This is the Privacy and Cookies Policy for the website hosted at https://BotBroker.io/ ("we", "us" and "our site") and the BotBroker app "our App" (together, the "Platforms"). The Platforms are operated by or on behalf of Botbroker LLC. We are committed to protecting and respecting your privacy. This policy (together with our Terms and Conditions and any other documents referred to in it) sets out:
·Information we collect about you.
·Cookies and other technologies.
·How we use your information.
·Our promotional updates and communications.
·Who we give your information to.
·Where we store your information.
·Payment processing
·How we protect your information
·How long we keep your information.
·Your rights.
·Changes to this policy.
·Contact us
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By using the Platform you acknowledge you have read and understood this Privacy Policy.
For the purposes of European Economic Area data protection law, (the "Data Protection Law"), the data controller is: Botbroker LLC, 324 South Beverly Drive, Beverly Hills, CA 90212.
Information we collect about you
We will collect and process the following personal data from you:
Information you give us
This is information about you that you give us directly when you interact with us.
This is information about you that you give us by filling in forms on our Platforms or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Platforms, subscribe to our service, search for a product, place an order on the Platform, on or via our Platforms, enter a competition, promotion or survey, submit a query, and when you report a problem with our Platforms.
The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, login and password details.
Information we collect about you from your use of our Platforms: We will automatically collect information from you each time you visit our Platform. This includes:
·Technical information
·Information about your visit
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
Cookies and other technologies
Our Platforms use cookies to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content.
Our Platforms use cookies and similar technologies to distinguish you from other users of our Platforms. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platforms.
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen will tell you how to do this. We also give you information about disabling cookies. However, you may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Platform and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use
We use the following types of cookies:
·Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
·Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
·Functionality cookies. These are used to recognize you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
·Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our website/App and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We may also work with advertising networks that gather information about the content on our Platforms you visit and on information on other websites and services you visit. This may result in you seeing advertisements through our Platforms or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.com/uk.
Disabling cookies
The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Platforms. If you disable all cookies, you will be unable to complete a purchase on our Platforms.
If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below: -
For Microsoft Internet Explorer:
1.Choose the menu “tools�? then “Internet Options�?
2.Click on the “privacy�? tab
3.Select the setting the appropriate setting
For Google Chrome:
1.Choose Settings then Advanced
2.Under "Privacy and security," click “Content settings�?.
3.Click “Cookies�?
For Safari:
1.Choose Preferences then Privacy
2.Click on “Remove all Website Data�?
For Mozilla Firefox:
1.Choose the menu “tools�? then “Options�?
2.Click on the icon “privacy�?
3.Find the menu “cookie�? and select the relevant options
For Opera 6.0 and further:
1.Choose the menu Files then “Preferences�?
2.Privacy
Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site.
Except for essential cookies, all cookies used on our site will expire after twenty-four months.
How we use your information
You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed here. For a list of data processors we use, please email us at [email protected] for further information.
We use information held about you in the following ways:
Information you give to us:
We will use this information to:
Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
·administering your account with us;
·notifying you about changes to our service.
Provide you with information about our goods we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications'.
Ensure in our legitimate interests that:
·content from our Platforms is presented in the most effective manner for you and for your computer.
·we provide you with the information, products and services that you request from us.
Information we collect about you from your use of our Platforms
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
To administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
To keep our Platforms safe and secure.
For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
To improve our Platforms to ensure that content is presented in the most effective manner for you and for your computer.
To allow you to participate in interactive features of our service, when you choose to do so.
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products.
You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you.
Who we give your information to
We may give your information to:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
Selected third parties.
Our selected third parties may include:
Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy (this will not identify you as an individual).
Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.
Payment processing providers who provide secure payment processing services. Note your payment card details are not shared with us by the provider.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
If Botbroker LLC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Botbroker LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
Where we store your information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.
Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
We may transfer your personal information outside the EEA, to the United States:
In order to store it.
In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
Where we are legally required to do so.
In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and
we have concluded these are not overridden by your rights.
Payment processing
Payments made on the Platforms are made through our payment gateway provider, PayPal. You will be providing credit or debit card information directly to PayPal. which operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information which you supply to PayPal is not within our control and is subject to PayPal's own privacy policy and terms and conditions.
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS 1.3 (a strong protocol), X25519 (a strong key exchange), and AES_128_GCM (a strong cipher). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Your rights
You have the right under certain circumstances:
·to be provided with a copy of your personal data held by us;
·to request the rectification or erasure of your personal data held by us;
·to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
·to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section);
·to request that your provided personal data be moved to a third party.
Your right to withdraw consent:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us [email protected]. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section.
You can also exercise the rights listed above at any time by contacting us at [email protected].
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.html ). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Changes to this policy
Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on May 6, 2019.
Contact Us
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].
Purpose and lawful basis for processing of personal data
This table sets out:
·What personal data we process
·What we use that data for
·The lawful basis for the processing
It forms part of our privacy policy which you should also read.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a)Identity
(b)Contact
Performance of a contract with you
To process and deliver your order including:
(a)Manage payments, fees and charges
(b)Collect and recover money owed to us
(a)Identity
(b)Contact
(c)Financial
(d)Transaction
(e)Marketing and Communications
(a)Performance of a contract with you
(b)Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a)Notifying you about changes to our terms or privacy policy
(b)Asking you to leave a review or take a survey
(a)Identity
(b)Contact
(c)Profile
(d)Marketing and Communications
(a)Performance of a contract with you
(b)Necessary to comply with a legal obligation
(c)Necessary for our legitimate interests (to keep our records updated and to study how customers use our products)
To enable you to partake in a prize draw, competition or complete a survey
(a)Identity
(b)Contact
(c)Profile
(d)Usage
(e)Marketing and Communications
(a)Performance of a contract with you
(b)Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a)Identity
(b)Contact
(c)Technical
(a)Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b)Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a)Identity
(b)Contact
(c)Profile
(d)Usage
(e)Marketing and Communications
(f)Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a)Technical
(b)Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a)Identity
(b)Contact
(c)Technical
(d)Usage
(e)Profile
Necessary for our legitimate interests (to develop our products/services and grow our business).
