PRIVACY POLICY

Updated January 1, 2019

DUBL®, Inc. is committed to protecting and respecting your privacy. We understand that you care about the use and storage of your Personal Data to protect your privacy. This policy explains the information we might collect, use, share, and keep about you, and may change from time to time so please check back here frequently. If you disagree with this Privacy Policy, please discontinue using our Products, including our website (“Site”).

All terms of our Terms of Use and Software License are incorporated in this Privacy Policy as if fully set forth herein. All capitalized terminology in this Privacy Policy is defined in our Terms.

SCOPE OF POLICY.

This Privacy Policy applies to:

  • Visitors to our public Site(s), including but not limited to https://www.DUBL.app and any of our affiliates’ sites:
    • who request information by e-mail or telephone,
    • who provide User Content to us,
    • who purchase, license, access, or use our Products through us or our resellers, affiliates, or our Business Partners, or
    • who participate in any contest or survey, and
  • Users of any of our Products provided by us, our resellers, affiliates, or Business Partners, and
  • Users of any of our Products accessible through any of our downloadable or Internet-based programs or applications.

The legal definition of Personal Data varies by location. If you are located in the U.S., the legal definition in Colorado shall apply unless superseded by U.S. Federal law. If you are located outside the U.S., only the legal definition that applies in your physical location will apply to you under this Privacy Policy.

CONSENT.

You are never required to provide us with the types of information covered by this Privacy Policy. For individuals located outside of the European Union/European Economic Area, by accessing our Site and/or providing Personal Data to us, you do so voluntarily and are expressly opting-in and unambiguously consenting to the collection, use, retention, disclosure, and transfer, including cross-border transfer, of your Personal Data as explained in this Privacy Policy.

 

For individuals located within the European Union/European Economic Area, you will be asked to ‘opt in’ to this Privacy Policy and our collection, use, retention, disclosure, and transfer of Personal Data prior to accessing or using our Site.

NO USE BY MINORS.

We do not knowingly collect Personal Data from anyone under the age of majority in your location. Protecting children’s privacy is especially important to us. It is our policy to comply with the Children’s Online Privacy Protection Act (COPPA) and all other applicable laws. We do not sell Products through our Site and children under the age of majority are not eligible to provide us with Personal Data.

We ask that you carefully monitor your children’s activities on the Internet. We believe that there is no substitute for proper parental supervision. If you believe your child has provided us with Personal Data or has ordered a Product without permission, please contact us by email at legal@DUBL.app  and we will promptly delete such Personal Data and disable access to the associated account(s).

If we receive a submission to any contest or survey that is from a minor, the minor’s Personal Information will be deleted as soon as we learn that the submission comes from a minor and the contest or survey entry shall be void.

SHARING PERSONAL DATA/UNRELATED THIRD PARTIES.

We do not share Personal Data with unrelated third parties without providing you a choice. Personal Data that you provide to us while using our Products, including our Site, may be used to contact you for promotional offers, marketing programs, or other communications from us, our vendors, contractors, affiliates, licensors, licensees, (other than you), and Business Partners.

If you provide us with User Content or post any such User Content on our social media pages (e.g., https://www.Instagram/DUBL.app), including without limitation testimonials and videos, you are granting us the right and license to use that User Content for all commercial purposes. If you are accessing or using our Products as another’s employee, volunteer, or contractor, please be aware that your employer or contractor may have authorized us to use and/or share your Personal Data.

SHARING PERSONAL DATA/BUSINESS PARTNERS.

We ask our Business Partners who have access to your Personal Data in connection with providing services to us or to you to keep your Personal Data confidential and are not permitted to use this information for any other purpose than to carry out the services they are performing or to market products or services to you as long as you have the option to opt out of that communication.

When we make Personal Data available to our Business Partners, we will not share with them any more information than is necessary; and we will use reasonable efforts to ensure, by contract or otherwise, that they use your Personal Data in a manner that is consistent with this Privacy Policy.

INFORMATION WE MAY COLLECT FROM YOU.

We may collect and process the following types of Personal Data about you.

