What information we collect
We may collect certain user information, including personal data.
Information You Provide To Us. We collect information you provide directly to us including when you use the E2Buddy Service. This information includes personal data. This personal data will be processed for the purposes described in this Privacy Notice, as it may be amended from time to time. For example, your personal data will be used to create or modify your profile and account, access and use the E2Buddy Service(including but not limited to when you play games, answer quiz cards, or use a mobile app), participate in any interactive features of the E2Buddy Service, submit a contact or consent form, participate in a survey, or request customer support.
The personal data that we may collect directly from you includes your name, email address, phone number, information about your Product account preferences, transactional information (including services purchased or subscribed to and amount paid), as well as any contact or other information you choose to provide.
If you are a member of a social media network, like Google, you may choose to use your social credentials to create and log into your E2Buddy account.
The personal data provided during payment is collected and processed by our payment processor (in most cases, Google, Stripe or Razorpay). E2Buddy does not save any personal financial information, including credit card numbers, expiration dates, security codes, or postal codes.
Updating Your Information and Deactivating Your Account. If you need help accessing, modifying, or deactivating your account within the Product, please email [email protected] For users in the European Union (“EU”), please see the section below in this Privacy Notice titled “EU User Rights.”
Information We Collect Automatically When You Use the E2Buddy Service. When you access or use the E2Buddy Service, we may automatically collect information, including personal data, about you, including:
- Usage, Log and Device Information: We collect information from your use of the E2Buddy Service, such as number of visits, length of time spent using or accessing our Products, IP address (which may allow us to collect general location data), pages clicked on within the product, device type, unique device identifier, device language, system time, operating system, browser type, browser language, the date and time of your visit. We collect information on user activity in connection with the E2Buddy Service and may collect information about the features you use, the content you access, and any actions taken in connection with your access and use of the E2Buddy Service.
- Information Collected by Cookies and Other Tracking Technologies: A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognise your browser. Cookies may store user preferences and other information. You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
We also use third party vendor remarketing tracking technologies, including the Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN). As always we respect your privacy and do not collect any information that would identify you individually through the use of Google’s or any other 3rd party remarketing system.
Our third-party vendors, including Google, use tracking technologies on web browsers in order to serve ads based on past visits to our Products, report on the performance of our ads, conduct analytics on the use of our Products, fulfill orders and other user requests, prevent fraud, improve our Products and conduct surveys relating to our users’ experiences with our Products, and communicate with our users. You can opt out and/or customise your preferences by visiting Google’s Ad Settings. For more information about cookies and how to disable them, please see “Third-Party Analytics and Advertising Providers” below.
How we use information collected
We use the information collected through the E2Buddy Service in order to facilitate provision of the E2Buddy Service and engage with you about our products and offerings. We may use the information that we collect:
- To provide, operate, maintain, and improve the E2Buddy Service;
- To enable you to access and use the E2Buddy Service that you request, including sending you technical notices, updates, alerts, and support and administrative messages;
- To provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and receipts;
- To respond to your comments, questions, and requests, and provide customer service and support;
- To communicate with you about services, features, surveys, newsletters, offers, promotions, events, and provide other news or information about E2Buddy and our select partners;
- To process and deliver survey entries and rewards;
- To review and analyse trends, usage, and activities in connection with the E2Buddy Service and for marketing or advertising purposes;
- To investigate and prevent fraudulent transactions, unauthorised access to the E2Buddy Service, and other illegal activities;
- To personalise and improve the E2Buddy Service, and provide content and/or features that match your interests and preferences or otherwise customise your experience on the E2Buddy Service; and
- For other purposes about which we notify you in advance or for which we receive your consent, as necessary.
Data Retention and Erasure
We will maintain certain data for a period of 7 years from the date of your last log in or other study activity in order to keep accurate records for tax purposes. After 7 years from your last activity, we will permanently delete all such personally identifying information. We will keep all other personally identifying information for at least one year after your last login, but in no event longer than seven years. Regardless of the retention period described in this section, we may be required to retain data for longer to comply with legal, regulatory, or audit obligations. Other historical study information may be anonymized and kept at E2Buddy’s discretion.
What information we share or disclose to others
We will not share personal data about you with any third parties except as described in this Privacy Notice, or as defined in an agreement with us in connection with the E2Buddy Service (including a Data Processing Addendum, as applicable). Information that may be shared, pursuant to any applicable agreements, includes:
Third-Party Service Providers. We may share your information with third-party service providers who are working on our behalf and require access to your information to carry out that work, such as to process payment or as it relates to a Product feature. These service providers are authorised to use your personal data only as necessary to provide services to E2Buddy. As required by the European Union’s General Data Protection Regulation, E2Buddy enters into Data Processing Addendums with its Third-Party Service Providers that process personal data of users in the EU.
Third-Party Analytics and Advertising Providers. E2Buddy makes use of certain third-party analytics and advertising providers (“TPAAPs”) to, among other things, serve advertisements to E2Buddy and our users on third-party websites across such TPAAPs’ networks. E2Buddy allows TPAAPs to track our users’ browsing history on our Products using first-party cookies (such as the tools we use to store your Product preferences) and third-party cookies (such as the Google Analytics cookie). TPAAPs may use the information stored by the cookies to, among other things, evaluate your use of a website, prepare reports of website activities for website operators, including us, on the performance of advertising campaigns, other services associated with the website and Internet usage, to serve ads based on past visits to our Products, analytics and optimization on the use of our Products, order fulfillment and other user requests, fraud prevention, Products improvement and user surveys, attribution, and communications with our users. The information tracked and stored by the cookies enables TPAAPs to optimize and serve interest-based ads to E2Buddy’s users on third-party websites and mobile apps. By using or accessing our Products, you agree to the forwarding of data to TPAAPs and the processing by such TPAAPs of the data collected from you in the manner and for the purposes described above.
