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buuteeq Inc. -

PRIVACY POLICY

Last Updated Date: July 18, 2014

This buuteeq Privacy Policy (the “Privacy Policy”) applies to the website located www.buuteeq.com and operated by and on behalf of buuteeq, Inc. (“buuteeq”, “us” or “we”). This Privacy Policy will also apply to any other websites or on-line or mobile launched or operated by or on behalf of buuteeq (together with buuteeq.com, collectively, the “Site”). Together with our Terms and Conditions of Website Use (“Terms”), this Privacy Policy is a legally binding agreement between our Users and Customers and us.

1. DEFINITIONS

Please note that, unless we define a term in this Privacy Policy, all capitalized words used in this Privacy Policy have the same meanings as in our Terms.

Affiliates” means any company we own or control or that is under common control or ownership with us or that controls or owns us including, without limitation, our parent companies and subsidiaries. Unless otherwise indicated below, an Affiliate is not considered a third-party under this Privacy Policy.

Personal Information” is defined as set forth in the Terms, namely, information that is capable of identifying, directly or indirectly, a natural individual.

Sensitive Information” means Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life

Using” and/or “Processing” information means any or all or a part of the following: using cookies on a computer, subjecting information we collect via the Sites to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

2. U.S.—E.U. SAFE HARBOR

buuteeq complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. buuteeq has certified that it adheres to the U.S.-E.U. and U.S.-Swiss Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view buuteeq’s certification information, please visit http://www.export.gov/safeharbor/.

3. TRUSTE PRIVACY SEAL

TRUSTe European Safe Harbor certification

buuteeq has been awarded TRUSTe's Privacy Seal signifying that this Privacy Policy and our practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your Personal Information. Please note: the TRUSTe program covers only information that is collected through our website at www.buuteeq.com. It does not cover information that may be collected through mobile applications, devices or any third party sites or Affiliates.

TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our Privacy Policy or practices, please contact us at help@buuteeq.com. If you are not satisfied with our response you can contact TRUSTe here.

4. INFORMATION COLLECTION

  1. Personal Information Provided by You. In the course of your use of the Site and the Services, we may ask you for Personal Information, which may include:

    - Contact information such as name, email address, mailing address, and phone number; and

    - Billing information, such as bank account or payment card information;

    Please Note: We will never intentionally collect Sensitive Information from you; however, if we do so, we will treat it as Personal Information in accordance with this Privacy Policy. In addition, we will never automatically collect Personal Information from you; rather, you always have a choice about whether you provide it via your use of the Site or the Services. However, the Services (or certain components of them) may not be available if you choose not to provide us with the requested Personal Information.

  2. Personal Information Provided by Others.

    i. By Customers for Additional Authorized Users. Customers who use the Services may submit the Personal Information of other individuals at their organization to register them as authorized users of the Account. We will treat this as we treat all Personal Information; however, it is your/the Customer’s obligation to inform your or its authorized users about the purposes for which Personal Information about them is collected and that such Personal Information may be used on the Site and in connection with providing the Services. Authorized users can update or remove their Account information at any time by logging into the Site and editing their Account information or by contacting their Account administrator.

    ii. Referrals. We provide a referral mechanism for Customers through which they can send us information about other individuals or companies that may be interested in buuteeq. The uses described below notwithstanding, we will contact these referrals one time only using the information provided to us. buuteeq stores this information (including Personal Information) for the sole purpose of contacting the referral and tracking the success of our referral program. Referrals may contact us using the information below to request that we remove this information from our database. Please note that it is the referring Customer’s responsibility to obtain any consents required under applicable Laws, including any contractual arrangements, to provide Personal Information to us via our referral program.

  3. Other Information. We may also collect other types of information from you via the Site, including during our provision of Services that you request, including information about your business such as company name, company size, and business type. We will treat this information as we do your Personal Information, unless otherwise agreed to by you and buuteeq.