If you download marketing collateral or contact us for information about our Products, we collect and maintain Personal Data that may include your name, IP address, and contact information such as email address and/or telephone number. If you use, purchase, license, or lease our Products, respond to a survey or contest, or otherwise consent in advance, we will collect and maintain Personal Data that may include your name, mailing address, email address, social media user name, IP address, and telephone number.

We use your Personal Data to take necessary steps to respond to a request and/or to perform services requested. In addition, direct marketing is necessary for the legitimate business interests we are pursuing.

You may unsubscribe from emails at any time by clicking on the “unsubscribe” link in the emails you receive.

Your Personal Data is available to our employees, affiliates, and Business Partners with a legitimate business need, such as our marketing, order fulfillment team, operations team, survey processors, contest judges, customer relationship management software providers (CRM), and credit card processors.

We only collect Personal Data required for our legitimate business purposes. We do not request or require you to provide any special categories of Personal Data including, for example, genetic data, biometric data, or information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, or sexual orientation. If we become aware of any such data having been submitted to us, we will, where reasonably practicable, endeavor to delete it.

COOKIES.

A “Cookie” is a small amount of data generated by a website and saved by your web browser. Except for strictly necessary Cookies (defined below), at this time we do not use any other Cookies; and we do not allow third parties to use Cookies on our Site or in connection with our Products.

Should we decide to add Cookies or should a third party use Cookies in connection with our Site or Products, we will revise this Privacy Policy to include the types of Cookies utilized. In that event, when you visit our Site or access, use, lease, license, or purchase our Products, we may use the below types of Cookies. Outside the European Union or European Economic Area, use of our Site constitutes consent to our use of the Cookies detailed below. For Site visitors and/or customers located in the European Union, we will ask for your consent for Cookies except for Strictly Necessary Cookies, without which our Products and/or Site may not function. For more information on how Cookies function and disabling Cookies, consult your browser’s “Help” button.

    • Strictly Necessary Cookies. These Cookies are essential for our Site and our Products to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” for ecommerce functionality.
    • Session Cookies. Our Site may use session Cookies which your computer stores only for that browsing session, once you close your browser, the Cookie is deleted. These Cookies allow Users to navigate around our Site using your login details without having to login again on every page.
    • Analytics and Performance Cookies. Performance cookies collect information on how users interact with our Products and websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites and Products function and to understand how users interact with them.
    • Functionality Cookies. These Cookies are used to store preferences set by Users such as account name, language, and location.
    • Web Beacons and Parameter Tracking. These Cookies count Users who have visited our Site after clicking through from one of our advertisements on another website or in e-mails and to collect details of any Products purchased.
    • Targeting or Advertising Cookies. These Cookies are used to display relevant advertising to visitors who use our Products or visit our Site, as well as to understand and report on the efficacy of ads served on our Site or Products. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build User profiles, including showing you ads based on Products you’ve viewed or acts you have taken on our (and other) websites. These are set by us and trusted third-party networks, and are generally persistent in nature.
    • Google Analytics Tracking Cookies. This Cookie allows us to understand more about Site visitors, such as the number of visitors, details of the devices used to access our Products, which Site pages are accessed, and the various time details per visit.
    • Security Cookies. We use these cookies to help identify and prevent potential security risks.
    • Third Party Embedded Content. Our Site or Products make use of different third-party applications and services to enhance the experience of visitors and customers, including social media platforms or embedded content. As a result, Cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
    • EU Cookie Law Banner. This Cookie remembers visitor acceptance of our European Union (“EU”) Cookie Banner. The banner’s dismissal rule can be set to one of three options: when a visitor specifically clicks on the button, when a visitor scrolls down the page, or after a specific amount of time (as determined by you). If choosing to dismiss the banner after a specific amount of time, the minimum length is 3 seconds, and the maximum length is 1,000. Once the banner accepted/hidden, a technical Cookie named “eucookielaw” is set, which prevents it from being displayed until the acceptance/consent expires. If we use third-party ads, an additional technical Cookie named “personalized-ads-consent” will also be set, following the same expiration rule and allowing personalized ad content to be served to the accepting visitor. A visitor’s consent will expire after 180 days. On the next visit by that IP address or User, the Cookie Banner will reappear.

