IBBLE PRIVACY POLICY

Revised Date: July 2022

This Privacy Policy (“Policy”) describes how Ibble, Inc. (“ibble” or “we” or “our” or “us”) treat certain information collected or provided in connection with an end user’s (also “you” or “your” or “their” or “user”) use of our website www.getibble.com as well as any other website, page, or app owned by us (together, the “Site”) and all products and services provided by ibble in connection with the Site (“Services”). 

The Site is a social media platform that is content driven. Registered users may use the Site and Services to post content, music, videos, photographs, pictures, graphics, names, likeness, images, biographical information, and other information or materials owned and/or created by them and can view each other’s Accounts (described further below), communicate with each other, share photos, post comments, and describe their interests.

At ibble, we are committed to safeguarding your personal information and want you to know how we collect, use, and share and protect information about you and the choices you have regarding our use of your information in connection with the Site and Services. If you have any questions concerning this Privacy Policy, please email us at privacy@ibble.com

We may change or add to this Privacy Policy from time-to-time, so we encourage you to review it periodically. The most recent version of the Privacy Policy will be posted on our Site, with the “Revised Date” posted at the top of the Privacy Policy. If we make any material changes to our Privacy Policy or how we handle your personal information, you will know because the Revised Date of the Privacy Policy will change. If we make a significant or material change in the way we use your personal information, we may post a more prominent notice (including, for certain services, email notification of privacy policy changes where possible) in advance of any such change for thirty (30) days where feasible. Where permitted by law, users are bound by any minor changes to the Privacy Policy when they use the Site after those changes have been posted.

 

1. SCOPE

This Privacy Policy applies to the collection of personal information from users of the Site and Services, including any updated and new products or services that may be offered in the future by ibble. It relates to information we collect from you, including personal information / personally identifiable information (also referred to as “PII”) and information that does not identify you personally. PII may include, for example, some or all of the following: your name, mailing address, email address, telephone number, mobile phone number, passwords, credit/debit card information, username, and password. The information provided in this Policy is designed to inform you of what information we collect, why we collect such information, how we use the information we collect, and the choices we offer, including how to access and update information.

This Privacy Policy applies only to PII. It does not cover data we, or our authorized third-party vendors or partners, collect that cannot be used to identify an individual or to pseudonymous data. Nor does it include encoded or anonymized information or aggregated data which we collect or create about a group or category of services, users, or features that does not contain personally identifying information. We reserve the right to collect and share aggregate, encoded, or anonymized information with potential partners or other third parties without restriction.

 

2. YOUR CONSENT TO THIS PRIVACY POLICY

This Privacy Policy is incorporated into and subject to our Terms of Use Agreement (“Terms”) that applies to use of the Site and Services. Where permitted by law, by using the Services and this Site, you consent to our Terms of Use Agreement and this Privacy Policy, including our use and disclosure of your PII as stated in this Privacy Policy, whether or not you register with the Site. This Privacy Policy is not a contract and does not create any legal rights.

 

3. INFORMATION COLLECTED AND USED BY IBBLE

We may collect, use, share, store, or otherwise process your PII when you provide consent to do so, and/or as necessary to provide Services that are subject to terms you have accepted, such as our Terms of Use Agreement. If you choose to decline, not provide, or to adjust your privacy settings on your device to restrict the collection of these types of information, some features of the Site or Services may not function properly or be available to you. We may process your PII when necessary to comply with legal obligations, or for purposes of pursuing legitimate interests (such as providing Services, creating Accounts, improving the Site and Services, performing internal analytics, preventing fraud, enforcing legal claims, and for security purposes) if doing so is consistent with your rights and appropriate to the context.

Information You Provide to Us
We may collect the information that you directly provide to us, such as when you enter it via the Site or Services, or include it in communication that you send to us. This type of collection often occurs through our business support processes, and may include, but is not limited to, information such as:

  • Account Processes
    When users create an Account with the Site, ibble may collect user-submitted information such as name, country, zip/postal code, city and state, email address, telephone number, or password. Account information, including users’ pictures and names, may be displayed and publicly viewable to others in order to facilitate user interaction in the ibble social networking community.

We use your submitted PII to help prevent other users from accessing your Account, which includes using your PII to authenticate user sign-in attempts. This generally helps allow us to prevent individuals without access to your login credentials from logging in to your Account or otherwise using the Service as if you.

  • Purchase Processes
    Where we (or our third-party payment providers, defined further below) may ask you to provide your name, billing information including credit or debit card number, or permit you to log-in directly to your PayPal or similar financial service or account to process a purchase. In certain instances, we (or our third-party payment providers) may request your address.
  • Technical and Customer Support Processes; Notices
    We may ask you to provide PII and information related to the issue you are contacting us about. We may provide you with push notifications or notifications via SMS or email regarding your use of the Services. You may be able to adjust your notification settings within your user account options, or you can contact us directly for other options to adjust these settings.
  • Services Features and Delivery of Services
    We may collect the information that you provide by entering it into certain Service features. For example, when you want to submit content which we collect and then display for you via the Site or relevant Services as necessary. Materials you post or upload to the Site or Services, or interactions you make with the Site or Services, along with your profile picture and Account information (if you login using a social media provider or other online service) will be associated with your Account. This allows other users to view a username (and picture, if applicable) in connection with materials you post, and reciprocally, allow you to see the usernames of other users that post or upload materials to the Site or Services. You may be able to limit the audience for your submitted content by specifying the desired audience in the Service when sharing content or interacting with the Site or Services. ibble may also collect and process PII relating to your engagement with the Site or Services to help it provide you with information and options that may be of interest to you.

