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BOLWALA, INC. PRIVACY STATEMENT
PRIVACY STATEMENT

This Privacy Statement (“Privacy Statement”) explains how Bolwala (“Bolwala” “us,” “our,” and “we”) uses your information and applies to all who use our Web site – www.bolwala.com, mobile applications and social media assets (collectively, the “Site”). In addition, please review the Site’s Terms of Use which governs your use of the Service, and includes, among other things, grants of rights from you, limits on our liability and your remedies, mandatory arbitration, and waiver of jury trial and class actions. By using our Site, you agree to our Terms of Service and consent to our collection, use and sharing of your information and data, and other activities, as described below.

By using the Site, you agree to the terms of this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your personal information or interact with the Site.
We may modify this Privacy Statement at any time. This Privacy Statement is organized as follows:

  • Types of Information We Collect

  • Your Choices

  • How Bolwala Uses Information

  • When and Why Bolwala Discloses Personal Information

  • How Bolwala Collects Information

  • Security of Personal Information

  • Accessing and Correcting Personal Information

  • Social Networks

  • Privacy Practices of Third Parties

1. Types of Information We Collect

We will collect information, including Personal Information and Non-Identifying Information, when you interact with us and the Site, for example when you:

  • access or use the Site;

  • register, subscribe, or create an account with Bolwala;

  • open or respond to our e-mails;

  • refer friends, family, or others to Bolwala;

  • contact customer service or use other customer support tools;

  • provide information to enroll or participate in Other Programs provided on behalf of, or together with, Business Partners;

  • visit any page online that displays our ads or content;

  • purchase products or services on or through the Site;

  • connect or link to any Site via social networking sites;

  • post comments to Online Communities; and

  • Provide information to our Merchants.

This Privacy Statement does not apply to the collection of information in any way other than as listed above.

2. Your Choices

We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to Bolwala, and you can limit the communications that Bolwala sends to you.

(a) Commercial E-mails

You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send or by logging into your account and adjusting your e-mail preferences. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your account and your transactions on the Site. You may update your subscription preferences at any time.

(b) Cookies and Other Technologies

You may manage how your browser handles Cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.

(c) Device Data

You may manage how your mobile device and mobile browser share certain Device Data with Bolwala, as well as how your mobile browser handles Cookies by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

When you first visit or use the Site we may request permission to collect and use your device’s precise geolocation. You can opt not to permit the collection of this information, or permit it only when using the mobile app, but it may limit certain functions or features of the Site. You can control how and whether we collect your precise geolocation information through your device’s settings.

3. How Bolwala Uses Information

We use information collected as described in this Privacy Statement to:

  • Operate, maintain and improve the Site and our services, and Other Programs

  • Provide you with interest-based ads, push notifications, communications, and offers for products and services from us and participating Business Partners, including based on your precise geolocation;

  • Facilitate and fulfill orders placed on the Site and Other Programs

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  • Evaluate your eligibility for certain types of offers, products or services that may be of interest to you, and analyze advertising effectiveness;

  • Answer your questions and respond to your requests;

  • Perform analytics and conduct customer research;

  • Communicate and provide additional information that may be of interest to you about Bolwala and our Business Partners, sometimes by combining your information with information from Other Sources

  • Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information.

  • Manage our everyday business needs, such as administration of the Site, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use, or to comply with the law;

We also may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.

4. When and Why Bolwala Discloses Information

We (or our Vendors on our behalf) may share your Personal Information as required or permitted by law:

  • with any Bolwala Affiliate who may only use the Personal Information for the purposes described in this Privacy Statement;

  • with our Merchants to provide services for us and who are required to protect the Personal Information;

  • to report or collect on debts owed to us or our Business Partners;

  • with relevant Business Partners :

  • with whom we jointly offer products and services;

  • to facilitate a direct relationship with you, including in connection with any program we administer on behalf of the Business Partner;

  • to enable electronic communications with you as part of purchase, a sponsored reward, offer, contest, program, or other activity in which you have elected to participate;

  • to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;

  • to combat fraud or criminal activity, and to protect our rights or those of our Affiliates, users, and Business Partners, or as part of legal proceedings affecting Bolwala;

We encourage Business Partners to adopt and post privacy policies. However, their use of Personal Information obtained through Bolwala is governed by their privacy policies and is not subject to our control.

