Privacy Policy

JOYBOT Privacy Policy

Your privacy is important to us. This Privacy Policy ("Policy") applies to services provided by Bula Labs, Inc. ("we", "us", or "Company") and our website, product pages, web applications, mobile application (the "Mobile App") or other digital products that link to or reference this Policy (collectively, the "Services") and explains what information we collect from users of our Services (a "user", "you", or "your"), including information that may be used to personally identify you ("Personal Information") and how we use it. We encourage you to read the details below.

We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by posting a new Policy to this page, and/or by sending notice to the primary email address specified in your account. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically reviewing this Policy to check for any changes. Changes to this Policy are effective when they are posted on this page. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy.

Scope and Applicability

The Policy applies to your information when you visit our website or otherwise use the Services. The Services may recommend products provided by third party suppliers and/or may contain links to other websites. This Privacy Policy does not apply to such third party websites or links. We have no control over those websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites. By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites.

What Information Do We Collect?

Information You Provide to Us

• Account Information. To create an account for the Services or to enable certain features, we may require that you provide us with information for your account such as name, email, password, and authentication credentials.
• Content. We collect any content that you provide, transmit or upload to the Services, including any documentation, files, text messages, emails, calendar events, photos, contact information, preferences, inputs and prompts, or any other information, which may include information about you or your intended gift recipients.
• Location. We may ask you to share your location so that we can set language and region preferences and apply geographic limitations. We may also use this information to personalize gifts.
• Other Information You Provide. We receive other information from you when you choose to interact with us in other ways, such as your interactions on the site or if you sign up for one of our webinars or newsletters, participate in a research study or event, or otherwise communicate with us. Our site also personalizes gift recommendations based on how you interact with gift ideas (e.g. viewing, clicking, favoriting, voting up/down).
• Business Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.

Information We Collect Automatically

When you visit, use, and interact with the Services, we may receive the following information about your visit, use, or interactions ("Technical Information"):

• Log Data. Information that your browser automatically sends whenever you use our website ("log data"). Log data includes your internet protocol address, browser type and settings, the date and time of your request, and how you interacted with our website.
• Usage Data. We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, computer connection, IP address, and the like.
• Device Information. Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Analytics. We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

We use cookies and other tracking technologies to help us collect and process Technical Information. Please see the "How Do We Use Tracking Technologies" section below for more information.

Information We Receive from Third Party Sources

• Giftee Information. We may collect additional personal information about gift recipients that you have identified, from publicly available sources, social media posts and profiles, search engine results, as well as third-party data providers, and combine this information to formulate and improve gift recommendations. This may include, for example:
  • Name, age, and gender of the gift recipient.
  • Information about the gift recipient's lifestyle, interests and preferred brands.
  • Information about the gift recipient's education history and employment status.
  • Photos, videos and other content that include the gift recipient.
  • Information the gift recipient has made publicly available.
• Social Networks and Advertising Providers. We may receive information from our social network and advertising providers, including to help us identify or enrich our understanding of prospective customers, and to serve and measure advertising.
• Joint Marketing, Business Partnership, Referral Partners. We may receive your contact information from partners that we engage for joint marketing activities and our referrals programs.
• Information from Other Sources. We may obtain information from other sources, including, but not limited to, publicly available sources, brand partnerships, and third-party integrations you consent to, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you.

How Do We Use The Information We Collect?

We use the information we collect:

• To deliver and improve the Services and your overall user experience.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• To link or combine user information with other Personal Information.
• To develop, improve or expand our business, products and services.
• To conduct internal reporting, auditing, and research, including focus groups and surveys.
• To compare and verify information for accuracy and update our records.
• To email, message, or otherwise contact you with information and updates about us and the Services.
• To respond to your comments and questions and provide customer service.
• To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• To analyze how you use the Services with analytics and other tools to help us understand traffic patterns and know if there are problems with the Services.
• To combine information with other data we already have to improve your experience with our Services or inform you of products and services we think may be of interest to you
• Create targeted advertising to promote the Services and engage our users.
• In connection with a merger, acquisition, reorganization or similar transaction.
• When required by law or to respond to legal process.
• To protect our users, other individual lives, and/or the rights or property of Company.
• To maintain the security of the Services.
• At your direction or instruction, or for any other purpose with your consent.

Do We Share Your Personal Information?

In addition to the specific situations discussed elsewhere in this privacy policy, we may disclose personal information in the following circumstances:

• With our corporate affiliates and subsidiaries.
• With gift suppliers and fulfillment partners.
• With third parties that perform services to support our core business functions and internal operations, which may include database administrators, cloud computing services, payment processors, advertising services, and application services providers.
• With third parties that we have partnered with, such as to jointly create and offer a product, service or joint promotion, or in connection with facilitating referral partnerships.
• To support our audit, compliance, and corporate governance functions.
• In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy).
• If we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect, protect against or investigate fraud or security issues.
• If required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Company may do business; (b) protect and defend the rights or property of Company; (c) act in urgent circumstances to protect the personal safety of users, customers, and contractors/employees of Company or others; or (d) enforce our Terms of Service or otherwise protect against any legal liability.
• With your consent or at your direction.

How Do We Use Tracking Technologies?

Some of the features on the Services may require the use of "cookies" - small text files that are stored on your device's hard drive. We use Cookies to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to remember your preferences, analyze trends, learn about our user base, provide relevant advertising, and operate and improve our Services. We may supplement the information we collect from you with information received from third parties, including information collected using third party cookies. You may delete and block all cookies from our Services, but parts of the Services may not work or your overall user experience may be diminished, since it will no longer be personalized to you. It may also prevent you from saving customized settings, like log-in information.