From time to time, we may also partner with a third party to sponsor an opportunity or promotion through the Site. Users may be asked to provide PII including name or email address or to answer questions to participate. ibble may transfer PII to certain third parties that you have requested to receive information from or to whom you directed us to share your information to avail yourself of the applicable opportunity.

We may also collect information via market research questionnaires you may respond to in order to gain a better understanding of our customers and thus provide more valuable service. This helps us to determine how best to provide useful information to customers and to understand which parts of our websites and Internet services are of most interest to them.

We may also collect, in instances where you have provided it, information about other individuals, including their email address and PII. If you are sharing information with us about any other individuals, you must obtain their consent.

  • Transactions with Third Party Payment Providers
    If you participate in a transaction through the Site, such as making a payment through the Site or setting up a recurring payment for any subscription services we may offer, one of our third-party payment providers may receive your payment information for purposes of processing such transaction and ibble will receive such payment after any applicable fees have been deducted in accordance with our agreement with such third-party payment providers. Our third-party payment providers may have their own privacy policy and those terms will apply to you, so please be sure to review them as they may be noted at time of payment. If you use another website to purchase our Services, you do so at your own risk, and you should carefully review the privacy policy and terms of any such websites.

Purchases generally require credit card information for processing. This includes name, credit card number, expiration date, billing and/or mailing address, and authentication codes or related information as needed to authorize the charge and complete the transaction. Credit card data transferred in connection with any third-party payment provider is via a Secured Sockets Layer (SSL) line if you are using a SSL enabled browser such as Firefox, Safari, or Google Chrome. We may also use SSL on other select pages where you enter PII. This ensures that your PII is encrypted as it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer. We do not receive or store complete credit card information, though when you place an order through the Site, our third-party payment providers may maintain your order information for its records unless and until you ask to delete this information.

  • Contacts
    If you authorize us to access your contact list, we may use that information to help you and your contacts discover each other on the Service, or to help you invite your contacts to join the Service. We may also collect and record certain information such as your unique device ID, hardware type, media access control (“MAC”) address, the version of your operating system, your location (based on your Internet Protocol (“IP”) address), a universally unique identifier generated by the App (“UUID”), and if you are using an Apple device, the unique identification for advertisers assigned to your device (“IDFA”). With your consent, we may use your IDFA and other identifiers to track your activity across other companies’ apps and websites to help us present you with more personalized ads and offer our Site and/or Services to you for free. This information is useful to us for troubleshooting and helps us understand usage trends and for providing you with the correct version of the Site.
  • Location
    With your consent, we may process your location data information to (a) make recommendations to you and show you relevant content, and (b) provide you the option to tag your location in posts so others can find it by the recommendation engine, search, or map view of that location. By sharing your precise location information for specific purposes, you will be able to tag your location in content you submit to the Site or via the Services, and we can provide you recommendations and context of things that are happening around you. Neither course nor precise location data is a requirement for using the Services. This data, if available, will only be used to enhance the end-user experience, and if you choose not to share your location information, you will still be able to use the Site, but certain features will be unavailable to you. If you share your location information, you can choose to stop sharing your location information at any time by adjusting the location settings of the Site in your device’s settings.

Automatic Information Collection
When you use the Site, we may automatically gather certain information from you about your use of our Services. This may include usage information, such as information on when, how often, and for how long you use the Site and the content you submit and view via the Services. This also may include server log data such as the IP address, time zone, operating system, some of the cookies installed on your device, or the webpage you were visiting before you came to our Site. As described below, we may collect this information through a number of means, including server logs, cookies, online tracking mechanisms, and in connection with third parties. We may associate such information with other PII we have about you. 

One such method of collection may be UXCam to anonymously study how users interact with the Service. UXCam may record screens visited, interaction patterns (such as screen actions, gestures: taps, scrolls) and device details (type, version, model, operating system). This information helps us identify user experience and compatibility issues, which supports our efforts to improve the Services. UXCam does not collect personally identifiable information and does not track your browsing habits across apps. More information about the information collected by UXCam is available at the following url: http://www.uxcam.com/privacy-policy.

Analytics
We may use certain third-party services to assist us in analysis, auditing, research, and reporting regarding the Site and Services. For instance, our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Site. We may use log data for troubleshooting purposes and to track which pages people visit in order to improve the Site. Third-party vendors may also collect aggregate log data independently from us.

We may associate data gathered from such services with any PII from any source. We use the collected usage statistics to better understand our customers, measure the performance of the Services, and measure the effectiveness of our marketing efforts. The vast majority of service usage statistics cannot be reasonably used to identify a particular individual or household. However, if any usage statistics can be used for such a purpose, we will only use the information for aggregate statistical purposes rather than observing the behavior of any particular user.

Some aspects of the Site or Services may also contain electronic images known as web beacons that allow us to count the number of users who have visited those pages. These web beacons collect only limited information such as a cookie number, time, and date of a page view, and a description of the page on which the web beacon resides. Such web beacons do not carry or collect any PII and you cannot opt-out or refuse them. However, where they operate with cookies, you can render them ineffective by opting out of cookies or changing the cookie settings in your browser.

