Effective date: 12th December 2022
Welcome to Bulletn.
Bulletn LLC (“Company”, “Bulletn”, “us”, “we”, or “our”) owns and operates www.bulletn.net and Bulletn mobile application (hereinafter referred to as “Service”).
1.1 In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:
means the www.bulletn.net website and Bulletn mobile application operated by Bulletn LLC;
means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession);
“USAGE DATA ”
is data collected automatically either generated by the use of Service or from the Service infrastructure itself (for example, the duration of a page visit);
are small files stored on your device (computer or mobile device);
“DATA CONTROLLER ”
“DATA PROCESSORS (OR SERVICE PROVIDERS”
means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively;
is any living individual who is the subject of Personal Data;
“THE USER ”
is any living individual who is the subject of Personal Data;
3. TYPES OF DATA COLLECTED
3.1. We collect Personal Data directly from you, from others, and automatically from your use of the Services. We will only collect your Personal Data (a) when applicable, with your consent, (b) if we have a legitimate interest in doing so, or (c) as authorized or required by law. The types of Personal Data we collect about you and the manner of the collection depending on how you interact with Bulletn. We only collect Personal Data as reasonable and necessary. If you do not provide the relevant information, we may not be able to provide you with certain Services or features.
3.2. Sources. We collect Personal Data from these sources:
3.2.1. Directly from you, with your consent. When you register for an Bulletn account, we collect, including, but not limited to, your first name, family name, social media usernames, username, gender, phone number, email, mailing address, zip code, business address, training history, consignee information, method of payment and bank account information, etc. When you contact us for customer service or to make inquiries via our forms, surveys or other means, we ask for your name, phone number, and transaction information, and we record the date, frequency, and other details about your inquiry. We collect this information with your consent, and we use it to provide you with Bulletn, respond to your inquiries, and to communicate with you including sending you direct marketing materials.
3.2.2. Automatically from your use of Bulletn, with your consent. If you are opt-in to Bulletn you consent to Bulletn sharing your geolocation and other Personal Data from your account. You can opt-out of Bulletn at any using the deactivate button on your Bulletn dashboard. We collect this information with your consent and we use it to provide you with Bulletn and for other purposes that you consent to or are permitted by law.
3.2.3. Automatically from your use of Bulletn, with a legitimate interest in providing and improving our Services. When you navigate to and through Bulletn or the Site, we collect information about your device, software, and network including: IP address, browser type, device name and model, device ID, operating system version number, language selected for a device, time zone, telecom operator information, error logs, certain user behavior, and other information collected through cookies and other similar technologies. We collect this information to achieve our legitimate interest in monitoring and improving our Services.
3.2.4. From third parties, with a legitimate interest, such as other websites and social networks that you may link to your Bulletn account, marketing companies, and other third parties that may lawfully provide us with Personal Data. When you link from another website or social network, we may obtain information from your account, such as account ID, e-mail address, and profile picture. We reserve the right to collect information about you from our Service Providers and third-party sources. We may combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new users, and improve and expand our Services.
3.3. Bulletn does not collect Data we believe to be sensitive. As an User, you have the ability to see the Data we have about you.
4. USE OF DATA
4.1. Bulletn uses the collected data for various purposes:
4.1.1. to provide and maintain our Service;
4.1.2. to notify you about changes to our Service;
4.1.3. to allow you to participate in interactive features of our Service when you choose to do so;
4.1.4. to provide customer support;
4.1.5. to gather analysis or valuable information so that we can improve our Service;
4.1.6. to monitor the usage of our Service;
4.1.7. to detect, prevent and address technical issues;
4.1.8. to fulfill any other purpose for which you provide it;
4.1.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
4.1.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
4.1.11. 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 information;
4.1.12. in any other way we may describe when you provide the information;
4.1.13. for any other purpose with your consent.
5. RETENTION OF DATA
5.2. We will 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.
5.3. We will also retain Usage Data for internal analysis purposes.
5.4. Usage Data is generally retained for a shorter period, 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.
6. TRANSFER OF DATA
6.1. Your information, including Personal Data, 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 from those of your jurisdiction.
6.2. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
7. DISCLOSURE OF DATA
7.1. We may disclose personal information that we collect, or you provide:
7.1.1. Disclosure for Law Enforcement.
220.127.116.11. Under certain circumstances, we may be required to disclose your Personal Data, but we will only do so if required by law.
7.1.2. Business Transaction.
18.104.22.168. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
7.1.3. Other cases. We may disclose your information also:
22.214.171.124. to our subsidiaries and affiliates;
126.96.36.199. to contractors, service providers, and other third parties we use to support our business;
188.8.131.52. to fulfill the purpose for which you provide it;
184.108.40.206. for the purpose of including your company’s logo on our website;
220.127.116.11. for any other purpose disclosed by us when you provide the information;
18.104.22.168. with your consent in any other cases;
22.214.171.124. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
8. SECURITY OF DATA
8.1. The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.
8.2. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
9. YOUR DATA CHOICES, OPT-OUT AND DELETION
9.1. Opting Out of Data Sharing, Preventing Future Use of Data, Data Deletion
9.2. Bulletn also wants you to be aware of additional choice mechanisms that are available to you. For example, the Digital Advertising Alliance self-regulatory codes (the “DAA Codes) in the United States enable you to opt-out of certain advertising and marketing uses of Data. Bulletn adheres to the First Party principles of the DAA Codes, and many of our Purchasers adhere to the DAA Codes. For more information about the DAA and to better understand those choice mechanisms, please visit https://youradchoices.com/.