YOU MAY DISABLE COOKIES IN YOUR BROWSER SETTINGS. PLEASE KEEP IN MIND, DISABLING ALL COOKIES MAY IMPAIR PRODUCT FUNCTIONALITY.

SECURITY.

WHERE WE STORE YOUR PERSONAL DATA

We use servers in the United States to process and store Personal Data.

While no server can be completely secure, we make reasonable efforts to ensure that these servers are kept in a secure, locked environment with restricted access and we have on our own, and in conjunction with the third parties who operate the servers, established physical, electronic, and procedural safeguards to protect your information.

Personal Data stored by us may be accessed and processed by staff operating outside your jurisdiction, who work either for us or for one of our Business Partners. This staff may be engaged in fulfilling your order or request, processing a payment, and/or providing support services to us. We require these Business Partners to agree to treat your Personal Data securely and in accordance with this Privacy Policy and applicable law.

We have implemented a variety of technical and organizational measures to protect Personal Data from loss, misuse, unlawful processing, unauthorized access, disclosure, copying, alteration, and destruction. These include limiting access to the databases to a limited number of authorized staff, who are required to enter into non-disclosure agreements before access is afforded to them and who can only access the database for legitimate pre-authorized purposes. Further, access to the databases is password protected. We also have in place audit logs, intrusion detection software, anti-virus or malware protection, and system integrity tools to further protect data stored on these databases.

PASSWORDS

Where we have provided you (or where you have chosen) a password that enables you to access certain portions of our Products, you are responsible for keeping this password confidential. You are responsible in protecting your account by not sharing your password with anyone.

HACKERS

While we make reasonable and industry-standard efforts to ensure the integrity and security of our network and systems using the standard measures in place through our Site host, we cannot guarantee that such security measures will prevent third-party “hackers” from illegally obtaining this information.

We are not responsible for circumvention of any privacy settings or security measures contained in our Products, including the illegal acts of third parties (such as criminal hacking).

We disclaim any and all liability for disclosure of any information obtained due to errors in transmission or the unauthorized acts of third parties as more specifically detailed in our Disclaimers.  ANY TRANSMISSION IS AT YOUR OWN RISK.

THIRD-PARTY WEBSITES

Our Products may, from time to time, contain links to and from the websites of third parties. We only link to the home page of third-party content. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services. This includes any posting you may make on our social media page(s), which page(s) are controlled by such third-party social media sites.

We urge you to exercise care when providing information to anyone and to check the policies and terms of all third-party websites before you submit any Personal Data.

ADVERTISING.

We may use third-party advertising companies to serve ads when you visit our Site or use our Products. Such third-party companies may use information (not including your name, address, or e-mail address) about your visits to this and other websites to provide advertisements on sites, goods, and services that may be of interest to you. If you would like more information about this practice, and to know your choices about not having this information used by these companies, please review your rights at the Network Advertising Initiative.

SOCIAL MEDIA.

When you use features such as social networking, chat rooms, or forums, you should take precautions not to submit any Personal Data that you do not want to be seen, collected, or used by others. If you submit any Personal Data (that may be included in User Content) as part of a survey or contest, please consult our Terms for our rights to use that User Content.

Our Products include features from social media websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy, terms, and other policies of the companies providing those features.

RETENTION.

The amount of time we hold your Personal Data will vary but will not be kept for longer than is necessary for the purposes for which it is being processed. We will retain your Personal Data in accordance with the following criteria:

If you request information from us, we will retain your Personal Data solely for the legitimate business purpose of responding to your request or inquiry and will maintain that information to communicate with you regarding our other Products. You may opt out of such communications at any time and you will be provided with that opportunity to “unsubscribe” within each communication. If you request deletion of your Personal Data, we will pseudonymize or anonymize your Personal Data so that it cannot be connected to you.

