This Privacy and Cookies Policy (“Policy”) describes the personal information that Buzzle Ltd. (“Buzzle”, “our”, “we” or “us”) collects from or about you when you use our Services, or otherwise interact with us. It also describes how we use that information, and to whom we disclose it. As used in this Policy, “personal information” means information about an identified or identifiable individual and, in some jurisdictions, household. An identifiable individual is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. Personal information does not include general, statistical, anonymized or aggregated information, or any other information exempted under applicable privacy legislation. Capitalized terms used in this Policy that are not otherwise defined have the meanings ascribed to them in the Buzzle Terms of Service.
Please read this Policy carefully and contact us if you have any questions. By using our Services, other than to review this Policy and the Buzzle’s Terms of Service, or otherwise providing us with personal information, you will be deemed to have agreed to this Policy. If you do not agree with our collection, use or disclosure of your personal information in accordance with this Policy you should not access or use the Services or otherwise provide any personal information to us.
CALIFORNIA RESIDENTS: Alternate or additional terms may apply to you. Please also review the “Additional Information for California Consumers” set out at the end of this Policy.
1. Changes and Updates
This Policy was last updated on October, 22, 2024. Buzzle reserves the right to revise this Policy from time to time and, as such, you should review its terms each time that you visit our platform or otherwise use the Services. We will notify you about any significant changes in the way we handle personal information by sending a notice to the primary email address specified in your Account, by placing a prominent notice on the website or app, and/or by updating the privacy information on this page. Any changes to this Policy will not go into effect until at least five (5) days after they are posted or otherwise communicated to you. Your continued use of the Services signifies your acceptance of any changes to this Policy.
2. Accountability and Openness / Privacy Officer
Buzzle is responsible for personal information under our control, and we are accountable to you for our collection, use and disclosure for all personal information that you provide to us. We have established policies and procedures to safeguard any personal information that we have on file or that we collect, and to deal with complaints and inquiries. We will only collect, use and disclose personal information as described in this Policy.
Buzzle has designated a privacy officer (the “Privacy Officer”) who is accountable for the protection of data containing personal information, and for our compliance with this Policy.
If you have questions or concerns regarding this Policy, our compliance with it, as well as any of our processes and procedures relating to the collection, use and disclosure of your personal information, you may direct them in writing to the Privacy Officer at support@joinbuzzle.com or by mail to 103-2727 Steeles Ave W Toronto, Ontario M3J 3G9 Canada.
3. Collection of Personal Information
What Information is Collected and How?
We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information). In most cases, we will collect personal information directly from you when you use the Services, or otherwise interact with us. You may disclose as much or as little information as you would like. Personal information will always be collected using means that are transparent, fair and lawful.
A. Direct Collection
When you register for an Account, we may collect, use and disclose include your name, date of birth, email address, physical location and home address, as well as payment information and unique identifiers such as Account username, Account number and password. Other information that you may have the option to provide at the same time, but which is not required solely for the purpose of setting up your Account, includes such things as: marital status, whether you have children or pets, education level, income bracket, political preferences, religion, your interests and hobbies, credit scores, whether you own or rent a home, and the makes and years of any vehicles that you own. This information will only be collected when you voluntarily provide it to us.
With your prior consent, Buzzle will collect data about your online transactions, both through the use of the Buzzle app, and through filters on your Gmail account. The Buzzle app collects data in two ways: through screen capture or screen recording of your interactions on shopping apps, and by collecting internet search query, browsing and purchasing activities through URLs. We will only collect data that you permit us to collect. You will be asked to opt in and provide express consent for the types of information that you want to share, and you have the ability to opt out at any time.
We use the information that you provide to create a user profile, and license or sell the information in your profile to third parties Purchasers and, as set out in the Terms of Service, will share a portion of the revenue that we receive with you. It is up to you to decide, what information you want to share. The more data that you share, the more unique – and therefore valuable – it will be.