Cookies and Other Technologies
We automatically receive and store certain types of information when you visit the Site or use the Services through the use of cookies, web beacons, or similar programs to collect the information described above. Cookies are strings of text that a website may store on your computer. Cookies enable the Site to keep track of your preferences and activities when you use or visit the Site. 

The Site creates session cookies for each visit in order to facilitate your visit. The session cookie expires at the end of the session.

We may also use persistent cookies, which remain on your device for much longer. Cookies do not corrupt or damage your computer or computer files. 

We use cookies for authentication, to remember your settings, to keep track of your activity during a visit to the Site, to conduct usability tests, to improve Site performance, and to implement certain features of the Site. 

We use analytics and customization cookies, including third party cookies, to gather information on how our Site and Services are being used by our visitors and to measure how popular our marketing campaigns are. We use the data we get to help customize our Site, products, and Services for you and make the content you see as relevant as possible. We may also use the data we collect to help identify and prevent fraud, and to track visits from our affiliates or partners.

Social networking cookies allow visitors to share our pages and content through third-party social networking websites. 

Targeting/advertising cookies help us to customize and regulate (e.g., by capping the frequency of) the advertisements you receive, provide you with tailored offers, and measure the effectiveness of our advertising. For instance, if we target an ad campaign through an online advertising network, we might use cookies on our Site to estimate how many viewers of the ad later visited our Site – and therefore, how effective the ad campaign was. Or, we might “retarget” visitors to our Site by providing them offers (whether through online display media, email or direct mail) similar to those they viewed or expressed interest in during their Site visits.

Automated Decision-Making Systems may be used in connection with the Site or Services to help with the flow or availability of information, including recommendations engines or moderation systems for removal of impermissible content. 

ibble uses cookies to store users’ preferences and to record session information, for purposes including: (A) ensuring that visitors are not repeatedly offered the same advertisements, to customize newsletter, advertising, and Site content based on browser type and user Account information; (B) to help track usage to help us understand which parts of our Site or Services are most popular, where our visitors are going, and how much time they spend there; (C) to make usage of our Site or Services even more rewarding as well as to study the effectiveness of our customer communications, and (D) to customize each visitor’s experience and provide greater convenience. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form.

Our business partners also use cookies for the same general purposes identified in this Privacy Policy, including to improve their own marketing, products, or services. Third party use of cookies is subject to their own privacy policies, not this Privacy Policy. Third parties use cookies and other technologies to collect information about your online activities over time and across different websites. Third parties we work with also use other “device-graphing” information in order to make inferences and connections about our customers and potential customers across various devices – such as mobile phones, tablets, and browsers. (These companies may, for instance, make inferences that devices seen at a common IP address are used by common users.) Companies that we share information with use the information we provide to them, often in combination with their existing information, to provide you with more relevant advertising. Please see the “Opt-Out / Do Not Track” section below for more information regarding personalized advertisements and your “Do not Track” options.

You may be able to control the use of cookies at the individual browser level. If you consent to the placement of cookies, you may later remove cookies as your browser permits. If you reject or remove cookies, you may still use aspects of our Site, but your ability to use some features or areas of our Site may be limited. For more information about the use of cookies and how to block them, visit www.allaboutcookies.org, www.youronlinechoices.eu (Europe) or www.aboutads.info/choices (United States).

Some of the aspects of the Site or Services may contain electronic images known as web beacons that allow us to count the number of users who have visited those pages. These collect only limited information such as a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These web beacons do not carry any PII and you cannot opt-out or refuse them. However, where they operate with cookies, you can render them ineffective by changing the cookie setting in your browser.

You may opt out of receiving personalized advertisements from advertising companies that are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting http://www.networkadvertising.org/choices and www.aboutads.info/choices

Information We Receive From Third Parties
We may also supplement the information that we collect with information that we obtain from digital ad network vendors, or SNSs (defined below), which you may choose to integrate with the Services. We may combine the information we receive from these third parties with the information we directly collect.

 

4. PURPOSES FOR WHICH PII IS COLLECTED

We process data collected and your PII to provide you with the Services you have requested or purchased from us. We use this information to refine our Site and Services to better tailor them to your needs and to communicate with you about other goods or services we offer. Most of the time, we need to process your PII to fulfill an order for Services. If you choose to decline, not provide, or to adjust your privacy settings on your device to restrict the collection of these types of information, some features of the Site or Services may not function properly or be available to you. Sometimes we have a legitimate interest in processing data to better understand the needs, concerns, and interests of our Site visitors and customers so we can operate optimally as a business. And sometimes, we rely upon your consent, in which case we will keep a record of it and honor your choices. As detailed below, we may use or disclose PII that we collect for one or more of the following business purposes and commercial purposes:

