ExpatBuddy Inc. (“us”, “we”, or “our”) operates the ExpatBuddy mobile application and website (hereinafter referred to as the “Services”).
Collection and Use of Personal Information
Personal information is data that can be used to identify or contact a single person.
Here are some examples of the types of personal information we may collect and how we may use it:
What Personal Information We Collect
When you use our Services or interact with our company, we may collect a variety of information, including but not limited to, your location, name, mailing address, phone number, email address, contact preferences, shopping preferences, your calendar, and information about yourself and your contacts. We may collect this information from our application, from credit card information, and from other social media platforms, such as your login credentials, your “real” name, profile picture, and other information that you share or your social network shares with you.
When you share content with our Services or any connected third-party source, whether inside or outside your company community, we may collect data about such posts including but not limited to, content, likes, views, comments, and other responses. We may collect the information you provide about others such as names, mailing address, email addresses, and phone numbers. We will use such information to provide our Services, link your account with us to your social networking account, or for anti-fraud purposes. Furthermore, information that you share through our Services could become collected and viewed by other members of the company community.
In certain jurisdictions, we may ask for a government issued ID in limited circumstances and when required by law, However, we do not currently conduct background checks or verify the identity of our Users.
We do not guarantee anything about the Services, including the actions of our users. We do not guarantee matches, the frequency of your matches, that you will be compatible with those you match with, or that the people you match with are safe people to meet. You must exercise your own diligence and caution in using the Services and communicating with its users.
How We Use Your Personal Information
The personal information we collect allows us to create a platform so Expats around the world can communicate and interact to help acclimate to life in a new environment. You can opt out at any time by deleting the application from your device. This will not delete previously collected data. Expat Buddy is a communication tool, any content you send to another user could be collected and stored by that user in another format. Any content you post publicly could be saved and stored in a different medium by a third party. We cannot control what a third party will do with the content you upload or a communication that you have with any other user or the public. If a third party copies or saves such content anywhere other than our system, we will not be able to access or delete that information. It is your sole responsibility to act prudently when posting content to or communicating through our Services.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content, and advertising, and for loss prevention and anti-fraud purposes.
We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate Services. For example, we may use date of birth to determine the age of our users, and we may use that information to deny access to Services to users that do not meet our minimum user requirements.
From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies. Because this information is important to your interaction with us, you may not opt out of receiving these communications. If you would like to unsubscribe to any other emails, follow the instructions at the bottom of each email and we will remove you from our subscribers list.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve our Services and customer communications. We may occasionally ask users of our Services to complete online surveys and opinion polls about their activities, attitudes, and interests. These surveys help us better serve you and improve the usefulness of the Services.
Our Services may allow you to use social media outlets to log in to your account or to share content with the social media outlet. The personal information a social media outlet has collected from you is obtained and maintained by them independently of our Services. Other Services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use.
You may be able to add or import your contacts from another device or program. When you import your contacts, we will ask you if you wish to invite your contacts. If you indicate that you would like to invite them, we will send them an invitation from you to activate an account and join the community.
We may share the information in your account, and user content you elect to share via the Services, with the social media outlets with whom you choose to share user content. By publishing user content to your social media outlet, you are allowing us to access your social media outlet account information and you are agreeing to the applicable social media outlet terms and conditions. Other than what we may share with a social media outlet in connection with your use of the Services, the personal information a social media outlet has collected from you is obtained and maintained by them independently of our Services. Other services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use.
If you email us through the website, we may ask you for additional information so we can respond to your questions and comments. If you choose to correspond with us via email, we may retain the content of your email messages, your email address, and our response to you. In certain cases, we may post content from your emails addressed to us.
Collection and Use of Non-Personal Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, general location, time zone, and other details, so that we can better understand user behavior and improve our Services and advertising.
We may collect and store details of how you use our Services. This information may be used to improve the relevancy of results provided by our Services. In limited instances, to ensure the quality of our Services over the Internet, such information could be associated with your IP address.
If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
Cookies and Other Technologies
You can choose to limit the transmission of this data in your account preferences, or via your web browser. If you do not accept cookies you may be unable to utilize the full functionality of the Services.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our Services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising.
Pixel tags enable us to send email messages in a format which customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
In some of our email messages, or as a feature of the Services, we use a “click-through URL” linked to content on our website or the website of third parties. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in email messages. If you click on another third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you.Disclosure to Third Parties
At times we may make certain personal information available to strategic partners that work with us to provide the Services, or that help us market to customers. Before sharing personal information with third parties we will take all reasonable measures to ensure that the third parties will abide by this policy.
At times we may make certain non-personal information available to third parties for reasons other than providing the Services. We may disclose non-personally identifiable aggregate statistics regarding user behavior as a measure of interest in, and use of, our Services to third parties in the form of aggregate data, such as overall patterns or demographic reports, which do not describe or identify any individual user. Information relating to aggregate statistics may be collected through the use of third-party cookies and other third-party tracking devices. We may share aggregated information that does not include personal information and we may otherwise disclose non-identifying Information and log data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your personal information.
We also use your personal information to provide, maintain, protect, and improve the Services, to authenticate you as a user, to communicate with you, and to assist you in using the Services. We may combine your personal information with non-personal information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services, and to analyze and understand how our Services are used. For example, we may use your personal information to provide you with a list of expats who share your interests, or whom we believe you are likely to enjoy their company and we may also use your personal information to add you to such lists for other users. We will not share, rent, or sell your personal information to other parties, except to our service providers as set forth below.