It is not our intention to collect financial information, social insurance numbers, SMS messages or phone numbers. Similarly, we do not intend to collect “personal health information” (PHI) as that term is defined in the US Heath Insurance Portability an Accountability Act (HIPPA), nor is Buzzle a health information custodian or agent (as defined in the Ontario Personal Health Information Protection Act), although in certain circumstances you may have the option of self-reporting general health-related information. If we inadvertently collect personal information about you which you have not previously provided us with consent to collect or use, we will either seek your consent for its use in accordance with this Policy,or destroy it.
If you provide comments or other Feedback to us regarding our Services, those comments or other feedback become the property of Buzzle and we may use, disclose and share them for any purpose provided that we do not associate them with your personal information without your express consent. (Please see our Terms of Service for further details regarding Buzzle’s use of any Feedback that you provide.)
B. Collection from Third Parties
Buzzle will collect information about your online transactions when you visit third party shopping apps, or query, browse or purchase through URLs. Buzzle does not purchase consumer lists, and will not otherwise collect personal information from a third party unless we receive assurance that all necessary consents have been obtained, or unless we are required or permitted to do so by applicable law. Any personal information collected from a third party will be used only for the purposes for which it was collected.
C. Information Collected Through Automated Means
Users may visit the Buzzle platform without telling us who they are or revealing any information about themselves. However, like many companies’ websites, our web server automatically logs certain information related to a user’s visit to the site, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the user’s location, the type and version of the browser that the user is using, the date and time the user accessed the site, the Internet address of the website from which the user linked directly to the Buzzle platform, the operating system that the user is using, the pages of the Buzzle site that the user has visited, and the user’s online browsing history. Unless required or permitted by law, we will not attempt to link this information with the identity of individuals visiting our platform unless we have consent to do so. We may, however, review server logs and traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving our Services, and to monitor and compile statistics about website usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.
Buzzle also uses, analytics, pixels and other technologies in order to improve our Service, your user experience, and to analyze how our website is used, in order to assist with our business and marketing. Information regarding these technologies, and the manner in which they are used to collect personal information. Your browser or device may include “Do Not Track” functionality. “Do Not Track” is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a standard for “Do Not Track” technology. No standard has been adopted to date. At this time, Buzzle does not respond to browser “Do Not Track” signals.
4. Consent
Consent for the collection, use or disclosure of personal information may be express or implied.
When you submit personal information to us for the purpose of opening an Account, we will seek your consent at the time of collection, and efforts will be made to ensure that you understand the purpose(s) for which the information will be used or disclosed.
The information that we collect from you through your use of the Buzzle app, and through filters on your Gmail account, is sold or licensed to Purchasers. In return, you will receive a share of the revenue as described in the Terms of Service. You will be asked to opt in and to provide express consent for the types of information that you want to share. You should not consent to sharing any personal information if you do not consent to Buzzle making that information available to Purchasers.
Purchasers use the personal information that they acquire from Buzzle for the purposes of marketing and advertising, including market studies, market research and direct marketing to you of goods and services that they believe may be of interest to you based upon the information in your profile. By agreeing that Buzzle may share your information with Purchasers, you consent to these uses of your personal information by Purchasers. If you do not agree, you should withhold or withdraw your consent to the sharing by Buzzle of your personal information. All Purchasers will be bound by written agreements with Buzzle restricting the use, protection and further disclosure of your personal information.
In certain circumstances, we might seek your consent regarding use or disclosure after the information has been collected, but before use, such as when Buzzle wishes to use personal information already in its possession for a purpose that was not previously identified.
Part of providing meaningful consent is understanding the risk of harm and other consequences of the disclosure of personal information. While we endeavour to continually use best practices to minimize the risk of harm (See: Safeguards – How Personal Information is Protected, below), technology is constantly evolving, and no safeguards can be guaranteed to be failsafe or to provide absolute protection against misfeasors. Significant harm that may result from the unauthorized use of the personal information that you disclose includes identity theft.