  • To respond to your inquiries and provide customer support.
  • To notify you regarding changes or updates to our Site, Services, or business.
  • To provide, support, personalize, tailor, and develop our Site or Services and your user experience.
  • To process entries to a competition or promotion. 
  • To audit our interactions with you, such as counting impressions or verifying the quality and effectiveness of content including ads.
  • To communicate with you by email, telephone, or mobile devices, about products or services that may be of interest to you either from us or from other third parties.
  • To update, safeguard, anonymize, aggregate, or enhance customer records. 
  • To prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
  • To maintain the safety, security, and integrity of our Site, Services, other technology assets, and our business, including the detection of security incidents.
  • To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our Site or Services.
  • To develop, improve, and deliver marketing and advertising.
  • To perform research and analysis about your use of, or interest in, our products, services, or content, including by the use of third-party analytics services.
  • For internal operational uses such as research, analytics, development, audits, and security.
  • To carry out obligations under any contract we have with you.
  • For the performance of our obligations or contractual arrangements with you or to take steps at your request before entering into contractual arrangements with you.
  • For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this Privacy Policy.
  • To enforce and enable our legal rights and the legal rights of our partners and users.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
  • To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development.
  • For our legitimate interests or those of a third party.
  • Where you have given consent. 
  • For any other purpose described to you when collecting your PII before or at the time of collection.

We may, and we may authorize third parties to, create aggregate records from PII by excluding information that makes the information identifiable. We may use and disclose, and authorize third parties to use and disclose, aggregate non-personal information at our discretion.

We may also combine the information you provide to us over time and we may combine such information with information that is publicly available, collected through cookies and other technologies, and information that we receive from our partners, third-party payment providers, and other third parties. We may use that combined information to better provide you our Services, and to better provide you personalized content, customized content, and advertising.

 

5. SHARING AND DISCLOSURE OF PII

We want you to understand when and with whom we may share PII we have collected about you or your activities on our Site. Generally, we may routinely share PII with: 

  • Our service providers and those with whom we’ve contracted in connection with our Site, products, and/or services, such as third-party payment providers, promotional partners, and website hosts, and various customer, tech, and operational support.
  • Third parties approved by you, including Social Sites you choose to link to your account or third-party payment providers.
  • Others if you choose to participate in a special event (for example, a promotion, contest, or sweepstakes), with those organizations participating in the applicable event.
  • Our insurers and brokers, including as necessary to monitor for potentially fraudulent or harmful activities. 
  • Others as we believe is necessary to comply with applicable laws, statutes, or regulations, and/or to enforce this Privacy Policy and the Terms and to protect our rights and the rights of others.
  • Our financial and legal institutions.
  • Others as required by a court or government agency or to respond to a claim by you or a third party.
  • Others as part of a transfer of our assets, for example in the event of a merger, acquisition, corporate change, or the unlikely event of a bankruptcy involving us.
  • Others as you may otherwise request or agree.

Data Sharing Services and Sources
We may use cooperative databases to identify potential subscribers and customers. We may also combine PII we collect with additional PII collected from other sources.

Advertising Technology Services
We may also engage third party online advertising technology service providers to help us deliver advertisements to you on websites you visit, including social media sites, after using the Site. This is a common practice known as “re-targeting.” For information about these practices, visit the Network Advertising Initiative website at Network Advertising – Understanding Online Advertising or the Digital Advertising Alliance website at AboutAds. You may remove yourself from targeted advertising of companies within the Network Advertising Initiative by opting out at Network Advertising – Choices, or of companies participating in the Digital Advertising Alliance program by opting out at AboutAds – Choices. You may request that we not share your PII with third parties for direct marketing purposes by contacting us at privacy@ibble.com.

Required Disclosures
ibble may disclose PII to any third party if it believes that disclosure is necessary: (A) to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by ibble, whether or not a response is required by applicable law; (B) to enforce the Terms of Use Agreement or to protect our rights; or (C) to protect the safety of members of the public and users of the Site and Services. We may use or disclose your PII where such disclosure is necessary for compliance with applicable law, including without limitation, lawful law enforcement requests and United States Treasury Department Office of Foreign Assets Control compliance. When we disclose and exchange information with law enforcement agencies and regulatory bodies, we do so to comply with our legal and regulatory obligations, to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

Third Party Policies
Third parties may also collect PII about your online activities over time and across different websites when you visit our Site. Any third parties to whom we may disclose PII may have their own privacy policies which describe how they use and disclose information generally. Those policies will govern use, handling, and disclosure of your PII once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.

Aggregate / Non-Personal
We may share aggregated and non-personal information we collect with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Site and the most popular features or services accessed. This information does not contain any PII and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising. We may also report aggregated, de-identified data relating to activity on the Site to third parties or the general public. We may combine such data with data obtained from third-party sources in order to generate such reports. We may also share it with third parties to develop and deliver targeted advertising on the Site and on websites of third parties. 

Business Transition
In the event of a merger, sale of capital stock or assets, reorganization, consolidation, or similar transaction involving ibble, including, without limitation, during the course of any due diligence process, the information we possess (including PII) shall be transferred as a corporate asset to the acquiring entity, provided that such entity will continue to handle such information in accordance with this Policy. We may disclose and exchange PII in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. We may also share PII or other information we have collected about you or your activities on our Site as you may request or otherwise agree.

Opt Out / Do Not Track
You can opt out of some uses of PII by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work

Like many websites, the Site does not currently respond to “do not track” browser headers or settings. However, there are various ways to opt out of interest-based advertising, such as TRUSTe’s Ad Choices, the Network Advertising Initiative’s Consumer Opt-Out Page, or you can also visit Google’s Ad Settings to manage the ads Google serves. 

