This Privacy Policy is effective September 24, 2018, or earlier if you are presented with it sooner, like when you create an account, pair your Bond Touch bracelets to a mobile device, or visit Bond Touch’s website.

Congratulations and thank you for purchasing and using your Bond Touch bracelets to keep in touch with your loved ones.  We are honored that you are trusting us with being a part of your close relationships.  For Bond Touch bracelets to work, we collect and use information that is important to you.  This Privacy Policy explains how we use that information.

Here we describe the privacy practices for our bracelets, other devices, apps, software, websites, products, and services (the “Services”).  We discuss the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.

1. Legal Bases for Collecting, processing, and using Information

Bond Touch is a “Controller” for the purposes of Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”).  Our legal bases for collecting, processing, and using information from you under the GDPR in connection with the Services are as follows:

(a) CONSENT

Your purchase, activation, or use of a bracelet, or your opening of an account with us, or your use of our website, or your logging onto or use of our app, or your use of any of our Services, constitutes your legal consent to collection, processing, and use of information by us in accordance with this Privacy Policy under US law, the GDPR, or any other applicable law in your jurisdiction.

(b) NECESSITY

Collection and use of information by us in accordance with this Privacy Policy is necessary for these purposes:

  • proper functioning of a bracelet;
  • opening of an account;
  • use of an account; 
  • logging onto and use of our app;
  • logging onto our website;
  • processing payment for any of the Services; and
  • any other use of the Services.

2. INFORMATION WE COLLECT

When you use our Services, we collect the following types of information.

(a) INFORMATION YOU PROVIDE US

Account Information

Some information is required to create an account on our Services, such as your name, mobile telephone number, mobile carrier, password, email address, social media accounts, date of birth, residential address, and photo.  The person that will exchange touches with you through the bracelets will also create an account on our Services and will provide the same information to us.  You may also choose to provide other types of information related to any other Services we may provide in the future, such as a community username and messages.

Additional Information

To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, such as access to your contact list on your mobile device.

If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and messages.

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service.  For example, if you connect to Facebook, Twitter, or Instagram, we may receive information like your name, profile picture, age range, language, email address, and friend list. 

Payment and Card Information

If you purchase Bond Touch bracelets or other merchandise on our website or an authorized seller’s website, you provide your payment information, including your name, credit or debit card number or PayPal account information, card expiration date, CVV code, and billing address.  We store your shipping address to fulfill your order.

(b) INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES

Bond Touch Device Information

Your Bond Touch bracelet and apps, together with your mobile device, collect data on:

  • touches sent or received;
  • the sender and the recipient of such touches;
  • information regarding the sender and recipient of such touches, including mobile phone numbers and the other Account Information described above; 
  • the sender’s and recipient’s location at a city-level of granularity (see “Location Information” below); and
  • the number, time, and duration of touches sent and received.

When information regarding touches syncs with our apps or software, data is recorded on your mobile device and is then transferred to our servers which may be operated by third parties.

Location Information

The Services include features that use location data to a city-level of granularity, which may be obtained from GPS signals, device sensors, Wi-Fi access points, and cell tower IDs.  We may also derive your approximate location from your IP address.  We do not collect location data to a level of granularity more precise than city-level.

Usage Information

When you access or use our Services, we receive certain usage data.  This includes information about your interaction with the Services, such as when you turn on the Bond Touch bracelet, create or log into your account, pair your Bond Touch bracelet with your account, open or interact with the Bond Touch app or bracelet, log out of your account, or turn off the Bond Touch bracelet.

We also collect data about the devices you use to access the Services, including Bond Touch bracelet information, IP addresses, mobile phone numbers and other identifiers, browser type, language, operating system, referring web pages, pages visited, location, and cookie information. among other sources of data collection.

Personally Identifiable Information (PII) Relating to Touches

Personally Identifiable Information (PII) (e.g. names, mobile smartphone numbers, photos, and anything else that could identify you or the person with whom you exchange touches) related to data from touches sent and received through bracelets (“Touch Data”) remains saved within the mobile app on your smartphone until you uninstall the app.  The Touch Data is transmitted to Bond Touch’s servers and is used to deliver touches between you and the person that is receiving and sending touches with you.  We then pseudonymize the Touch Data to remove its personally identifiable aspects which are then deleted immediately from our servers after a touch is delivered.  We keep the pseudonymized Touch Data for our analytics which we may share with third party processors (see “How We Use Information”).