5. USE AND DISCLOSURE OF YOUR INFORMATION

  1. Internal Use. We use Your Personal Information as follows. We will not share or disclose it with any of our Affiliates, except as set forth below:

    - Assess the needs of your business to determine suitable Services
    - Send you requested information regarding our Site and Services
    - Send you updates about our Site and Services
    - Respond to your Customer service requests, questions and concerns
    - Administer your Account
    - Send you our newsletter and marketing communications
    - Improve our Site, Services and marketing efforts.
    - Conduct research and analysis; however, we may share or disclose the results of such research, including to third-parties and our Affiliates, in anonymous, aggregated form, as more particularly described in Section 5(D) below

  2. Sharing With Affiliates. We may store your Personal Information in a database that is accessible to our Affiliates; however, our Affiliates may not use your Personal Information in any manner (including to contact you with marketing communications) without your prior consent, which you may provide to us.
  3. Sharing With Third-Parties. We may share or disclose your Personal Information with or to third parties only in the ways that are described in this Privacy Policy. We do not sell or rent your Personal Information. If you wish to update or delete your testimonial, you can contact us using the information below.

    i. Service Providers. buuteeq may share or transfer Personal Information with or to other companies and individuals that help us provide our Services and/or maintain the Site or conduct our business. We may employ third party companies and individuals to provide the Services on our behalf, and to perform, without limitation, maintenance services, database management, payment processing, marketing communications, and web analytics. These third parties have access to Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

    ii. Compelled Disclosure. We may disclose your Personal Information to courts, governmental authorities or other parties as required by applicable Laws, including to comply with a subpoena, or similar legal process, or if such disclosure is required in the context of a law enforcement investigation.

    iii. Safety and Security. We may disclose your Personal Information to third-parties when we believe in good faith that disclosure is necessary to protect ours or our Users and Customers’ rights, safety or property , including to investigate fraud.

    iv. Sale or Merger. If buuteeq is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information, including in the context of such a sale, merger or acquisition.

    v. With Consent. If you give us written consent to do so, we may share or disclose your Personal Information to any third party covered by your consent. This includes any Personal Information you may consent to allow us to share in any Customer testimonials we may post on our Site.

  4. Sharing and Disclosure of Aggregate Data. buuteeq may share information that is derived from multiple Users’ Personal Information in aggregate form and/or if such information is not capable of identifying you or any other individual. We may share this aggregate information with third parties for industry analysis, demographic profiling and other purposes, including any such information collected from End Users (as more completely discussed below).

6. ACCESS AND CHOICE

  1. Generally. You may always access Personal Information we hold about you by logging in to your Account, if applicable, or by contacting us via the methods described in this Section. If we receive a request to access your Personal Information via email, we may take additional steps to confirm that the individual requesting access to the Personal Information is authorized to do so. In addition, , you may correct, update, amend, or remove Personal Information, or ask to have Personal Information removed by making the change on your Account settings page, by emailing help@buuteeq.com or by contacting us by telephone or postal mail at the contact information listed below. Please note that we may be required to retain certain Personal Information about you to comply with applicable Laws and/or legal processes and, if so required, we will retain such Personal Information. If you no longer desire to use our Services, you may cancel your Account as set forth in the Terms.
  2. Opt-Out Preferences. As indicated above, we may use your Personal Information (name and email address) to send you marketing communications or information about our products and Services from time to time. Also, if you wish to subscribe to our newsletter(s) or blog updates, we will use your Personal Information (name and email address) to send them to you. You may choose to stop receiving our newsletter, updates or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your Account settings page or you can contact us at help@buuteeq.com.

7. RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as we deem it necessary to provide Services to you, comply with applicable Laws (including those regarding document retention), resolve disputes with you or other Users or Customer, with any parties and otherwise as necessary to allow us to conduct our business. All Personal Information we retain will be subject to this Privacy Policy, even if you have cancelled your Account or are otherwise no longer a Customer.

8. INFORMATION COLLECTED FROM YOUR DEVICES

  1. Analytics / Log Files. As is true of most websites, we gather certain information automatically from the devices you use to access the Site and Services and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual Users or contain any Personal Information, to analyze trends, to administer the Site, to track Users’ movements around the Site and to gather demographic information about our User base as a whole. We do not link this automatically-collected information to your Personal Information.
  2. Tracking Technologies. Like many websites, we may also use cookies, Web beacons and similar technology to collect information from the devices you use to access the Site and Services (collectively, “Tracking Technology.” A “cookie” is a small data file that we transfer to your devices’ hard disk(s) for record-keeping purposes and a “Web beacon” is a tiny graphic with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users; however, Web beacons place no files on your devices.
    i. Cookies. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to our Site. Second, we utilize session ID cookies to enable certain features of our Site and Services, to better understand how you interact with the Site and to monitor aggregate usage by and web traffic routing on our Site. Unlike persistent cookies, session cookies are deleted from your computer when you close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of our Site. Also, as with the information collected in sub-section (A), the information collected by cookies does not contain Personal Information, nor will we link the information collected to your Personal Information.