Publicly Accessible Software Features
Certain elements of your PII and certain information about your use of our Services are publicly accessible via the provided Services. Please be aware that whenever you voluntarily post public information to the Site or via the Services, that information can be accessed by the public and can in turn be used by those people to send you unsolicited communications. We are not responsible for the PII you choose to submit and make publicly available on the Site or via the Services. Please think carefully before you post any PII online.

If you follow a link provided on the Site to a third-party website.
If you choose to “share” content or to otherwise post information from or via our Services to a third-party website, feature, or application, that information may become public and the third party web site may have access to information about you and your use of our Services. Likewise, other users may use these same features to share information about you. We are not responsible for how you use or publish personal data through these or similar features, or how third parties use the features to share information.

 

6. LEGAL BASES FOR PROCESSING PII

Our legal basis for collecting and using PII described above will depend on the PII concerned and the specific context in which we collect it. However, where we are processing your PII for our own purposes we normally rely on our legitimate interest to collect PII from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your PII, they include the interests in this Privacy Policy.

In some cases, we may rely on your consent or have a legal obligation to collect PII from you or may otherwise need the PII to protect your vital interests or those of another person. If we rely on consent to collect and/or process your PII, we will obtain such consent in compliance with applicable laws.

If you have questions about or need further information concerning the legal basis on which we collect and use your PII, please contact us using the contact details provided below.

 

7. USING SOCIAL FEATURES OF OUR SITE & SERVICES

The social features of our Site and Services promote and facilitate interaction among our Site users, including via separate social networking sites.

When you use any ibble Service, application, or feature at a site not controlled by ibble, such as a social networking site (“SNS”) like Facebook, YouTube, Instagram, Twitter, that site may allow ibble to access certain information about you, such as your IP address, which page you are visiting on the Site, and may also set a cookie to enable the feature to function properly. When integrating your SNS with ibble Sites or Services you may also be required to read and accept the SNS’s terms of service and privacy policy. By accessing the ibble Site or Services through a SNS, you are authorizing ibble to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the SNS could provide to ibble through the SNS.

If you choose (opt in) to use one of our social features, you may be asked to log into a SNS, such as Facebook, through our application. The SNS may provide ibble with your PII and content you have provided. We may link this data to your Account. When a SNS sends us the user IDs and names of your friends or contacts, we check to see which of your friends or contacts also have chosen to use the same social feature(s) you selected.

You may also be able to create an Account by logging in through a SNS. Integration with SNSs may allow you to automatically populate your Account that may be associated with our Site with information and content from your SNS account profile and to invite your SNS connections to join the Site. It also may allow us to better target our advertising within such SNSs (to the extent enabled by the applicable SNS). We will use, store, and disclose PII obtained in this manner in accordance with this Policy. 

The information you allow ibble to access varies by Service and SNS, and it is affected by the privacy settings you (and your social network/friends) establish at the SNS. When users elect to link to or embed SNS features or content to your Account we will utilize such SNS api services and you agree to be bound by the applicable SNS terms of service. You can find out more about these settings at the SNS where you access our Services.

You are never required to use our social features in order to use our Site or Services.

 

8. ACCOUNT

You may be able to choose not to provide us with certain information, but that may result in you being unable to use certain features of our Site or Services because such information may be required in order for you to register an account with us ("Account"); purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Site. 

Account owners may be able to log into their Account and view, amend, or delete their information. Please note that while changes or deletions to your Account or PII may be reflected promptly in active user databases, our servers or our associated third parties may retain previously provided information, and may be required to keep certain information and not delete it (or to keep information for a certain amount of time), in which case ibble will comply with your deletion request only after we have fulfilled such requirements. 

Also, changes to, or deletion of, any Account information does not affect any other information collected by ibble, which we may retain and continue to use or disclose in accordance with this Privacy Policy. If we have already provided your PII to a third party before you have changed your preferences or updated your Account or PII with us, you may have to change your preferences directly with that third party.

We reserve the right to verify the identity of any person making a request to opt-out or to delete or modify PII; provided, however, that we will have no liability of any kind resulting from false or erroneous requests or any change or deletion made by us for any reason. 

We store PII for only as long as reasonably necessary to fulfill the purposes described above, as we determine is necessary for business records, and as required under applicable law.

 

9. ACCOUNT DATA ON CLOSURE; RETENTION OF PII

Except as otherwise required by law, if your Account or the account associated with your Account is closed for any reason, you will no longer have access to data, messages, files, or other material or content you uploaded to the Site and any closure of your Account and any associated account may involve deletion of any content stored therein; ibble will have no liability whatsoever. 

We retain your PII for as long as we reasonably need it to fulfill the purposes described in this Privacy Policy, comply with our legal obligations and policies, resolve disputes, and enforce our agreements. ibble, in its sole discretion and as permitted or required by law, may retain some or all of your Account or profile information.

 

10. EMAIL CHOICE / OPT OUT

ibble may use PII, including email addresses, to send updates, a newsletter, or news regarding the Services. ibble may send email messages which use a “click-through URL” linked to content on the Site. When a user clicks one of these URLs, they may pass through and be monitored by our web server before arriving at the destination web page. 

All notification emails and communications also include instructions for opting out of those communications in the future. Note that users who have opted-out of promotional messages or updates may still receive email messages from ibble where necessary to provide a service you have requested or where necessary to inform you of critical information relating to your use of the Site.