We want to be open about our cookie use. The following sets out how we may use different categories of cookies and your options for managing cookie settings:

In addition to cookies, we may use other tracking technologies:

• Log Files, which are files that record events that occur in connection with your use of technology services, including the Services.
• Pixels (also known as web beacons), which are code embedded in a website, email, application or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access technology that contains a pixel, the pixel may permit us or a separate entity to track your interactions. We may incorporate pixels from separate entities that allow us to track our conversions, bring you advertising, and provide you with additional functionality.
• Session Replay Technologies, which may be used to collect information regarding visitor behavior on the Services. This helps us understand how users are using our Services and improve the user experience.

Analytics and Interest-Based Advertising

Our third party analytics services providers and advertising providers may use cookies and other tracking technologies to collect and store data Technical Information to be used for the purposes outlined in this Privacy Policy. We may use analytics services to help us understand how users access and use the Services and other aspects of our products and services.

In addition, we may work with agencies, advertisers, ad networks, and other technology services to place advertisements on our behalf on other websites and services. Our third-party advertising service providers may use web beacons to recognize you when you visit the Services and to help determine how you found the Services. They may also use cookies, action tags, web beacons, and/or GIF tags placed in various places on the Services and our online ads to collect information about your visit and your interaction with our ads.

To limit collection of information from mobile devices, including location data, please visit your device's settings to set the "Limit Ad Track", "Location Based Services," or other similar feature on your device. You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the NAI https://optout.networkadvertising.org/ or DAA https://optout.aboutads.info/. If you opt-out of interest-based ads, you will still see ads on websites you visit, but those ads will not be based on your browsing behavior.

How Do We Secure Your Personal Information?

We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

The safety and security of your Personal Information also depends on you. If you have an account with us, you are responsible for keeping your membership details confidential. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using the Services, you acknowledge that you understand and agree to assume these risks.

Data Retention

We retain your Personal Information while your account is in existence or as needed to provide the Services to you. This includes data you or others provided to us and data generated or inferred from your use of the Services. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Managing Your Privacy

All users may request to review, update, correct or delete the Personal Information furnished by a user in their user account by accessing your account settings or contacting us at support@joy.bot. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account may become deactivated.

If you wish to cancel your account, you may do so by contacting us at support@joy.bot or through your account page, and any personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law.

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Company features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language) in those communications. Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our terms of service or privacy policy.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor's browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit https://www.allaboutdnt.com.

Children Under 16

The Services are not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at support@joy.bot and the information will be deleted.

Contact Us

If you have any questions about this Policy, your Personal Information, or the Services, you can contact support@joy.bot.

Region-Specific Disclosures:

A Note to California Residents

If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to us at our designated address and receive the following information: (a) the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.

To make such a request, please contact us at support@joy.bot.

A Note to California and other U.S. Residents

Some U.S. state privacy laws require specific disclosures. Please see below for additional information about the categories of personal information that we collect and how we use and disclose that information. You can read more about the personal information we collect and where we collect it from in the "What Information Do We Collect" section above, how we use personal information in the "How Do We Use The Information We Collect?" section above, and how we retain personal data in the "Data Retention" section above.

• We collect the following categories of information: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
• The sources of personal information from whom we collected are: directly from our users, third-party data providers, publicly available sources, social media profiles and posts, search engine results, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.
• The business and commercial purpose of collecting personal information are as summarized in our "How Do We Use The Information We Collect?" section.
• We disclosed certain data elements within the following categories of personal information for a business purpose: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to business partners, service providers, government entities, and other third parties as described in the "How Do We Share Your Information" section.

Depending on where you live and subject to applicable exceptions, you may have the following privacy rights in relation to your personal information:

• The right to know information about our processing of your personal information, including the right to access your personal information, often in a portable format;
• The right to request deletion of your personal information;
• The right to correct your personal information; and
• The right to be free from discrimination relating to the exercise of any of your privacy rights.

Exercising Your Rights. You can exercise privacy rights described in this section by submitting a request to support@joy.bot.

Verification. In order to protect your personal information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete personal information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal information for verification. If we cannot verify your identity, we will not be able to honor your request.

Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us. Authorized agent requests can be submitted support@joy.bot.

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights. To appeal a decision, please send your request to support@joy.bot.

A Note to Users Outside the United States

Our Company is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the laws of the country(ies) where the Services are controlled. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

A Note to European Residents

We typically will process your information pursuant to the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; or (3) as necessary for our legitimate interests. We also may process your information where it is necessary to comply with a legal obligation to which we are subject. The laws of certain jurisdictions may provide data subjects with various rights in connection with the processing of Personal Information, including:

1. The right to withdraw any previously provided consent;
2. The right to access certain information about you that we process;
3. The right to have us correct or update any personal information;
4. The right to have certain personal information erased;
5. The right to have us temporarily block our processing of certain personal information;
6. The right to have personal information exported into common machine-readable format;
7. The right to object to our processing of personal information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and
8. The right to lodge a complaint with the appropriate data protection authority.

Where we are deemed a data controller under the laws of certain jurisdictions, we will take steps to help ensure that you are able to exercise your rights regarding Personal Information about you in accordance with applicable law. To do so, you may contact us at support@joy.bot. Please note these rights may be limited in certain circumstances as provided by applicable law. We will promptly review all such requests in accordance with applicable laws. Depending on where you live, you may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at support@joy.bot, so we have an opportunity to address your concerns directly before you do so.