Last updated: February 17, 2020
collection, use and disclosure of Your information when You use the
Service and tells You about Your privacy rights and how the law
We use Your Personal data to provide and improve the Service. By
using the Service, You agree to the collection and use of information
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings
defined under the following conditions.
The following definitions shall have the same meaning regardless of
whether they appear in singular or in plural.
- You means the individual accessing or
using the Service, or the company, or other legal entity on behalf of
which such individual is accessing or using the Service, as
applicable.Under GDPR (General Data Protection Regulation), You can be
referred to as the Data Subject or as the User as you are the
individual using the Service.
- Company (referred to as either “the
Company”, “We”, “Us” or “Our” in this Agreement) refers to BluBracket,
Palo Alto CA.For the purpose of the GDPR, the Company is the Data
- Affiliate means an entity that controls,
is controlled by or is under common control with a party, where
“control” means ownership of 50% or more of the shares, equity
interest or other securities entitled to vote for election of
directors or other managing authority.
- Account means a unique account created for
You to access our Service or parts of our Service.
- Website refers to BluBracket, accessible from
refers to the Website.
- Country refers to: California, United States
- Service Provider means any natural or
legal person who processes the data on behalf of the Company. It
refers to third-party companies or individuals employed by the Company
to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the
Company in analyzing how the Service is used.For the purpose of the GDPR, Service Providers are
considered Data Processors.
- Third-party Social Media Service refers to
any website or any social network website through which a User can log
in or create an account to use the Service.
- Personal Data is any information that
relates to an identified or identifiable individual.For the purposes for GDPR, Personal Data means any
information relating to You such as a name, an identification number,
location data, online identifier or to one or more factors specific to
the physical, physiological, genetic, mental, economic, cultural or
For the purposes of the CCPA, Personal
Data means any information that identifies, relates to, describes or
is capable of being associated with, or could reasonably be linked,
directly or indirectly, with You.
- Cookies are small files that are placed on
Your computer, mobile device or any other device by a website,
containing the details of Your browsing history on that website among
its many uses.
- Usage Data refers to
data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the
duration of a page visit).
- Data Controller, for the purposes of the GDPR
(General Data Protection Regulation), refers to the Company as the
legal person which alone or jointly with others determines the
purposes and means of the processing of Personal Data.
- Business, for the purpose of the CCPA (California
Consumer Privacy Act), refers to the Company as the legal entity that
collects Consumers’ personal information and determines the purposes
and means of the processing of Consumers’ personal information, or on
behalf of which such information is collected and that alone, or
jointly with others, determines the purposes and means of the
processing of consumers’ personal information, that does business in
the State of California.
- Consumer, for the purpose of the CCPA
(California Consumer Privacy Act), means a natural person who is a
California resident. A resident, as defined in the law, includes (1)
every individual who is in the USA for other than a temporary or
transitory purpose, and (2) every individual who is domiciled in the
USA who is outside the USA for a temporary or transitory purpose.
- Sale, for the purpose of the CCPA (California
Consumer Privacy Act), means selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a
Consumer’s Personal information to another business or a third party
for monetary or other valuable consideration.
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain
personally identifiable information that can be used to contact or
identify You. Personally identifiable information may include, but is
not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet
Protocol address (e.g. IP address), browser type, browser version, the
pages of our Service that You visit, the time and date of Your visit,
the time spent on those pages, unique device identifiers and other
When You access the Service by or through a mobile device, We may
collect certain information automatically, including, but not limited
to, the type of mobile device You use, Your mobile device unique ID,
the IP address of Your mobile device, Your mobile operating system,
the type of mobile Internet browser You use, unique device identifiers
and other diagnostic data.
We may also collect information that Your browser sends whenever
You visit our Service or when You access the Service by or through a
Tracking Technologies and Cookies
activity on Our Service and store certain information. Tracking
technologies used are beacons, tags, and scripts to collect and track
information and to improve and analyze Our Service.
You can instruct Your browser to refuse all Cookies or to indicate
when a Cookie is being sent. However, if You do not accept Cookies,
You may not be able to use some parts of our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent
Cookies remain on your personal computer or mobile device when You go
offline, while Session Cookies are deleted as soon as You close your
We use both session and persistent Cookies for the purposes set out
- Necessary / Essential CookiesType: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with
services available through the Website and to enable You to use some
of its features. They help to authenticate users and prevent
fraudulent use of user accounts. Without these Cookies, the services
that You have asked for cannot be provided, and We only use these
Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance CookiesType: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted
- Functionality CookiesType: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You
make when You use the Website, such as remembering your login details
or language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter
your preferences every time You use the Website.
- Tracking and Performance CookiesType: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information
about traffic to the Website and how users use the Website. The
information gathered via these Cookies may directly or indirectly
identify you as an individual visitor. This is because the information
collected is typically linked to a pseudonymous identifier associated
with the device you use to access the Website. We may also use these
Cookies to test new advertisements, pages, features or new
functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices
regarding cookies, please visit our Cookies Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service,
including to monitor the usage of our Service.
