BUDDHI PRIVACY POLICY

Last Updated: February 9, 2020

Buddhi PBC (“Buddhi”, “we”, “our”, “us”) offers a community guide and wellness registry, including mobile applications and websites related to such platform available online (collectively, the “Services”).

The Services enable our customers to, among other things, interact with companies and other third parties offering products and services (collectively, “Vendors” and each individually a “Vendor”) and book services that a Vendor offers. Find out more about our Services here.

Buddhi takes the privacy and security of personal information very seriously. As such, we have prepared the following Privacy Policy to provide you with information about how your data is collected, used, stored, shared, transferred, and protected as a result of your interaction with and use the Services. By using the Services, you agree to the following Privacy Policy and our Terms of Use. If you disagree with any of the provisions described below, your remedy is to stop using the Services immediately.

APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”).

DATA CONTROLLER DISCLAIMER

Please note that we are only data controllers with respect to any membership and profile information for the purposes set out in this Privacy Policy. For all other purposes relating to our Services, we operate as data processors for our Vendors and the Vendors act as data controllers. Our Vendors have their own privacy policies and we do not accept any responsibility or liability for their policies or processing of personal information. This Privacy Policy and the rights and obligations set out below only apply where we are acting as data controllers.

PERSONAL INFORMATION COLLECTION & USAGE

Information Provided by You

In general, you can access the Services without telling us who you are or revealing any information about yourself. When you interact with the Services, including through expressing interest in obtaining information about us or our Services or submitting an inquiry , we may collect personal information, which may include your name, date of birth, company name, e-mail address, phone number, and other information that identifies you (collectively, “Personal Information”). It is your decision to use the Site, and, as such, any provision of this Personal Information is completely voluntary. By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.

We utilize analytic services, including, without limitation Google Analytics to capture and analyze visits and traffic in using the Services. These analytic services collect information about your use of the Services, including, without limitation, information about your visit to the Site and/or Application, any referral website, the type of web browser and operating system you are currently using, and your network location and IP address. The information collected by these analytic services is anonymous and aggregated. We reserve the right to use this information for any lawful business purpose, including selling or sharing the aggregated and anonymized data collected, whether by us or a third party service provider. We may also use this aggregated and anonymized data to analyze trends or seek third party advertisers.

The personal information we collect depends on the context of your interactions with us and our Services, the choices you make related thereto, and the features you use. The personal information we collect can include the following:

Information Collected Automatically & Through Our Services

We may automatically collect certain information when you visit, use or navigate the Services. This information is non-personal and does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, browsing history on the Services, the length of time spent on certain pages, Internet service provider, date/time of visit information, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain security and operation of our Services, and for our analytics and reporting purposes.

We may also collect Personal Information about you from other companies. If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated or linked to the Services, you are subject to the Terms of Use and Privacy Policies of those social networking services.

We may also collect Personal Information about you for other purposes from time-to-time, or as permitted or required by law. We will always identify any additional purpose prior to or at the time of collection.

Buddhi’s Information Usage

We may use the Personal Information and/or non-personal information collected as described in this Privacy Policy, including to:

We may use the analytics information collected as described elsewhere in this Privacy policy, including to:

Information Sharing

We may process or share data, including Personal Information, for the following reasons:

We may also share non-personal information with select third-parties, such as our advertisers, for purposes of serving you with customized promotions. If you would like to learn more about the sharing of non-personal information for purposes of providing customized advertisements or promotions, please visit http://www.aboutads.info/consumers/.

PERSONAL INFORMATION STORAGE & SAFETY

If you no longer want Buddhi to use your information to provide the Services to you, you may cancel your membership. Buddhi will retain and use your information as permitted under this Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes and enforce our agreements. We also retain log files and other information for analysis purposes.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Cookies may be stored only for the time you are in a given site or they may remain stored in your browser for a defined period of time beyond your current session. Cookies work in combination with content within the website itself, to capture and remember information. To learn more about these technologies and how they work, please see www.allaboutcookies.org.

We use cookies and other similar technologies (such as web beacons and pixels) to collect and process non-personal information, personalize our Site for you, and to collect aggregate information about the usage of our Site.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can review the options available to manage cookies in your browser. One option is to disable, or turn-off, all cookies. If you turn cookies off, you may not be able to browse the Site. If you disable certain kinds of cookies, some aspects of our Site may not function properly or as well.