We recognize the potentially sensitive nature of Touch Data as it may constitute “personal data” in connection with your personal relationships for purposes of Article 9 of the GDPR.  The Touch Data is therefore pseudonymized and stored and processed separately from other PII to ensure that it cannot be used to identify you or any person with whom you exchange touches.

Other PII Not Collected From Touches

We retain other PII that is collected from sources other than touches, such as your payment information, account information, shipping information, and any information from social media accounts that you allow us to obtain.  We use that information as described in this Privacy Policy.

Cookies and Similar Technologies We Use

Like many online products, we use cookies, pixels, local storage, and software development kits (“SDKs”) to remember things about you so that we can improve our Services.

  • Cookies are small data files stored on your browser or device.  They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”).  For example, we partner with third-party analytics providers which set cookies when you visit our websites.  This helps us understand how you are using our Services so that we can improve them.
  • Pixels are small images on a web page or in an email.  Pixels collect information about your browser or device and can set cookies.
  • Local storage allows data to be stored locally on your browser, mobile smartphone, or other device, and includes HTML5 local storage and browser cache.
  • SDKs are blocks of code provided by our partners that may be installed in our mobile apps.  SDKs help us understand how you interact with our mobile apps and collect certain information about the device and network you use to access the apps.

We and our partners use these technologies on our Services as follows:

  • Preferences:
  • To help us remember your settings and preferences, like your preferred language or the country you are in, so that we can personalize the Services.
  • Authentication and Security:
  • To help us maintain the security of your data and the Services.
  • Service Features and Performance:
  • To provide you with functionality and optimize the performance of the Services.
  • Analytics and Research:
  • To help us understand how you are using the Services so that we can improve them continuously.
  • Advertising:  
  • To enable our partners to serve ads for our products and services, deliver relevant ads to people who may be interested in them on other services, measure the performance of ads; and opt you out of receiving interest-based ads if you choose.

To change your settings related to cookies and similar technologies, see the section “Your Options Relating to Cookies and Similar Technologies” below.

3. HOW WE USE INFORMATION

We use the information we collect to provide, improve, and develop our Services.

(a) PROVIDING, IMPROVING, AND DEVELOPING SERVICES

We deliver the Services, improve them, and research and develop new ones using the information we collect.  For example, we use the information to do the following:

  • provide you with the Services you request; 
  • understand how you and other users interact with the Services; 
  • track usage trends; 
  • provide customer support; 
  • troubleshoot and protect against errors; 
  • perform data analysis and testing; 
  • conduct research and surveys; 
  • personalize the Services; and 
  • develop new features and Services.

(b) COMMUNICATING WITH YOU

We use your information to send you Service notifications and inform you of new features or products.  You can control marketing communications and most Service notifications by changing your account settings or via the “Unsubscribe” link in an email.  We also use your information to respond to you when you contact us.

(c) PROMOTING SAFETY AND SECURITY

We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

4. HOW INFORMATION IS SHARED

We do not share your information, including your PII, except in the limited circumstances described below.

(a) WHEN YOU AGREE OR DIRECT US TO SHARE

You may direct or authorize us to share your information with others, for example, by choosing to connect to any of your social media accounts or to a third-party app to which you grant access to your account.  If you do so, their use of your information will be governed by their privacy policies and terms.  You can revoke your consent to share with third-party apps by changing your account settings.

(b) FOR EXTERNAL PROCESSING

We may transfer information to our corporate affiliates, service providers, and other partners that process it for us based on our instructions, all of which are “Processors” for purposes of the GDPR.  Such processors must act in compliance with this Privacy Policy, applicable law, and any other appropriate confidentiality and security measures.  These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.

A list of processors and the data processed by them includes the following as of the date of this Privacy Policy is listed on Exhibit A at the end of this Privacy Policy.  The processors are located variously in the United States, the European Union, or elsewhere.  We may engage the services of other similar third-party processors or process other types of data from time to time at our discretion to maintain and enhance the quality of the Services.

We may engage other similar third-party processors or process other types of data from time to time at our discretion to maintain and enhance the quality of the Services.