    ii. Web Beacons. We, through our third-party provider, may use the information collected by Web beacons to serve you targeted advertisements. If you wish not to have this information used for the purpose of serving you targeted ads, you may opt-out by clicking Here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. And, as with the information described in the above sub-sections, the information collected by Web beacons does not contain Personal Information, nor will we link the information collected to your Personal Information.

  3. Third-Party Use of Tracking Technologies. We may allow third-parties to display content on the Site, including advertisements for their products and services or for other purposes. These third- parties may use cookies, clear gifs, images, Web beacons and scripts to help them better manage their content on our Site. These third-party uses of Tracking Technologies are not covered by our Privacy Policy and wee do not have access to or control over these Tracking Technologies. However, none of these Tracking Technologies will collect Personal Information with you and, if we are permitted to access or use it, we do not tie the information gathered by third-parties to your Personal Information. If you wish not to have this information used for the purpose of serving you targeted ads, you may opt-out by clicking Here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

9. SECURITY

The security of your Personal Information is important to us. We make commercially reasonable efforts to protect your Personal Information from unauthorized use and access. In addition, we follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as a credit card number or log-in information) on our Site, we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security either before, during or after transmission to or via the Site or Services. If you have any questions about security on our Site, you can contact us using the information below.

10. ABOUT THE CUSTOMER SITES

As indicated above, this Privacy Policy only governs information we collect from our Users and Customers. This Section discusses how we treat our Customers’ End User Data (as defined in the Terms)

  1. Generally. As indicated in the terms, buuteeq collects and Processes End User Data, including Personal Data, under the direction of our Customers, and has no direct relationship with the End Users whose may be processed as part of providing our Service. If you are an End User of one of our Customers and would no longer like to be contacted by one of our Customers that use our Services, please contact that Customer that you interact with directly (i.e. the company or individual who has retained use to provide Services). We will use End User Data, including Personal Information, to the extent required for us to provide Services to our Customers, which may include transfer to third-parties who we use to help us do so. Transfers to other third parties are covered by the agreements with our Customers. Also, we may use End User Data, including Personal Information, for our internal business purposes in any manner, provided such End User Data is modified and/or aggregated such that the Customer or the individual End User are anonymous
  2. Access; Choice; Removal. An individual End User who wants to access correct, amend, or delete inaccurate End User Data should direct his or her query to the appropriate Customer, who is the data controller. If a Customer requests buuteeq to remove any End User’s Personal Information, we will respond to their request within 30 days.
  3. Retention. We will retain End User Data, including Personal Information, as described in Section 6 above.

11. ADDITIONAL INFORMATION

  1. Links to Third Party Sites. Our Site includes links to other websites whose privacy practices may differ from those of buuteeq. If you click on these links, visit those sites or submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.
  2. Blog / Forum. Our Site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected and used by others who access such information so we strongly urge you not to post any Personal Information. Our blog is managed by a third party application that may require you to register to post a comment. We do not have access to, or control over the information posted to the blog. You will need to contact or login into the third party application if you want any Personal Information that you may have posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy.
  3. Social Media Widgets. Our Site includes social media features, such as the Facebook ‘Like’ button, links to our various social media pages and widgets, such as the ‘Share’ this button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it, whether we or a third party is hosting such social media features or widget.
  4. Changes To This Policy. Any Personal Information that we collect is subject to the privacy policy in effect at the time such information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll provide you Notice through a prominent notice on our site or by emailing you (using the email address on your account) and indicate when such changes will become effective.

12. CONTACT US

If you have any questions about this Privacy Policy, please contact us at help@buuteeq.com or at +1-800-734-1769 (US), +56-2-2892-0273 (Latin America) or +31-202-610-295 (Europe). You may also write to us at: 220 West Mercer Street #500 Seattle, WA 98119 USA.