5. Withdrawal of consent
You may always choose not to disclose personal information. You will be asked to opt in and to provide express consent for the types of information that you want to share, and you have the ability to opt out at any time.
When Buzzle is already using personal information on the basis of your consent, you may withdraw or change that consent at any time. Note, however, that withdrawal of consent is forward looking. If you withdraw consent, Buzzle will stop all further use and sharing of your personal information. However, Buzzle may be unable to control the use of personal information that has already been licensed or sold to Purchasers in accordance with consent that you had previously provided.
To withdraw or change your consent to our use of your personal information, you may log on to your Account and opt-out or withdraw your consent to the sharing of your information. At any time, you may also delete your Account, which will result in all of the information that you have provided being purged from our system. You may also send your request in writing, along with details of the use of your information that you wish to change or withdraw your consent for, to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). Note that where our processing of your personal information is not based on your consent (but is based on another legal ground), we may not be able to comply with your request. We will endeavour to inform you of this in writing if this is the case.
In some circumstances, particularly where our use of certain personal information that you have provided to us is integral to your use of our Services, your refusal to provide consent, or to change or withdraw consent, may adversely affect your interactions with us and/or your ability to use our Services, and/or to receive compensation.
6. Purpose – Why We Collect, Use and Disclose Information
Except as specified below, will not use or disclose your personal information for any purpose other than the purpose(s) for which it was collected from you, without first obtaining your consent.
The information that we collect from you is used to create a detailed user profile. The information is then sold or licensed, at fair market value, to third party Purchasers, who use the information for marketing / market development and advertising purposes. Unlike when most other companies collect and sell your data, Buzzle will share a fair portion of the revenue from the sale or license of your information with you. Please review the Terms of Service for more information regarding the sale or licensing of your personal information.
Where personal information that has been collected is to be used for a purpose not previously identified, we will notify you of the new purpose and, where necessary, obtain your consent prior to the use of that information for the new purpose unless otherwise permitted by law.
7. Commercial Electronic Messages
Buzzle complies with Canadian “anti-spam” legislation and will only send electronic communications as permitted by law. We may send you email or SMS messages in connection with the Services. Note that you may always unsubscribe from our electronic communications by following the “unsubscribe” link clearly included in each communication, or by notifying the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). We will promptly comply with all “unsubscribe” requests.
You may receive electronic messages from a Purchaser or other third party to which we have provided your contact information in accordance with this Policy. If you do not wish to receive messages from those third parties, you will need to “unsubscribe” directly from those messages through communication with the third-party sender. Buzzle cannot control, and will not be liable for, a Purchaser’s or any other third party’s compliance with “unsubscribe” requests, or anti-spam legislation generally.
8. Disclosure to Third Parties
Except as specifically provided in this Policy or permitted by law, your personal information will not be shared with third parties unless we provide you with both prior notice and choice.
As previously described, Buzzle may sell or license the information that you consent to provide to us or allow us to collect through the use of the Buzzle app to third party Purchasers at fair market value.
Buzzle may also disclose your personal information to third party subcontractors and service providers in connection the operation of our business and the provision of the Services. Third party service providers to which we may disclose personal information include payment processors such as PayPal, login authentication services, analytical support services, web hosts, and parties that we engage to send out marketing materials. Given the nature of cloud services, personal information may be stored outside Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in the jurisdiction(s) where it is transferred or stored.
Prior to disclosing your information to third parties, Buzzle will have written contracts in place with those third parties to ensure that any personal information that you disclose or allow us to collect is protected, and is used only in accordance with this Policy and applicable laws. We may change or add service providers and Purchasers at any time, at our discretion. Details regarding the personal information that we make available to our third-party service providers and Purchasers, and how it is used, is available by contacting the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). Any request made by you to correct, change or erase personal information will be promptly communicated to third party services providers; however, for practical reasons, Buzzle may not be able to ensure that any personal information previously made available to Purchasers based upon your consent can be corrected, charged or erased.