SAFETY OF YOUR INFORMATION

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.

All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone. If you believe your password has been compromised, please contact us immediately.

If we receive instructions using your Buddhi membership login information, we will consider that you have authorized the instructions. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate memberships, and to remove or edit content.

YOUR CHOICES

You may have choices when it comes to the collection, use, and sharing of your personal information. You may choose to “unsubscribe” from email marketing communications, or you can contact us at help@hibuddhi.com to be removed from our email marketing lists or to terminate your membership. Please be aware that you are not able to opt out of receiving communications about your buddhi or related transactions with us unless you terminate your use of our Services.

Upon your request to terminate your membership, we will deactivate or delete your membership and information from our active database. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

ACCESSING YOUR INFORMATION

You must notify us of any change in your Personal Information by updating your Buddhi membership profile through our Services. Any changes will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

LOG-IN THROUGH SOCIAL NETWORKS

You may have the option of signing into the Services through Facebook, Google, or other social networks. Logging in through these social networks may allow us to access certain public information related to your profile. When you sign in through one of these social networks, you may be asked what information you would like to share. It is up to you what to share with us, or whether anything at all from your social network profile is shared at all.

LINKS TO THIRD PARTY SITES

We may provide you with links to third-party websites through the Services. We may also allow third-party websites or applications to link to our Services. We are not responsible for the collection, use, or sharing of your personal information once you leave our Services and follow a link to a third-party website. Please consult each linked website’s privacy policy for a description of how the website collects, uses, and shares your information.

DO NOT TRACK

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not use technology that recognizes DNT signals from your web browser.

CHILDREN’S INFORMATION

The Services is not intended for children under the age of 18 years old. We do not knowingly collect information from children under the age of 18. If we discover that we have information from a child under the age of 18, we will delete it immediately. If you believe that a child under the age of 18 may have provided his or her information to us, please contact us using the contact information below. You are not permitted to enter any information about a minor anywhere on the Services unless you are that minor’s legal guardian and consent to the practices described in these Terms of Use on behalf of that minor. We may ask you to verify that consent, and you are required to do so promptly.

VISITING THE SERVICES FROM OUTSIDE THE UNITED STATES

This Privacy Policy is intended to cover the collection of information on the Services from United States residents only. If you are visiting the Services from outside the United States, please know that by using the Services, you understand and agree that your information may be moved to, accumulated and processed in the United States and such information may be transferred to our third parties with whom we share such information as described in this Privacy Policy.

CALIFORNIA RESIDENTS’ PRIVACY RIGHTS.

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

Your California Privacy Rights

If you are a California resident, the CCPA may allow you to make certain requests about your personal information. Specifically, the CCPA may allow you to request us to:

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and other account information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please use the online web form or contact us at help@hibuddhi.com.

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our Services, charge you different prices or rates (if any), or provide you a lower quality of Services if you exercise your rights under the CCPA. However, we may have different tiers of Services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, attributes or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.

Notice of Right to Opt Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include when we share your information with third parties to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.

Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:

If you would like to opt out of Buddhi’s use of your information for such purposes that are considered a “sale” under California law, you may submit a sale opt-out request by emailing us at team@hibuddhi.com. Please note that we do not knowingly sell the personal information of minors under 18 years of age without legally-required affirmative authorization.

California Shine Light

If you live in California and have an established business relationship with us, you can request a list of the Personal Information we have shared with third-parties for their marketing purposes. We will also give you a list of the third-parties that have received your information. You can make a request one time each year.

To exercise your rights, you can e-mail us at help@hibuddhi.com or write to:

buddhi PBC

625 W. Adams St., 19th Floor

Chicago, IL 60661

Mention in your letter that you are making a “California Shine the Light” inquiry. We will respond within 30 days.

UPDATES TO THIS PRIVACY POLICY

We reserve the right to make changes to this Privacy Policy at any time and in our sole discretion. We will post changes directly to this Privacy Policy and update the date at the top of this Privacy Policy, so it is your responsibility to check back here from time to time to review. If we make a material changes to this Privacy Policy, we may provide advance notice of such change. The revised Privacy Policy will be effective upon posting, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. Except as otherwise expressly stated by us, your access and use of our Site is subject to the version of this Privacy Policy in effect at the time of access or use.

CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy, please contact us using the information below:

buddhi PBC

625 W. Adams St., 19th Floor

Chicago, IL 60661

help@hibuddhi.com