9.3. You can also use the tools made available via most mobile operating systems to refresh your IDFA and stop sharing your location at any point by doing the following:
9.3.1. Apple devices:
126.96.36.199. Opt-out of app-based tracking for interest-based advertising by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON.’ For iOS 6, you can do this by selecting Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON.’ You can do this for iOS 7 and higher by selecting Settings -> Privacy -> Advertising and toggling Limit Ad Tracking to ‘ON’.
9.3.2. Android devices:
188.8.131.52. Opt-out app-based tracking for interest-based advertising by taking the following steps: (i) Open the Google Settings app on your device; (ii) Select “Ads”; and (iii) Opt-out of interest-based ads. You can obtain further information about how identifiers on mobile are used for advertising and receive instruction on how to opt-out of mobile advertising here: Google Privacy & Terms webpage.
9.4. A trade association called the Network Advertising Initiative also publishes a helpful list of ways to opt-out of targeted ads on mobile devices at https://www.networkadvertising.org/mobile-choice/.
10. YOUR RIGHTS
10.1. You have the following rights in relation to your Data:
10.1.1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. 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." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
10.1.2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
10.1.3. Right to erase - the right to request that we delete or remove your Data from our systems.
10.1.4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
10.1.5. Right to data portability - the right to request that we move, copy or transfer your Data.
10.1.6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
10.2. To make inquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org
10.3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.
10.4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
11. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
11.1. If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
11.2. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
11.3. If you wish to be informed what Personal Data, we hold about you and if you want it to be removed from our systems, please email us at email@example.com
11.4. In certain circumstances, you have the following data protection rights:
11.4.1. the right to access, update or to delete the information we have on you;
11.4.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
11.4.3. the right to object. You have the right to object to our processing of your Personal Data;
11.4.4. the right of restriction. You have the right to request that we restrict the processing of your personal information;
11.4.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
11.4.6. the right to withdraw consent. You also have the right to withdraw your consent at any time when we rely on your consent to process your personal information;
11.5. Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.
11.6. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
12. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
12.2. According to CalOPPA we agree to the following:
12.2.1. users can visit our site anonymously;
12.2.4. users are able to change their personal information by emailing us at firstname.lastname@example.org
12.2.5. Our Policy on “Do Not Track” Signals:
12.3. We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
12.4. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
13. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)
13.1. If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
13.2. What personal information we have about you. If you make this request, we will return to you:
13.2.1. The categories of personal information we have collected about you.
13.2.2. The categories of sources from which we collect your personal information.
13.2.3. The business or commercial purpose for collecting or selling your personal information.
13.2.4. The categories of third parties with whom we share personal information.
13.2.5. The specific pieces of personal information we have collected about you.
13.2.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
13.2.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
13.3. Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
13.4. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through the de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
13.5. To stop selling your personal information. We don't sell or rent your personal information to any third parties for any purpose. You are the only owner of your Personal Data and can request disclosure or deletion at any time.
13.6. Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services that require the usage of your personal information to function.
13.7. To exercise your California data protection rights described above, please send your request(s) by one of the following means:
13.7.1. By email: email@example.com
13.8. Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.
14. CONSUMER PRIVACY REQUESTS
14.1. Through the Services, Bulletn provides methods for you to directly access, edit, delete or export certain Personal Information Bulletn processes in your use of the Services.
14.2. If you wish to exercise your rights under applicable privacy laws beyond these methods, please submit a verifiable Consumer Privacy Request: by email at firstname.lastname@example.org
14.3. Bulletn may only legally fulfill a Consumer Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request.
14.4. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
15. SERVICE PROVIDERS
15.1. We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
15.2. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
16.1. We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).
17. LINKS TO OTHER SITES
17.1. Our Service may contain links to other sites that are not operated by us.
17.2. If you click a third-party link, you will be directed to that third party's site.
17.4. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
18. BEHAVIORAL REMARKETING
18.2. Google Ads (AdWords)
18.2.1. Google Ads (AdWords) remarketing service is provided by Google Inc.
18.2.2. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
18.2.3. 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.
18.2.4. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
184.108.40.206. Facebook remarketing service is provided by Facebook Inc.
18.4. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
18.4.1. To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
18.4.2. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
18.4.3. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
18.5.1. Instagram remarketing service is provided by Facebook Inc. For more information on the privacy practices of Instagram, please visit the Instagram Privacy Terms web page: https://www.instagram.com/519522125107875?helpref=page_content.
19. CHILDREN’S PRIVACY
19.1. Our Services are not intended for use by children under the age of 16 (“Children”).
19.2. You must be at least 16 years old, and if you are below the age of 16, you must have obtained the consent of your parent or legal guardian to open a Bulletn Account and use the Service.
19.3. The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 16 years of age.
19.4. We do not knowingly collect or solicit personally identifiable information from children under 16 years of age; if you are a child under 16 years of age, please do not attempt to register for or otherwise use the Bulletn Services or send us any personal information.
19.5. If we learn we have collected personal information from a child under 16 years of age, we will delete that information as quickly as possible.
19.6. If you believe that a child under 16 years of age may have provided us with personal information, please contact us at email@example.com
21. CONTACT US
21.1.1. By email: firstname.lastname@example.org