Last Modified: June 13, 2018.
- Our products and services are provided by Buckitdream, Inc., a Washington corporation (“Company”, “we”, “our” or “us”). We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website www.buckitdream.com or download any of our corresponding mobile applications and use our platform (our “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy also contains information about how you may access your personal information held by us, seek correction of this information and make complaints if you think we have breached any privacy laws and how we will deal with such complaints.
- Given that we operate across a number of different global jurisdictions, we are subject to a number of different privacy laws, including the General Data Protection Regulation (Regulation (EU)) 2016/679 (the "GDPR") which requires us to explain how we will collect, use, maintain, protect and disclose the personal information of individuals based within the European Union. The sections of this policy in which we set out this explanation will only apply to you if you are based in the European Union
- This policy applies to personal information we collect about you, including:
It does not apply to information collected by:
- Through your use of this Platform.
- In email, text, and other electronic messages between you and this Platform.
- Through our mobile applications which provide dedicated non-browser-based interaction between you and this Platform.
- When you interact with our advertising and applications on third-party websites and services which are linked to or accessible through this Platform.
- us through means other than directly or indirectly through the Platform as described above, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Platform.
- Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. This policy may change from time to time. Please visit this page if you wish to stay up to date, as we will post any changes here.
Children Under the Age of 13
- Our Platform is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Platform. We do not knowingly collect personal information from children under 13 years old. If you are under 13 years old, do not use or provide any information on this Platform, register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of this Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child younger than 13 years of age, please contact us at firstname.lastname@example.org.
Information We Collect About You and How We Collect It
- We collect several types of information from and about users of our Platform, including information:
We collect this information:
- by which you may be personally identified or are reasonably identifiable, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
- that is about you but individually does not identify you, such as the sites you visit, the links you click on and the items you purchase; and
- about your internet connection, the equipment and browser you use to access our Platform and usage details.
- Directly from you when you provide it to us.
- Automatically as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From social media and other sites which you link through your account.
- From third parties, for example, our business partners.
Information You Provide to Us
- The information we collect on or through our Platform may include:
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by any other visitors of the Platform.
- Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Platform.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Platform.
- Your search queries on the Platform.
Information We Collect Through Automatic Data Collection Technologies.
- As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not honor ‘do not track’ signals and do not track, plant cookies, or use targeted advertising when a Do Not Track (DNT) browser mechanism is in place.
- The information we collect automatically may include personal information. We may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize our Platform according to your individual interests;
- Speed up your searches; and
- Recognize you when you return to our Platform.
- The technologies we use for this automatic data collection may include, but are not limited to, the following:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
- We use information (including any personal information) that we collect about you or that you provide to us, for various purposes including:
- To present our Platform and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Platform or changes to any products or services we offer or provide though it.
- To improve the services we offer you including how to best reach or contact you, via various channels such as but not limited to email, SMS, mobile, app, phone, push notification.
- To allow you to participate in interactive features on our Platform.
- To conduct analytics in order to improve the Platform.
- To provide you with technical support and troubleshooting.
- In any other way we may describe when you provide the information.
- To send you information about the products or services we offer including information via email about promotions and other offers.
- For any other purpose with your consent.
- We may not be able to do these things without your personal information.
- If you are based within the European Union, please click here for information about the legal bases we rely on to process your personal information. If you are based within the European Union, in certain circumstances you have the right to object, and you can find out more about how and when to do this here.
- We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, you can contact us using the contact details below or opt out in any of the electronic communications that we send you. If you are based within the European Union, we need your consent for some aspects of our marketing activities. Please click here for more information about how we will conduct these marketing activities in a manner that complies with the GDPR.
- If you are based within the European Union and you are not happy about this, you have the right to opt-out of receiving marketing materials from us and can find out more about how to do so here.
- We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
- We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's business and assets, whether as a going concern or as part of bankruptcy,
- liquidation, or similar proceeding, in which personal information held by the Company about our Platform users is among the business and assets transferred.
- To third parties to market their products or services to you if you have not opted out of these disclosures (if you reside within the European Union, we will need your consent for some aspects of our marketing activities, please click here for more information).
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Platform, we will transmit the contents of that email and your email address to the recipients.
- For any other purpose disclosed by us when you provide the information.
- For any other purpose with your consent.
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
- We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by unsubscribing on any of the related electronic communications you receive from us. If you are based within the European Union, please click here for more information about how we will share your personal information for third-party advertising.
- Promotional Offers from the Company. If you do not wish to have your email address and contact information used by the Company to promote our products or services, you can opt-out by unsubscribing on any of the related electronic communications you receive from us.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by unsubscribing on any of the related electronic communications you receive from us.
- We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.
Accessing and Correcting Your Information
- You can review and change your personal information by logging into the Platform and visiting your account profile page. Subject to some exceptions allowed by law, you can also request access to and seek correction of any personal information that we hold about you at any time. To request access please contact us using the details provided below.