Users who no longer wish to receive promotional messages or updates may choose to opt out. To opt-out, simply unsubscribe via the unsubscribe mechanism in the footer of the applicable email, or log-in to your user Account to manage your email preferences, and click the appropriate box to disable the notification emails you no longer wish to receive. 

Opt-out requests may not be able to be immediately processed, and we may also continue to send you other types of transactional and relationship email communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please also note that changing information in your Account or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us.

You may also contact us at privacy@ibble.com if you no longer wish to receive communications regarding the Site or our Services.

 

11. SECURITY

We have implemented reasonable measures designed to secure your PII from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, we use encryption technology to protect certain information, such as passwords. Please note that no method of electronic transmission or storage is 100% secure, however, and that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. ibble cannot guarantee the security of user Account or profile information or PII. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of member information at any time. To mitigate this risk, users are urged to also take precautions to protect their PII by changing passwords often using a combination of letters and numbers, carefully protecting passwords from disclosure, implementing updated internet security and virus protection on your device(s), using a secure web browser, and/or using a secure password manager service. 

Users should also be aware of how they handle and disclose their own PII and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.business.ftc.gov/privacy-and-security/consumer-privacy for information about how to protect yourself against identity theft. 

If you suspect that your device’s security or your information has been compromised or your password accessed or used by an unauthorized third party, immediately change your password and take other security steps as may be necessary or recommended in such circumstances.

If we become aware of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Site if a security breach occurs. We may also send an email to you at the email address you have provided to use in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. 

ibble may also integrate third party software that collects information about users for security reasons.

 

12. PRIVACY OF CHILDREN

We do not knowingly collect information from minors, and the Site and any Services we offer are intended for adults over the age of 18. Consistent with applicable law, we do not knowingly collect PII from minors under the age of thirteen (13) without the consent of their parents or guardians. If we learn that we have inadvertently obtained information in violation of applicable laws prohibiting collection of information from minors without such consent, upon proper notice, authority, and necessary confirmation of such, we will work to promptly delete it.

 

13. INTERNATIONAL DATA TRANSFERS

ibble is a website operated from the United States by a company headquartered in the United States. If you are located outside of the United States, please note that the information you provide to us may be transferred to the United States and governed by applicable U.S. laws and regulations and this Privacy Policy. The applicable laws in the United States regarding the processing of data (personal or otherwise) may be less stringent than the laws in your country.

When we transfer PII for any of the purposes identified in this Privacy Policy from the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland to another party located outside of the EEA, UK, or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which may include obtaining your consent for such data transfer, the standard contractual clauses adopted by the European Commission, or another framework deemed adequate by the European Commission. In cases where we transfer your PII pursuant to your consent, you may contact us by email at privacy@ibble.com to request that your consent be withdrawn. Please note that if you choose to decline, not provide, or to adjust your privacy settings on your device to restrict the collection of PII or other information, some features of the Site or Services may not function properly or be available to you.

 

14. ADDITIONAL PRIVACY RIGHTS AND OBLIGATIONS FOR INDIVIDUALS LOCATED IN THE EEA, UK, AND SWITZERLAND

This section sets out rights applicable only to PII of individuals located in the EEA, UK, or Switzerland, and our obligations regarding their PII.

If you are located in the EEA, UK, or Switzerland, then you may have the right to restrict or object to our processing of your PII. The right to restrict processing arises only in limited circumstances, for example, if you think we are processing inaccurate information. In addition, if we are required to restrict processing but the requirement is temporary, we may not be permanently obligated to adhere to your request. We will, however, let you know when the restriction is lifted. In cases where our basis for processing your information is the satisfaction of our legitimate interests (e.g., fraud prevention), you may object to our processing. However, we will decline your request if our interest in continuing to process your information is sufficiently compelling to legally override your interest in the request, or our processing is necessary to establish, exercise, or defend a legal claim. You also may prevent us from sending direct marketing at any time without limitation. To request a restriction or to object to processing, please submit your request by sending an email to privacy@ibble.com.

Individuals located in the EEA, UK, or Switzerland may also have the right to obtain their PII so they can transfer it to another party, or ask us to do so on their behalf, which we will do when technically feasible. This right is limited, and only arises when our processing of your information is automated and based on your consent or our terms and conditions. To exercise this right, please submit your request by sending an email to privacy@ibble.com.

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. A good explanation of the UK GDPR (in English) is available for example on the website of the United Kingdom’s Information Commissioner’s Office. If you are located in the EEA, UK, or Switzerland: you may have additional rights to request access to, correction of, erasure of, or the transfer of your PII, as well as the right to object to or restrict the processing of your PII. 

You may exercise these and other rights, if applicable, by contacting us as described in the Contacting the Site section of this Privacy Policy. We may request specific information from you to confirm your identity, and in some circumstances, we may charge a reasonable fee for access to your PII. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Any PII we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. 

ibble is headquartered in the United States. ibble has appointed an internal data protection officer for you to contact if you have any questions or concerns about ibble’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to ibble’s Data Protection Officer. ibble’s data protection officer’s name and contact information are as follows:

ibble, Inc.
Attn: Raymond Kaminski
200 East 6th St, Suite 208 
Austin, TX 78701
Phone: 512-766-8383

 

If you believe that our processing of your PII is inconsistent with your data protection rights under the GDPR or other relevant rules or requirements and we have not adequately addressed your concerns, you may have the right to lodge a complaint with the Data Protection Supervisory Authority of your country.

