personal information enumerated in the CCPA:
• Identifiers, including name, postal address, email address, and online identifiers (such as IP address).
• Customer records, including phone number, billing address, and credit or debit card information.
• Commercial or transactions information, including records of products or services purchased, obtained, or considered.
• Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
• Geolocation data.
• Inferences drawn from the above information about your predicted characteristics and preferences.
Categories of Personal Information Disclosed for a Business Purpose
The personal information that RA EL BUL disclosed to the Affiliates and Third Parties for a business purpose in the twelve (12) months prior to the effective date of this Privacy Policy falls into the following categories established by the CCPA, depending on which features of the Site you used:
· identifiers such as your name, address, phone numbers, or IP address, for example, if we use an Affiliate or Third Party carrier to deliver a product or service to you;
· personal information, such as a credit card number, for example, if we use an Affiliate or Third Party payment processor;
· your age, gender, or other protected classifications, for example, if you choose to participate in a survey distributed by an Affiliate or Third Party survey provider;
· commercial information, such as the details of a product or service you purchased if an Affiliate or Third Party service provider is assisting to provide that product or service to you;
· internet or other electronic network activity information, such as if we use an Affiliate or Third Party service provider to help us gather crash reports for analyzing the proper functioning of the Site or other company Products, Services or sites;
· geolocation data; and
· audio or visual information, for example if an Affiliate or Third Party service provider reviews recordings of your interactions with our customer service personnel for quality assurance purposes.
Right to Delete
Users of the Site also have the right to request that we delete your personal information. In addition to the using the email address provided in HOW TO CONTACT US, you may also send regular mail to the street address listed there.
Right to Be Free from Discrimination for Exercise of CCPA Rights
The CCPA explicitly prohibits businesses from discriminating against consumers who exercise their rights under the law, including: denying goods or services, disparities in pricing and/or quality, or even suggesting pricing or quality may differ. RA EL BUL will not discriminate against you for exercising any of your CCPA rights.
No Sale of Personal Information
Under the CCPA, California residents have the right to avoid the sale of their personal information to others. RA EL BUL does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA includes the activities set out in this Privacy Policy, such as those disclosed in the USAGE OF PERSONAL INFORMATION section above, we will comply with applicable law as to such activity.
See also (above): Categories of Personal Information Disclosed for a Business Purpose; and AFFILIATES AND THIRD PARTIES for further details about the categories of parties with whom we share information.
Verification of Consumer Requests
The CCPA requires that businesses maintain a reasonable method for identity-verification of consumer requests to correct, know or delete. You can designate an authorized agent to submit requests on your behalf. However, RA EL BUL will require written proof of the agent’s permission to do so and verify your identity directly. If you or your agent send us such a request using the contact information provided in HOW TO CONTACT US, above, we will contact you for confirmation by email, using the email address you provided when you created your SUPERSTAR account.
Shine the Light
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To submit a request, contact us by using the contact information provided above under HOW TO CONTACT US and indicate you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
European Union Users
Further, individual users of RA EL BUL who are in the European Union (“EU”) have the following data protection rights:
· You can object to the processing of your personal information, ask to restrict processing of your personal information or request its portability. Users in the EU can exercise these rights by contacting us using the information provided in the HOW TO CONTACT US section, above.
· Similarly, if personal information is collected or processed on the basis of your consent, you may withdraw your consent at any time. Withdrawing your consent won’t affect the legality of any processing conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
· Finally, you have the right to complain to a data protection authority about the collection and use of personal information. For more information, please contact your local data protection authority.
RA EL BUL answers all requests from individuals choosing to inquire about or exercise their data protection rights in accordance with applicable data protection law, subject to such individuals’ verification of identity.