- You may elect to suspend your account through the account profile page. However, while suspension of your user account will render your account inaccessible and unsearchable by other users on Platform, account suspension does not necessarily result in a deletion of your account or information associated with your account. Furthermore, we may not accommodate a request to change information or to suspend an account if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
- If you are based within the European Union, please click here for more information about your rights in regards to data privacy under the GDPR.
- If you are based within the European Union, please click here for more information on our retention of your personal information.
- If you are located anywhere outside of the United States, please be aware that information we collect, including, personal information, will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.
- If you are based within the European Union, please click here for more information on how we will transfer your data internationally.
Your California Privacy Rights
- California Civil Code Section § 1798.83 permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
- We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Depending on the circumstances, these measures may include staff authentication, access controls, encryption, records management protocols and secure premises. Any payment transactions will be encrypted using industry standard encryption technologies. We store personal information in both physical and electronic form, sometimes with the assistance of third parties such as specialist data hosting providers.
- The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.
- Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
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EU Residents – Additional Privacy Information
Legal bases for processing personal information
- Where we process your personal information as a data controller (being the party who determines the purposes and means of processing personal information), we need to ensure that there is a legal basis to justify our processing of your personal information. There are a number of different ways that we are lawfully able to process your personal information. We have set these out below.
Where processing your personal information is in our legitimate interests
- Under the GDPR, we can process certain personal information where it "is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal information."
- We may process your personal information for the purposes of our legitimate interests to ensure that we provide a better, more relevant service to you, and to analyse log data/user statistics to ensure that the Platform runs smoothly.
- We do not think that any of our data processing activities prejudice individuals in any way. However, you do have the right to object to us processing your personal information on this basis. We have set out details regarding how you can go about doing this above.
Where you give us your consent to process your personal information
- Under the GDPR, we are also allowed to process certain personal information where you have specifically consented. In certain circumstances, we will seek to obtain your opt-in consent before we undertake certain processing activities with your personal information. In plain language, this means that:
- You have to give us your consent freely, without us putting you under any type of pressure;
- You have to know what you are consenting to – so we'll make sure we give you enough information;
- You should only be asked to consent to one processing activity at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and
- You need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion. you receive from us.
- We will obtain your opt-in consent prior to sharing your personal information with third party applications and carrying out certain marketing activities. As and when we introduce these particular processing activities, we will provide you with more information so that you can decide whether you want to opt-in.
- You have the right to withdraw your consent to these activities. You can do so at any time, and please click here for more information on how to do so.
For the purposes of our legal obligations
- We also have legal and regulatory obligations that we need to comply with. Under the GDPR, we are allowed to process your personal information where this is necessary for us to comply with a legal obligation to which we are subject.
- We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please click here.
- We may periodically send you information that we think you may find interesting. In particular, we may wish to use your data to:
- contact you about our offers, goods and services; and
- send you details about the goods and services of third parties which we think might be of interest to you.
- If you are based within the European Union, we need your consent for some aspects of marketing activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain further below).
- Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us and we are marketing other related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For other types of e-marketing (including when we send you details about goods and services offered by third parties), we are required to obtain your explicit consent.
- If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so here.
- If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so here.
Data Subject Rights
- If you are based within the European Union, you should be aware that the GDPR offers various protections and clarifies the rights of EU citizens and individuals in the European Union with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
- To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
- Right to object: this right enables you to object to us processing your personal information where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply. If your objection relates to us processing your personal information because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
- we can show that we have compelling legitimate grounds for processing which overrides your interests; or
- we are processing your data for the establishment, exercise or defence of a legal claim.
- Right to withdraw consent: Where we have obtained your consent to process your personal information for certain activities (for example, for our marketing arrangements), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
- Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
- Right to erasure: You have the right to request that we erase your personal information in certain circumstances. Normally, the information must meet one of the following criteria:
We would only be entitled to refuse to comply with your request for erasure for one of the following reasons:
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
- Right to restrict processing: You have the right to request that we restrict our processing of your personal information in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal information are:
If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.
- Where you dispute the accuracy of the personal information that we are processing about you. In this case, our processing of your personal information will be restricted for the period during which the accuracy of the data is verified;
- Where you object to our processing of your personal information for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal information;
- Where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- Where we have no further need to process your personal information but you require the data to establish, exercise, or defend legal claims.
- Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal information to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
- Right of data portability: If you wish, you have the right to transfer your personal information between data controllers. In effect, this means that you are able to transfer your Buckitdream account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal information that we process automatically (i.e. without any human intervention); (ii) personal information provided by you; and (iii) personal information that we process based on your consent or in order to fulfil a contract.
- Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. The supervisory authority in the United Kingdom is the Information Commissioner's Office at:Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (T: 0303 123 1113 M: firstname.lastname@example.org).
- We will not keep your personal information for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation).
- When it is no longer necessary to retain your data, we will delete any personal information that we hold about you from our systems.
- We want to make sure that your data are stored and transferred in a way which is secure. If you are based within the European Union, we will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
- by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal information by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
- by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal information from entities in the European Union to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
- transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
- where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a customer of ours); orwhere you have consented to the data transfer.
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