For purposes of the GDPR, we are a “controller” and you are a “data subject.”

 

15. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If applicable, this section of the Privacy Policy pertains only to consumers who reside in the State of California (“consumers” or “you”), and generally to the personal data of a particular consumer or household (“California Personal Information”). However, California Personal Information does not include, and this Privacy Policy does not apply to:

  • Publicly available information from government records;
  • Deidentified or aggregated consumer information; and
  • Other information excluded from the scope of California Consumer Privacy Act of 2018 (“CCPA”) and, as amended by, California Privacy Rights Act (“CPRA”).

This section of the Privacy Policy applies only to the extent we direct the purposes and means of California Personal Information processing and otherwise qualify as a “business” under the CCPA. It does not apply to information we collect, disclose, or otherwise process as a “service provider” under CCPA on behalf of our customers and business partners, or if the CCPA is not applicable.

California Personal Information We May Collect
We may collect personal information contained in the following categories of California Personal Information:

  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
  • Identifiers such as your real name, alias, postal address, zip code, telephone number, email address, account name, Social Security number, driver’s license number, payment card numbers, passport number, or other similar identifiers.
  • Unique and online identifiers such as device identifiers, internet protocol addresses, cookie identifiers, beacon identifiers, pixel tags, or mobile ad identifiers, or similar technology, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device.
  • Commercial information that identifies or could reasonably be linked to you, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information which identifies or could reasonably be linked to you, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
  • Geolocation information, such as your specific, real-time physical location or precise movements while you access our Site or Services if you have enabled location services on your device.

Sources of California Personal Information
We obtain the categories of California Personal Information that we collect as indicated above from the following categories of sources:

  • Directly from you, including when you provide information to us.
  • Indirectly from you, such as through logging and analytics tools, cookies, pixel tags, and other automatic data collection tools that we use on our website.
  • From third parties, such as our customers, service providers, other business partners, and third-party websites.

Purposes for which California Personal Information Is Collected
We may use or disclose the categories of California Personal Information listed above that we collect for one or more of the following business purposes and commercial purposes:

  • To respond to your inquiries and provide customer support.
  • To contact you regarding changes or updates to our service offerings.
  • To provide, support, personalize, and develop our websites, applications, and product or service offerings.
  • To audit our interactions with you, such as counting impressions or verifying the quality and effectiveness of content including ads.
  • To prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
  • To maintain the safety, security, and integrity of our websites, applications, other technology assets, and our business, including the detection of security incidents.
  • To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our websites and other applications.
  • To develop, improve, and deliver marketing and advertising.
  • For internal operational uses such as research, analytics, development, audits, and security.
  • For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this Privacy Policy.
  • To enforce and enable our legal rights and the legal rights of our partners and users.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
  • To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development.
  • For any other purpose described to you when collecting your California Personal Information before or at the time of collection.

Sharing California Personal Information
We may share your California Personal Information with the following categories of third parties:

  • Third-party partners sponsoring various opportunities to which you submit.
  • Our service providers.
  • Our affiliates and subsidiaries.
  • Other third parties to whom you or your agents direct us to disclose your California Personal Information, in which case your California Personal Information will be shared with that third party.
  • Other third parties to protect our legal rights or comply with legal requirements.
  • Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Other third parties involved in a merger, sale, joint venture, or other transaction involving a transfer of our business or assets.
  • Other third parties with your prior consent.

Disclosures of California Personal Information for a Business Purpose in the Preceding 12 Months

In the preceding 12 months, we may have disclosed California Personal Information for a business purpose as follows:

  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))— to our customers, third-party partners, our service providers, agents (including publishing administration and sync licensing agents), affiliates and subsidiaries, other third parties to whom you or your agents direct us to disclose your California Personal Information, and other third parties to protect our legal rights, to comply with legal requirements, as required by law, to carry out a merger, sale, joint venture, or other transaction involving a transfer of our business or assets, or with your prior consent.
  • Identifiers— to our customers, third-party partners, our service providers, agents (including publishing administration and sync licensing agents), affiliates and subsidiaries, other third parties to whom you or your agents direct us to disclose your California Personal Information, and other third parties to protect our legal rights, to comply with legal requirements, as required by law, to carry out a merger, sale, joint venture, or other transaction involving a transfer of our business or assets, or with your prior consent.
  • Unique and online identifiers— to our customers, our service providers, agents (including publishing administration and sync licensing agents), affiliates and subsidiaries, other third parties to whom you or your agents direct us to disclose your California Personal Information, and other third parties to protect our legal rights, to comply with legal requirements, as required by law, to carry out a merger, sale, joint venture, or other transaction involving a transfer of our business or assets, or with your prior consent.
  • Commercial information that identifies or could reasonably be linked to you— to our service providers, agents (including publishing administration and sync licensing agents), affiliates and subsidiaries, other third parties to whom you or your agents direct us to disclose your California Personal Information, and other third parties to protect our legal rights, to comply with legal requirements, as required by law, to carry out a merger, sale, joint venture, or other transaction involving a transfer of our business or assets, or with your prior consent.
  • Internet or other electronic network activity information identifies or could reasonably be linked to you— to our service providers, agents (including publishing administration and sync licensing agents), affiliates and subsidiaries, other third parties to whom you or your agents direct us to disclose your California Personal Information, and other third parties to protect our legal rights, to comply with legal requirements, as required by law, to carry out a merger, sale, joint venture, or other transaction involving a transfer of our business or assets, or with your prior consent.
  • Geolocation information— to our service providers, agents, affiliates, and subsidiaries, other third parties to whom you or your agents direct us to disclose your California Personal Information, and other third parties to protect our legal rights, to comply with legal requirements, as required by law, to carry out a merger, sale, joint venture, or other transaction involving a transfer of our business or assets, or with your prior consent.