- To manage Your Account: to manage Your
registration as a user of the Service. The Personal Data You provide
can give You access to different functionalities of the Service that
are available to You as a registered user.
- For the performance of a contract: the
development, compliance and undertaking of the purchase contract for
the products, items or services You have purchased or of any other
contract with Us through the Service.
- To contact You: To contact You by email,
telephone calls, SMS, or other equivalent forms of electronic
communication, such as a mobile application’s push notifications
regarding updates or informative communications related to the
functionalities, products or contracted services, including the
security updates, when necessary or reasonable for their
- To provide You with news, special offers and
general information about other goods, services and events which we
offer that are similar to those that you have already purchased or
enquired about unless You have opted not to receive such
- To manage Your requests: To attend and manage
Your requests to Us.
We may share your personal information in the following situations:
- With Service Providers: We may share Your
personal information with Service Providers to monitor and analyze the
use of our Service, to show advertisements to You to help support and
maintain Our Service, to contact You, to advertise on third party
websites to You after You visited our Service or for payment
- For Business transfers: We may share or
transfer Your personal information in connection with, or during
negotiations of, any merger, sale of Company assets, financing, or
acquisition of all or a portion of our business to another
- With Affiliates: We may share Your
information with Our affiliates, in which case we will require those
company and any other subsidiaries, joint venture partners or other
companies that We control or that are under common control with
- With Business partners: We may share Your
information with Our business partners to offer You certain products,
services or promotions.
- With other users: when You share personal
information or otherwise interact in the public areas with other
users, such information may be viewed by all users and may be publicly
distributed outside. If You interact with other users or register
through a Third-Party Social Media Service, Your contacts on the
Third-Party Social Media Service may see Your name, profile, pictures
and description of Your activity. Similarly, other users will be able
to view descriptions of Your activity, communicate with You and view
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is
retain and use Your Personal Data to the extent necessary to comply
with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes, and
enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis
purposes. Usage Data is generally retained for a shorter period of
time, except when this data is used to strengthen the security or to
improve the functionality of Our Service, or We are legally obligated
to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the
Company’s operating offices and in any other places where the parties
involved in the processing are located. It means that this information
may be transferred to — and maintained on — computers located outside
of Your state, province, country or other governmental jurisdiction
where the data protection laws may differ than those from Your
such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that
Your data is treated securely and in accordance with this Privacy
Policy and no transfer of Your Personal Data will take place to an
organization or a country unless there are adequate controls in place
including the security of Your data and other personal
Disclosure of Your Personal Data
If the Company is involved in a merger, acquisition or asset sale,
Your Personal Data may be transferred. We will provide notice before
Your Personal Data is transferred and becomes subject to a different
Under certain circumstances, the Company may be required to
disclose Your Personal Data if required to do so by law or in response
to valid requests by public authorities (e.g. a court or a government
Other legal requirements
The Company may disclose Your Personal Data in the good faith
belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember
that no method of transmission over the Internet, or method of
electronic storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot guarantee
its absolute security.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform
their tasks on Our behalf and are obligated not to disclose or use it
for any other purpose.
We may use third-party Service providers to monitor and analyze the
use of our Service.
- Google AnalyticsGoogle Analytics is a web analytics service offered by
Google that tracks and reports website traffic. Google uses the data
collected to track and monitor the use of our Service. This data is
shared with other Google services. Google may use the collected data
to contextualise and personalise the ads of its own advertising
You can opt-out of having made your activity on the Service
available to Google Analytics by installing the Google Analytics
opt-out browser add-on. The add-on prevents the Google Analytics
with Google Analytics about visits activity.
more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
We may use Your Personal Data to contact You with newsletters,
marketing or promotional materials and other information that may be
of interest to You. You may opt-out of receiving any, or all, of these
communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send
emails to You.
The Company uses remarketing services to advertise on third party
websites to You after You visited our Service. We and Our third-party
past visits to our Service.
- Google Ads (AdWords)Google Ads (AdWords) remarketing service is provided by
You can opt-out of Google Analytics for Display
Advertising and customise the Google Display Network ads by visiting
the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics
Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout
– for your web browser. Google Analytics Opt-out Browser Add-on
provides visitors with the ability to prevent their data from being
collected and used by Google Analytics.
For more information on the privacy practices of
Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for
processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of
Personal Data is necessary for the performance of an agreement with
You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data
is necessary for compliance with a legal obligation to which the
Company is subject.
- Vital interests: Processing Personal Data is
necessary in order to protect Your vital interests or of another
- Public interests: Processing Personal Data is
related to a task that is carried out in the public interest or in the
exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal
Data is necessary for the purposes of the legitimate interests pursued
by the Company.