If you have accessed, downloaded, purchased, licensed, or leased Products from us or have provided us with any User Content (for e.g., a testimonial or contest submission), we will retain your Personal Data for as long as we are distributing, selling, licensing, or leasing Products in order to provide you with information regarding those Products. You may opt out of such communications at any time and will be provided with that opportunity to “unsubscribe” within each communication. If you request deletion of your Personal Data, we will pseudonymize or anonymize your Personal Data so that it cannot be connected to you.

YOUR RIGHTS.

You have certain rights in relation to the Personal Data we process. These rights to access, correct, amend, or delete Personal Data vary by location and only the rights available to you in your physical location will be enforceable by you under this Privacy Policy.

Typically, you have the following rights:

  • The right to access your Personal Data unless access is subject to a legal exception.
  • The right to have your Personal Data corrected if it is inaccurate or incomplete.
  • The right to have your Personal Data not processed.
  • The right to have your Personal Data erased if it is no longer necessary or required in relation to the purposes and there are no other overriding legitimate grounds for us to continue processing it.
  • The right to opt out if your Personal Data is to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or you subsequently authorized.
  • The right to complain to a supervisory authority if you think your rights have been infringed.
  • You may also have the right to request that a business disclose the categories or details of Personal Data collected.

To exercise your rights, you may make an inquiry by sending an email request directly to the Data Compliance Officer at legal@DUBL.app. In some cases, you may need to discuss deletion with your employer if you access our Products through your employer.

We will respond to your request in accordance with the laws that apply to you. When you make your request, we will maintain your request and related Personal Data as we maintain other Personal Data in order to respond, after which time we will delete the Personal Data provided in the request.

Access requests are free; however, we reserve the right to charge a reasonable fee to comply with your request when your request is unfounded or excessive.

TRANSFER OF PERSONAL DATA OUTSIDE OF EUROPE.

In the case of individuals located in countries where the General Data Protection Regulation (“GDPR”) applies, to the extent we transfer Personal Data to our office, or our Business Partners’ offices, in the U.S., we make efforts to comply with the GDPR. To the extent we transfer Personal Data to Canada, for the purposes set out in this Privacy Policy, we rely on the fact that Canada has been designated by the European Commission as a country that offers an adequate level of protection for Personal Data.

If we transfer Personal Data relating to individuals located in the EU or the European Economic Area to third parties, we will have in place Data Transfer Agreements based on the EU model clauses. We will also provide reasonable technical and organizational measures to protect Personal Data from accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access.

CALIFORNIA USERS.

Under California’s “Shine the Light” law, and once per year, California, U.S. residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from the seller the customer information shared, if any, with other businesses for their own direct marketing uses.

If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information during the immediately prior calendar year. If you believe this law applies to you, please send an e-mail message to Data Compliance Officer at legal@DUBL.app with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response only if the law applies to you.

We will maintain your request and the customer information you provided in that request for ninety (90) days to ensure you do not have any follow-up questions. After that time, the information associated with your request will be deleted. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

COMPLAINTS.

If you have a complaint regarding this Privacy Policy or how your Personal Data is being maintained, used, or processed, you should first contact our Data Compliance Officer, whose contact details appear below:

Attention: Data Compliance Officer
legal@DUBL.app

If you are located in the European Union/European Economic area and are still concerned that we are not complying with our obligations under the General Data Protection Regulation (“GDPR”) or another applicable regulation or statute, and/or that we are not handling Personal Data responsibly and in line with good practice, you may raise a concern with the UK Information Commissioner’s Office (“ICO”). Concerns may be reported online at: https://ico.org.uk/concerns/handling/ or by calling 0303 123 1113.

CONTACT.

Questions, comments, notices, and requests regarding this Privacy Policy are welcomed and should be emailed to our Data Compliance Officer at legal@app. Please make sure that you identify the Site and/or Product through which you submitted Personal Data to enable us to identify your records. We will respond to your communications within thirty (30) days unless your request involves information that requires significant and/or unusual research.

CHANGES TO PRIVACY POLICY.

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or provided when you next start a downloaded application or access an online software application or when you access our Site. The new terms may be displayed on-screen and you may be required to read and accept them to continue your access, download, license, lease, and use of our Products.