We may also disclose Non-Identifiable Information :

  • for the same reasons we might share Personal Information;

  • with Business Partners for their own analysis and research;

  • to facilitate targeted content and ads; or

5. How Bolwala Collects Information

You provide us with your Personal Information when you register, subscribe, create an account, make a purchase, or otherwise when you provide us with your Personal Information during your interaction with the Site and Other Programs. We also collect Personal Information when you contact us online for customer service and other support using self-help tools, such as email, text, or by posting to an Online Community.

We also receive Personal Information and other online and offline information from Other Sources. Bolwala will use such information in accordance with applicable laws. Such information, when combined with Personal Information collected as provided in this Privacy Statement, will also be handled in accordance with this Privacy Statement. We also use cookies, tags, web beacons, local shared objects, files, tools and programs to keep records, store your preferences, improve our advertising, and collect Non-Identifying Information, including Device Data and information about your interaction with the Site and our Business Partners' web sites.

We use Cookies and Device Data that allow us to connect your Site activity with other information we store about you in your profile or as related to your interactions with the Site. For more information on how Bolwala uses Cookies, including instructions on how to opt out of interest-based advertising, please review our Cookies Policy.

Device Data may be collected automatically, and as soon as your device interacts with the Site and Bolwala, even if you are not logged into the Site using your device. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

We collect your location information, including precise real-time geolocation, such as through look up based on IP address, GPS, Bluetooth, or WiFi signals, consistent with your choice of mobile device settings. We may also collect the precise location of your device when the app is running in the foreground, background, or even if you are not directly using the application depending on your device and its settings. Your device, as well as the Bolwala mobile app, provides you with options to control how and when we collect your geolocation. You may be able to disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for the Bolwala application in iOS privacy settings.

6. Security of Personal Information

Bolwala has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

7. Accessing and Correcting Personal Information

You can access, update and delete your Personal Information you provided to us, as described below, by managing this information through your online account or sending us an email at [email protected] You can update or remove Financial Account Information as well. Keeping your Personal Information current helps ensure that we, our Affiliates and Business Partners offer you the offers that are most relevant to you.

If you want to deactivate your Bolwala account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on the Site for financial reporting and compliance reasons.

We will retain your Personal Information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to deactivate your account or request that we no longer use your Personal Information to provide you services contact us at [email protected] We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Social Networks

Social Community Areas

The Site may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. All the information you post may be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. We recommend that you do not post any Personal Information in the social community areas.

Social Networks

You may log in to the Site using certain social network credentials. To manage the sharing of certain Personal Information with us when you connect with us through social networking platforms or applications, refer to the privacy policy and settings of the social networking website or application.

By proceeding through any of the above steps, you grant Bolwala permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Statement.

9. Privacy Practices of Third Parties

This Privacy Statement only addresses the use and disclosure of information by Bolwala through your interaction with the Site. Other websites that may be accessible through links from the Site and Other Programs may have their own privacy statements and personal information collection, use, and disclosure practices. Our Business Partners may also have their own privacy statements. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

Non-Identifiable Information means information that alone cannot identify you, including data from Cookies, Pixel Tags and Web Beacons, and Device Data. Non-Identifiable Information may be derived from Personal Information.

Online Communities means, collectively, our social networking pages or accounts, forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or linked through the Site.

Other Programs means special programs, features and functionality on our Site or other co-branded websites with Business Partners that we reasonably control and that have special use terms applicable to such special programs, features and functionality.

Other Sources means sources of information that legally provide Bolwala with your information, and which are outside the scope of this Privacy Statement at the time of collection.

Personal Information means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. This includes the following types of information:

  • Contact Information : your name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.

  • Relationship Information : information you provide that enables us to determine lifestyle, interests, and activities, including location information related to your state/province, city, or neighborhood; areas of interest, the types of deals that interest you, information collected through your interactions with social networks, demographic information (e.g., birth date, age, gender); information about persons for whom you have purchased Bolwala vouchers as gifts or who have bought Bolwala vouchers as gifts for you; and information about friends who refer you or whom you have referred;

  • Transaction Information : information you provide when you interact with us and the Site, such as the Bolwala vouchers you are interested in, purchase and redeem; email and other communications; and how you interact with Business Partners and our Vendors; and

  • Financial Information: information collected from you as needed to process payments for Bolwala vouchers or other products or services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and card verification number.

Pixel Tags and Web Beacons mean tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions.

Third-Party Ad-Servers means Vendors and other third parties that provide the technology to place ads on websites and track ad performance.

Vendors means, collectively, third parties that perform business operations on behalf of Bolwala, such as transaction processing, billing, mailing, communications services (e-mail, direct mail, etc.), marketing, data processing and analytics, servicing, collections, ad management, or information technology services.