We may collect, use or disclose personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request, request of a law enforcement agency, search warrant, subpoena or court order, or based upon our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to enforce our rights or to protect our assets, you or other users of the Services, or the public.
We may transfer to another entity, or its affiliates or third party data processors, some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. In each such case, Buzzle and the other part(ies) to the transaction or proposed transaction will enter into a written agreement limiting the period and purposes for which your personal information may be used and disclosed.
9. Retention of Personal Information
Subject to any legal or accounting requirements, we will retain personal information only as long as your Account is active, or as necessary to fulfill the purposes for which the information was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media. Your Account may, at our discretion, be deleted if you have not launched the Buzzle app at least once during any six (6) month period. In certain circumstances, you may request the erasure of the personal information that you have provided to us, which we will endeavor to do without undue delay as required by applicable law. While we will communicate any change or request for deletion to third party Purchasers, for practical reasons, we are unable to guarantee the deletion of your information after it has been provided to Purchasers. For that reason, you should carefully consider what information you choose to provide. Buzzle expressly disclaims responsibility for the acts or omissions of third-party Purchasers.
You may delete certain information from your Account by logging into your Account and changing the approved permissions. Written requests for the erasure of information may be sent to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information.
Once personal information has been destroyed, erased or anonymized, any rights regarding access to that information, erasure, rectification and data portability cannot be enforced.
10. Safeguards – How Personal Information is Protected
We have implemented physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive information.
Our data systems use user IDs and passwords, and we will only store data on remote servers hosted by reputable companies in Canada/North America. Staff and contractors who have access to personal information are bound by confidentiality obligations to ensure that information is handled and stored in a confidential and secure manner. Any payment information that you submit will not be stored on our servers, but rather will be sent to PayPal or another PCI Level 1-compliant payment processor for storage. Personal information that is transmitted to other sites, including data sent to Purchasers, is protected through the use of encryption. When destroying personal information, we delete electronically stored personal information and shred any physical materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal information may involve the transmission of data on an international basis and across networks not owned and/or controlled by Buzzle. Accordingly, we cannot guarantee that personal information will not be lost, or that it will not be altered, intercepted or stored by an unauthorized third party.
In the event of a security breach concerning personal information, we will endeavour to notify affected individuals promptly upon discovering the breach, as required by applicable law. In any event, if a breach is likely to affect the rights and freedoms of the affected individual, we will ensure that the notification is made without undue delay.
11. Individual Access / Accuracy / Destruction
We will endeavour to ensure that personal information contained in our records, or which is disclosed to third parties for the purposes described above will be as accurate, complete and up-to-date as is necessary for the purposes for which it is used. You may access the personal information that we hold about you through the Buzzle app. or by submitting a written request to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). Including “Request personal information” in the subject line of your email or letter will facilitate compliance with your request. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information You may also be entitled to receive a copy of your personal information in a structured, commonly-used, machine-readable format (or request that this be transferred to a third party where technically possible). In certain circumstances, Buzzle may not be able to provide you with access to all or some of your personal information, in which case you will be advised in writing of the reasons for our inability to provide you with the information.
You also have the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect. You will be able to correct or update certain information through your Account]. In other cases, we will amend the information provided that you advise us in writing as to the inaccuracy or incompleteness and provide satisfactory proof of your identity. Notices and requests regarding inaccuracies or changes can be sent to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer).
In certain circumstances, you have the right to require that we erase, limit and/or cease processing your personal information. You may also delete your Account at any time. All notices and requests asking us to erase, limit or stop processing your personal information should either be processed directly through your Account, or made via request in writing sent to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer).
12. Links to other Websites
To the extent our platform contains links to other websites, the owners of those websites are responsible for the privacy practices and content for their sites. If you click on those links, you will leave the Buzzle website, and third parties may collect personal information from you or your electronic devices. The accessing and use of any third party websites is at your own risk. Buzzle does not provide or endorse any information, goods or services available through third party websites, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites. This Policy applies only to the Buzzle Services, and we encourage you to review the privacy policies contained on each Internet site that you access.