To opt out of Google Analytics for Display Advertisers and customized Google Display Network ads, visit the Ads Preferences Manager. For more information on how we serve ads based on past visits to our Products, report on the performance of our ads, conduct analytics on the use of our Products, fulfill orders and other user requests, fraud prevention, improve our Products and conduct surveys relating to our users’ experiences with our Products, and communicate with our users, including how to opt-out, you can contact us at [email protected]
- Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the advertising preferences on your mobile device (for example,in Android, visit Settings > Google > Ads > Opt out of interest-based ads).
Disabling Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the E2Buddy Service. When accessing the E2Buddy Service, you will be prompted to choose to continue or learn more about adjusting your browser settings.
Compliance with Laws. We may disclose your information to a third party: (a) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or government request; (b) to enforce our agreements and policies; (c) to protect the security or integrity of the E2Buddy Service; (d) to protect E2Buddy, our customers, or the public from harm or illegal activities; (e) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or (f) as otherwise directed by you.
Business Transfers. We may share or transfer your personal data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Your personal data may be part of the transferred assets. Data processing for this purpose is a legitimate business interest. You may be notified thereafter of any such change in ownership or control.
Aggregated and/or Anonymised Data. We may also share aggregated and/or anonymised information that does not directly identify you individually with third parties. For example, in an ongoing effort to better understand and serve the users of the E2Buddy Service, we may conduct research on customer demographics, interests and behaviour based on the personal information, interviews, and other data provided to us. This research may be compiled and analysed on an aggregate basis, and we may share this aggregated data with our agents and business partners. This aggregated information does not identify you personally. We may also disclose aggregated user statistics in order to describe the E2Buddy Service to current and prospective business partners, and to other third parties for other lawful purposes.
Link to 3rd party websites
We may place links on the E2Buddy’s Website or Apps, including the E2Buddy Blog. When you click on a link from our Product to a third-party website, your activity and use is governed by that website’s policies; not by those of E2Buddy. We encourage you to review their privacy and user policies.
How we store information
By using and accessing the E2Buddy Service, you understand and agree to the storage of information and any other personal data on E2Buddy’s server and cloud-based solutions located in Singapore, or as defined in an agreement with us (including a Data Processing Addendum, as applicable).
How we secure information
We have adopted reasonable physical, technical and organisational safeguards against accidental, unauthorised or unlawful destruction, loss, alteration, disclosure, access, use or processing of information we collect.
You may access your Product account information and our Product only through the use of an individual user ID and password. To protect the confidentiality of personal data and information, you must keep your password confidential and not disclose it to any other person. To keep your account secure, always log out and close your browser when you finish your session. Please advise us immediately if you believe your password has been compromised in any way. Please note that we will never ask you to disclose your password to us.
Unfortunately, the transmission of information via the Internet and apps 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 us. Any transmission of personal information is at your own risk. We are not responsible for any circumvention of any privacy settings or security measures.
If you have any questions about the security of your personal data, you can contact us at [email protected]
Our Global Data Privacy and Protection Practices
E2Buddy uses standard clauses as the basis for its approach to provide appropriate safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals and the exercise of their corresponding rights.
EU User Rights
Right to Access, Update, or Erasure. You have the right to access, update, correct, or delete your personal data.
Right to Restrict Data Processing. You have the right to restrict the processing of your personal data upon request if it is (a) inaccurate or unlawful (b) under contest, or (c) no longer being processed for the original purpose. E2Buddy may continue to process the data if it is necessary to resolve legal claims, for the protection of the rights of another person, or for reasons of important public interest. We will notify you promptly upon receival of your request.
Right to Data Portability. You have the right to request and obtain your personal data that you provided or that we collected through your consent. We will provide your information in a commonly used, machine-readable format promptly, but no longer than 90 days from the initial request depending on the complexity. If circumstances arise where we are unable to complete your request, we will promptly provide a relevant reason, as well as inform you of additional steps that you may take.
Retaining Your Personal Information and Data. We will retain your personal data to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for as long as your account is active or as needed to provide you with the service.
Receiving Promotional and Other Communications. By subscribing to the E2Buddy service, you provide your consent about receiving promotional newsletter or product information emails. You may opt out by following the opt-out instructions provided in our emails to you, or by emailing us with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts.
Withdrawing Your Consent. You may withdraw any consent you previously provided to us for the processing of your personal data. As required by applicable law, we will apply your preferences going forward, within a reasonable amount of time. Even where you withdraw your consent, we may still process your personal data for limited purposes as necessarily required. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot use our product/service.
Lodging a Complaint with a Supervisory Authority. You have the right to submit a complaint to an EU supervisory authority if you believe that your personal data has been processed in a manner that is not compliant with the GDPR. You also have the right to submit a complaint to an EU supervisory authority if E2Buddy is unable to comply with your right of data portability or does not respond to your request within a timely manner.
If you are a California resident and use our product/service, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes if any, during the preceding calendar year. To request a notice, please submit your request to [email protected] with an appropriate subject line.
Our Policy toward Children
In compliance with the Children’s Online Privacy Protection Act(COPPA), and the Federal Trade Commission’s Children’s Online Privacy Protection Act Final Rule, E2Buddy service is not primarily directed to children under the age of 13. If we are made aware by anyone that a child under 13 has provided us with personal information, we will take steps to delete such information. If you are a California resident under the age of 18 and a registered user of E2Buddy, you may request that we remove content and information that you post on our service. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to [email protected] Please be aware that such a request does not ensure complete or comprehensive removal of the content and may remain visible in a manner that does not identify you. There may be other circumstances in which applicable laws do not require removal of such data even if requested.
Last updated: 18th December, 2019