In any case, the Company will gladly help to clarify the specific
legal basis that applies to the processing, and in particular whether
the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your
Personal Data and to guarantee You can exercise Your rights.
within the EU, to:
- Request access to Your Personal Data. The
right to access, update or delete the information We have on You.
Whenever made possible, you can access, update or request deletion of
Your Personal Data directly within Your account settings section. If
you are unable to perform these actions yourself, please contact Us to
assist You. This also enables You to receive a copy of the Personal
Data We hold about You.
- Request correction of the Personal Data that We hold
about You. You have the right to to have any incomplete or
inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data.
This right exists where We are relying on a legitimate interest as the
legal basis for Our processing and there is something about Your
particular situation, which makes You want to object to our processing
of Your Personal Data on this ground. You also have the right to
object where We are processing Your Personal Data for direct marketing
- Request erasure of Your Personal Data. You
have the right to ask Us to delete or remove Personal Data when there
is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data.
We will provide to You, or to a third-party You have chosen, Your
Personal Data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information
which You initially provided consent for Us to use or where We used
the information to perform a contract with You.
- Withdraw Your consent. You have the right to
withdraw Your consent on using your Personal Data. If You withdraw
Your consent, We may not be able to provide You with access to certain
specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation
and opposition by contacting Us. Please note that we may ask You to
verify Your identity before responding to such requests. If You make a
request, We will try our best to respond to You as soon as
You have the right to complain to a Data Protection Authority about
Our collection and use of Your Personal Data. For more information, if
You are in the European Economic Area (EEA), please contact Your local
data protection authority in the EEA.
Your Rights under the CCPA
California, You have the following rights:
- The right to notice. You must be properly
notified which categories of Personal Data are being collected and the
purposes for which the Personal Data is being used.
- The right to access / the right to request.
The CCPA permits You to request and obtain from the Company
information regarding the disclosure of Your Personal Data that has
been collected in the past 12 months by the Company or its
subsidiaries to a third-party for the third party’s direct marketing
- The right to say no to the sale of Personal
Data. You also have the right to ask the Company not to sell
Your Personal Data to third parties. You can submit such a request by
visiting our “Do Not Sell My Personal Information” section or web
- The right to know about Your Personal
Data. You have the right to request and obtain from the
Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or
selling the Personal Data
- Categories of third parties with whom We share
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also
have the right to request the deletion of Your Personal Data that have
been collected in the past 12 months.
- The right not to be discriminated against.
You have the right not to be discriminated against for exercising any
of Your Consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or
services, including the use of discounts or other benefits or imposing
- Providing a different level or quality of goods or
services to You
- Suggesting that You will receive a different price or
rate for goods or services or a different level or quality of goods or
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you
are a California resident, You can email or call us or visit our “Do
Not Sell My Personal Information” section or web page.
The Company will disclose and deliver the required information free
of charge within 45 days of receiving Your verifiable request. The
time period to provide the required information may be extended once
by an additional 45 days when reasonable necessary and with prior
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers
we partner with (for example, our advertising partners) may use
technology on the Service that “sells” personal information as defined
by the CCPA law.
If you wish to opt out of the use of your personal information for
interest-based advertising purposes and these potential sales as
defined under CCPA law, you may do so by following the instructions
Please note that any opt out is specific to the browser You use.
You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by
our Service Providers by following our instructions presented on the
- From Our “Cookie Consent” notice banner
- Or from Our “CCPA Opt-out” notice banner
- Or from Our “Do Not Sell My Personal Information” notice banner
- Or from Our “Do Not Sell My Personal Information” link
The opt out will place a cookie on Your computer that is unique to
the browser You use to opt out. If you change browsers or delete the
cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use
of information about the apps you use in order to serve you ads that
are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads
Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your
mobile device by changing the preferences on your mobile device.
Our Service does not address anyone under the age of 13. We do not
knowingly collect personally identifiable information from anyone
under the age of 13. If You are a parent or guardian and You are aware
that Your child has provided Us with Personal Data, please contact Us.
If We become aware that We have collected Personal Data from anyone
under the age of 13 without verification of parental consent, We take
steps to remove that information from Our servers.
We also may limit how We collect, use, and store some of the
information of Users between 13 and 18 years old. In some cases, this
means We will be unable to provide certain functionality of the
Service to these users.
If We need to rely on consent as a legal basis for processing Your
information and Your country requires consent from a parent, We may
require Your parent’s consent before We collect and use that
Links to Other Websites
Our Service may contain links to other websites that are not
operated by Us. If You click on a third party link, You will be
directed to that third party’s site. We strongly advise You to review
We have no control over and assume no responsibility for the
content, privacy policies or practices of any third party sites or
We will let You know via email and/or a prominent notice on Our
Service, prior to the change becoming effective and update the “Last
posted on this page.
- By email: email@example.com
- By visiting this page on our website: https://blubracket.com/