13. International Transfer and Storage of Information
Buzzle is based in Canada, however, given the nature of the Internet and cloud services, personal information may be transmitted, transferred, processed, backed-up and/or stored outside of Canada, including in the United States. In particular, certain of the third parties to which we disclose your personal information (see: Disclosure to Third Parties) may use and store that information at their facilities outside of Canada. We will use reasonable means to ensure that your information is only used in accordance with this Policy and the Terms of Use, including written agreements with the third parties to which we disclose your information, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada, or that your personal information will not be accessible to foreign courts, law enforcement or national security authorities in the jurisdiction(s) where it is transferred or stored.
14. Minors
Our Services are intended solely for users who are aged 16 or older. Buzzle will never knowingly collect personal information from persons under the age of 16. If we are advised or otherwise discover that personal information has been collected from someone under the age of 16 without the express consent of a parent or guardian, we will take all commercially reasonable steps to delete that information.
15. Compliance and Governing Law
Inquiries, requests and complaints regarding our compliance with this Policy should be directed to the Privacy Officer (see: Accountability and Openness / Privacy Officer). Complaints may also be made to the Privacy Commissioner of Canada. If you are entitled to data protection rights under the laws of other jurisdictions, such as the laws in European Union countries the law of the United Kingdom or Switzerland, or the laws of California, you may also be entitled to lodge a complaint with the relevant supervisory authority that deals with data protection matters in your jurisdiction.
Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual.
The Buzzle platform is operated from Guelph, Ontario, Canada. Except as required by applicable privacy laws, your use of the Services, this Policy and the protection of your personal information will be governed exclusively by the applicable laws of the Province of Ontario and of Canada. Additional rights may apply to users in other jurisdictions as required by applicable law.
ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS:
This section applies to consumers residing in the State of California, USA, in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”), as amended, and its implementing regulations. For such persons, this information supersedes any divergent or conflicting information elsewhere in this Policy.
Your Privacy Rights under the CCPA. The CCPA provides certain specific rights:
You also have the right to know what personal information we sell or share, and to whom. In particular, you have the right to request two separate lists from us where we disclose:
The disclosures described above will be limited to the personal information collected or used by Buzzle in the preceding 12 month period.
How to Exercise Your Rights
You may access or delete certain information, and opt-out of the selling or sharing of your information, directly through your Account. Alternatively, you may contact the Privacy Officer using the contact information set out above (see: Accountability and Openness / Privacy Officer). Your request must: (a) provide sufficient information that allows Buzzle to reasonably verify you are the person about whom we collected personal information (or an authorized representative); and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
Shine the Light Law
California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, entitles California residents to request certain information regarding Buzzle’s disclosure of personal information to third parties for their direct marketing purposes. Any inquiries regarding personal information sharing with third parties may be directed to our Chief Privacy Officer using the contact information above (see: Accountability and Openness / Privacy Officer).
OTHER US JURISDICTIONS
Consumer Health Data. If you are resident in certain US jurisdictions, you have certain additional rights pertaining to your consumer health data. These include the right to withdraw your consent to processing, to request the deletion of your consumer health data, and to confirm whether Buzzle collects, shares, or sells your consumer health data. To exercise these rights, you withdraw alter your rights through your Account or you may contact the Privacy Officer in writing using the contact information set out above (see: Accountability and Openness / Privacy Officer). When you contact us, please identify yourself and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Note that only you may make a request regarding your consumer health data, and Buzzle will verify your identity before processing any request.
We’re just four friends with different tech backgrounds who discovered something surprising – big tech companies make a lot from your phone data, but you don’t get a share. That didn’t sit right with us, so we created Buzzle. Inspired by bees working together, our goal is simple: we want Buzzle to work for you, so everyone can benefit, not just the big guys. buzzle is for all of us!