Any third parties to whom we may disclose California Personal Information may have their own privacy policies that describe how they use and disclose such information. Those policies will govern use, handling, and disclosure of such information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

Sales of California Personal Information
We do not sell your Personal Information to any third parties. We do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age.

How to Exercise California Privacy Rights
The CCPA provides consumers with specific rights regarding their California Personal Information. As applicable, this section describes those rights and explains how to exercise those rights.

  • Access to Specific Information and Data Portability Rights. You may have the right to request that we disclose certain information to you about our collection, use, and disclosure of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the Exercising Access, Data Portability, Correction, and Deletion Rights section below, as applicable, we will disclose one or all of the following depending on the scope of the request:
    • The categories of California Personal Information we collected about you.
    • The categories of sources for the California Personal Information we collected about you.
    • Our business or commercial purpose for collecting California Personal Information about you.
    • The categories of third parties with whom we shared your California Personal Information.
    • The specific pieces of California Personal Information we collected about you.
    • If we disclosed your California Personal Information for a business purpose, a list of the disclosures for a business purpose identifying the categories of California Personal Information disclosed.
  • Correction and Deletion Request Rights. You may have the right to request that we correct or delete your California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the Exercising Access, Data Portability, Correction, and Deletion Rights section below, as applicable, we will correct or delete your California Personal Information from our records, unless an exception applies.
  • Exercising Access, Data Portability, Correction, and Deletion Rights. To make a request to exercise the applicable access, data portability, correction of inaccurate personal information, and deletion rights described above, please submit a verifiable consumer request to us by either:

You may designate an authorized agent to submit requests on your behalf through a valid power of attorney in certain circumstances or through signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when requests are submitted through an authorized agent, such as, requiring the submission of signed written permission for the agent to act on your behalf, requiring you to verify your identity directly with us, and/or otherwise requiring you to confirm the authorized agent’s permission to act on your behalf directly. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized representative of that person. In order to verify your request, we may require you to originate your request from the primary email address associated with your ibble Account. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Making a verifiable consumer request does not require you to create an Account with us. However, if you have a password-protected account or Account with us we may consider requests made through that Account sufficiently verified when the request relates to California Personal Information associated with that specific account.

Any disclosures we are required to provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot or need not fulfill, or are permitted to decline, your request then we will alert you or your authorized representative. For relevant data portability requests, we will select a format to provide your California Personal Information that is readily usable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

  • Non-Discrimination. You have a right to not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above. Except to the extent permitted by the CCPA or CPRA, we will not discriminate against you for exercising the access, data portability, and deletion rights described above.

California’s Shine the Light Law
California’s “Shine the Light” law (Civil Code Section 1798.83) permits California residents who have an established business relationship with us to request certain information regarding our disclosures of their personal information (as defined by that law) during the preceding year, if any, to third parties for those parties’ own direct marketing purposes. If you are a California resident who has an established business relationship with us and wish to exercise your rights under that law, please send your written request by mail to:

ibble, Inc.
Attn: Raymond Kaminski
200 East 6th St, Suite 208 
Austin, TX 78701
Phone: 512-766-8383

 

Please include the full name and contact information for your ibble Account in your request and include the statement “Your California Privacy Rights” in the subject field of your correspondence. Please allow thirty (30) days for a response.

California - Do Not Track
Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser “Do Not Track” settings. At this time, no standard has been adopted by the World Wide Web Consortium (W3C) regarding such practices, and given current industry considerations, ibble does not generally respond to “do not track” signals and may collect PII about your online activities over time and across different web sites when you visit the Site, for example by using cookies on our Site. We will update our practices and Policy as these standards evolve. For more information about Do Not Track, please visit www.allaboutdnt.org.

 

16. NEVADA RESIDENTS

We do not “sell” personal information as defined under Nevada’s consumer privacy law (SB 220). As an added assurance to individuals who entrust their PII to us, they may sign up for a do not sell my information log that we maintain. To do so, please email us at privacy@ibble.com, and include the reference line “Nevada Do Not Sell”. We may contact you for additional information in order to process your request.

 

17. DISPUTES

Any disputes regarding this Privacy Policy are subject to our Terms of Use Agreement and will be governed by the laws of the State of Texas, applicable to agreements made and performed there.

 

18. CONTACTING IBBLE

If you have any questions about this Privacy Policy, or regarding the practices of or your dealings with our Site or Services, please contact us at: privacy@ibble.com. Physical inquiries can be sent to the following address:

ibble, Inc.
Attn: Raymond Kaminski
200 East 6th St, Suite 208 
Austin, TX 78701
Phone: 512-766-8383