We may match information collected from you through different means or at different times, including both personal information and site usage information, and use such information along with information obtained from other sources, including (without limitation) any of our other websites and third parties. We may send you notices (for example, in the form of emails, mailings, and the like), and otherwise correspond with you about products, services, companies, events sponsored by us and others, and other information that we think might interest you.
We may share personal information with, agents, contractors, controllers, third party individuals and other companies to assist us in providing the Services, or who provide ancillary services such as information processing, extending credit, fulfilling customer orders, delivering products, managing and enhancing customer data, providing customer service, assessing customer interest in our products operation and maintenance of the Services, database management, web analytics, and improvement of the Services, and conducting customer research or satisfaction surveys. These third parties have access to your personal information and other information collected as set forth in this policy, only to perform these tasks on our behalf and are obligated not to disclose your personal information or use it for any other purpose. Said third parties may be located anywhere in the world. Furthermore, your private information may be transferred and processed in the United States of America or abroad.
Accountability for Onward Transfer
When transferring personal information to a third party acting as a controller, we must comply with the Notice and Choice Principles (“Principles”). We must also enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify us if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made, the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.
When transferring personal data to a third party acting as an agent, we must: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department of Commerce or its designated agent upon request.
ExpatBuddy shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless ExpatBuddy proves that it is not responsible for the event giving rise to the damage.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for us to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our property and rights and the rights of our suppliers, or other third parties, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Our organization and activities are subject to investigatory and enforcement powers of the Federal Trade Commission, the Department of Transportation, and the Department of Commerce, and we comply with the Fair Information Practices act, the CAN SPAM Act, and the California COPP Act. It may be possible, under certain conditions, for you to invoke binding arbitration under Annex I of the Privacy Shield Act. We adhere to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. Individuals must have enforceable rights against data users, and recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors. We have chosen to fully comply with the Data Protection Authorities, and you may utilize the International Centre for Dispute Resolution-American Arbitration Association to resolve any violation of the Privacy Shield Act.
Protection of Personal Information
We take the security of your personal information very seriously. Our online services protect your personal information during transit using encryption such as Secure Sockets Layer (SSL). When your personal data is stored by us, we use computer systems with limited access housed in facilities using physical security measures. We restrict access to personal information to those employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations. Data is stored in encrypted form including when we utilize third-party storage. All transactions are processed through a gateway provider and are not stored or processed on our servers.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting via the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement, or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. While we endeavor to protect the security and integrity of sensitive personal information provided to us, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be safe from intrusion by others. In the event of a data breach and consistent with the above, we will notify users over email within seven (7) business days after becoming aware of a data breach.
When you use some products, services, or applications or post on a forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a posting, that information is public. Please take care when using these features.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, login information, or national identification numbers in a non-secure or unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Integrity and Retention of Personal Information
Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by updating your account preferences. For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by email in the contact us page on our website.
Usage of the Services by Minors
We understand the importance of taking extra precautions to protect the privacy and safety of minors using our Services. Minors under the age of eighteen (18), or the equivalent minimum age in the relevant jurisdiction, are not permitted to create accounts. However, it is not possible for us to independently verify the age of our customers. It is the responsibility of every parent to monitor his or her child’s online activities. These Services are not directed to minors. We do not knowingly collect personal information from minors. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, please contact us. If we become aware that a minor has registered for the Services and has provided us with personal information, we will delete such information from our files.
To provide location-based services on our platform we, our partners, third-party servicers, and licensees may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. By accepting the terms and conditions you have consented to transmission of your location data. This location data is not anonymous, could personally identify you, and is used by us and our affiliates to provide and improve our Services.
Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, we may transfer said personal information to local or foreign processing centers and process it there.
In compliance with the Privacy Shield Principles, ExpatBuddy, Inc. commits to resolve complaints about our collection or use of your personal information. EU, Swiss, and British individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ExpatBuddy, Inc. at: [email protected]. ExpatBuddy, Inc. has further committed to cooperate with the panel established by the EU data protection authorities (“DPAs”) with regard to unresolved Privacy Shield complaints concerning data transferred from the European Union, the United Kingdom, and Switzerland.
We will also make reasonable efforts to abide by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System (CBPR). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.
Residents living outside the United States should investigate local privacy laws and are only licensed to use our products if our products are in compliance with local laws.
Our Company-Wide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company.
All such communications are examined, and replies are issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
You may contact us by email at [email protected].
Or by mail at: 13359 North Highway 183 STE 406-707 Austin, Texas 78750-7153.
California Privacy Rights
For users who are California residents, you have the following rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
- You have the right to request that we disclose certain information to you and explain how we have collected, used, and shared your personal information over the past 12 months.
- You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at [email protected].
From time to time we may disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing your email contact information with third parties (if we have your email contact information), you may notify us at [email protected]. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you choose to use a service or promotion that requires us to contact you or share your information with a third party, then your previous opt-out preferences will not apply to such service.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do track our users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual user’s online activities over time and across different online services when using the Services.
Removal of Content for Minors
We offer interactive services which allow you to post content to share publicly or with coworkers, friends, and family. At any time, you can delete or remove content you have posted using the deletion or removal options within our Services. If you have questions about how to remove content in a specific Service or if you would like additional assistance with deletion, you can contact our support team directly. Although we offer deletion capability for our Services, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the Services.