(c) FOR LEGAL REASONS OR TO PREVENT HARM

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

We will notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so.  In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period.  Exceptions to notifying you include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.

We may share non-personal information that is aggregated or pseudonymized so that it cannot reasonably be used to identify an individual.  We may disclose such information publicly and to third parties to partners under agreement with us.

If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to any new entity.

5. HOW TO ACCESS OR DELETE YOUR PERSONAL INFORMATION

We provide you with account settings and tools to access and manage the personal information associated with your account.  You can also download certain account information, including data about your activities.

We store information associated with your account until your account is deleted.  You can delete your account at any time by contacting us at [email protected]  Please note that it may take a bit of time to delete your account information, and we may preserve it for legal reasons or to prevent harm, including as described in the “How Information Is Shared” section above.

(a) YOUR OPTIONS RELATING TO COOKIES AND SIMILAR TECHNOLOGIES

You have a number of options to control or limit how we and our partners use cookies and similar technologies, including for advertising.

  • Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies.  If you disable cookies, however, some of the features of our Services may not function properly.
  • To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info.
  • To opt out of ads on your social media accounts that are targeted to your interests, adjust the settings for these accounts.
  • Check your mobile device for settings that control ads based on your interactions with the apps on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.

Our websites do not respond to Do Not Track signals because we do not track our users over time and across third-party websites to provide targeted advertising.  However, we believe that you should have a choice regarding interest-based ads served by our partners, which is why we outline the options available to you above.

(b) DELETION OF INACTIVE ACCOUNTS

We delete accounts that have been inactive for nine (9) months after the last account activity.  All PII of the users of inactive accounts is also deleted.

6. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We work with partners that provide us with analytics and advertising services.  This includes helping us understand how users interact with the Services, serving ads on our behalf across the internet, and measuring the performance of those ads.  These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and apps.  Please see “Cookies and Similar Technologies We Use” and “Your Options Relating to Cookies and Similar Technologies” above.

7. OUR POLICIES FOR CHILDREN

We take additional measures to protect children’s privacy.  Persons under the age of 13 in the United States, or 16 in the European Union, or the equivalent minimum age in the relevant jurisdiction, are not permitted to create accounts unless a parent or legal guardian has consented to creating that account in accordance with applicable law.  If we learn that we have collected the personal information of a child under the relevant minimum age without such consent, we will take steps to delete the child’s information as soon as possible and we may disable such child’s account.  Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at the address below.

8. INFORMATION SECURITY

We use a combination of technical, administrative, and physical controls to maintain the security of your data.  No method of transmitting or storing data is completely secure, however.  If you have a security-related concern, please contact [email protected].

9. OUR INTERNATIONAL OPERATIONS AND DATA TRANSFERS

We operate internationally and may transfer information collected within the European Economic Area and Switzerland to the United States for the purposes described in this Privacy Policy.  Bond Touch complies with the EU-US and Swiss-US Privacy Shield principles regarding the collection, use, sharing, and retention of personal information from the EEA and Switzerland, as described in our EU-US Privacy Shield certification and Swiss-US Privacy Shield certification. Learn more about Privacy Shield at https://www.privacyshield.gov/welcome.

We are subject to the oversight of the US Federal Trade Commission and remain responsible for personal information that we transfer to others who process it on our behalf as described in the “How Information Is Shared” section. If you have a complaint about our Privacy Shield compliance, please contact us.  You can also refer a complaint to our chosen independent dispute resolution body, the International Centre for Dispute Resolution/American Arbitration Association, and in certain circumstances, invoke the Privacy Shield arbitration process.  More information is available at http://go.adr.org/privacyshield.html.

10. CHANGES TO THIS PRIVACY POLICY

We will notify you before we make material changes to this Privacy Policy and give you an opportunity to review the revised Privacy Policy before deciding if you would like to continue to use the Services.

11. HOW TO CONTACT US

If you have questions about this Privacy Policy, or about our use of your information, please contact us at:

Christoph Dressel

Bond Touch, Inc.

622B Santa Cruz Ave

Menlo Park, CA 94025

USA

[email protected]

As of the date of this Privacy Policy, we do not have a Data Protection Officer for purposes of Article 37 of the GDPR as we do not conduct regular and systematic monitoring users on a large scale or process any special categories of PII on a large scale.

EXHIBIT A

THIRD PARTY PROCESSORS

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