Last updated: August 18, 2016
By using or accessing the Platform or the Website, You acknowledge and accept the practices described in this Policy. We reserve the right to change this Policy from time to time. Your continued use of the Button Platform constitutes your acceptance of the Policy then in effect. For this reason, you should review the Policy from time to time to ensure that you understand and are willing to accept our current privacy practices.
Button collects Personally Identifiable Information (“PII”) from the Website when Users choose to provide it to us. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, or email address. For example, you may choose to send PII about yourself in an email, by completing a form on the Website, or by registering to be a Button Client. Button uses this information to contact you to respond to your inquiry or to service your account. Once collected, Button will store your PII for a reasonable time for record keeping purposes.
Button also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to the Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system.
Button offers a Platform that enables smart connections between mobile apps that drive installs, increase engagement and facilitate mobile commerce. Our Clients install code in their mobile app SDK that enables our Platform to function, and for Button to provide our Services. The smart connections are facilitated via a deep linking technology that offers the ability to pass User data from one mobile app to another – even through the app install process. Deep linking technology enables Button to recognize a mobile device over time within a reasonable level of statistical certainty. Mobile application developers (our “Clients”) use the Platform to enable people who use the Internet (“Users”) to leverage functionality across multiple mobile apps. Our Services are designed to help our Clients leverage cross-app functionality for the benefit of Users.
Our Platform is enabled on mobile apps where a Client chooses to install our SDK. We collect information from Users that download and use apps with Button’s SDK installed. This information includes:
Device Information. We collect information about the computer or mobile device such as your hardware model, operating system version, unique device identifiers, IP addresses and the mobile platform advertising identifiers (e.g., IDFA or Android ID) and our own pseudonymous Button identifier. We use this information to help recognize your computer or mobile device over time. We may also use persistent cookies to help us collect or store this information. Depending upon the mobile operating system that you use, we are able to see some or all of the other mobile apps downloaded onto your device. This information is generally considered non-personally identifiable in most jurisdictions.
Location Information. We may collect and process the precise location of the computer or device you are using such as the lat/long. We obtain your permission or obtain reasonable assurances from our Clients that they have your permission to use this information. We use this information to enable the Services to function properly. For example, if you are using an app to make a dinner reservation, you may want the Services to enable another app to book transportation to the restaurant. In this example, Button obtains the precise location of your computer or device and shares that information with a car service app in order to help you arrange transportation. Our Clients’ use of this information is subject to their privacy policies, not Button’s.
User Rewards Program Information. We may collect PII such as email address to administer the Button Rewards Program as described in our Terms of Service.
Client Information. We allow Clients to pass information to Button to facilitate the sharing of information from one app to another, including account ID’s, email addresses and telephone numbers of their registered Users. This information is intended to facilitate cross-app functionality that is initiated by Users, and to customize each User’s experience on Client apps. We ask Clients not to send or facilitate the sending of credit card information, passwords or other sensitive information via the Platform. We require that our Clients utilize our Service responsibly and in accordance with applicable law. Our Clients’ use of this information is subject to their privacy policies, not Button’s.
In addition to using information collected via the Website, Platform and Services as described above, Button reserves the right to use information in our possession to fulfill Clients’ and prospective Clients’ requests for the Services or for information about the Services, or to improve our Website, Platform and Services. In addition, we may use this information, combined with information we receive from third-party partners, for the purposes of performing analytics and conducting consumer research.
Button may also utilize information collected via the Website or the Service to better understand how Users come to download certain mobile Apps, what types of Apps are popular, what characteristics Users of certain Apps may have in common, and the connections between Users’ devices.
In addition to the uses described above, we reserve the right to share and transfer information under the following circumstances:
We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
If we enter into a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, we may sell, transfer, assign or license some or all of our assets to a third party, which assets may include information that we have collected.
We authorize access to information only for those employees, contractors and agents who need to know that information in order to operate, develop or improve our Website, Platform and Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Button is potentially liable.
We may aggregate data and share it without restriction. This data, when shared on an aggregated basis, does not include any PII. In addition, we may disclose information when we have reason to believe that disclosing such information is necessary to comply with legal and regulatory requirements, including any investigations, subpoenas and other legal processes, and/or to identify, contact or bring legal action against someone who is violating the law or that may be causing injury to or interference with Button’s rights or property, other Users or anyone else that could be harmed by such activities.
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
We do not knowingly collect any PII from, persons under the age of thirteen (13). If you are under the age of 13, you may not register an account with us or be a Client. If we learn that someone under the age of thirteen has provided their PII to Button, we will take reasonable steps to remove that User’s information from the database and restrict that User from future access to Our Services.
We take reasonable security precautions — including technical, administrative and physical measures — to safeguard the information in our systems. We use technical safeguards such as firewalls and Secure Socket Layer (SSL) / Transport Layer Security (TLS) encryption, and the PII we store is located on a secured server behind a firewall. We also enforce physical access controls to our buildings and files. No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while Button strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security.
We store PII such as email address or billing details so long as you continue to have a business relationship with Button and then for a reasonable time thereafter. You may ask us to delete that information by following the instructions below. Button stores certain Non-PII collected via our Services such as a User’s pseudonymous ID (e.g., cookie ID, IFA, IP address, collectively, a “User ID”) so long as our systems continue to encounter that User ID. We remove the User ID within two years after our last encounter with that User ID. After a User ID is removed, Button may store the de-identified data set for up to five years.
We acknowledge the right of users to access, update, edit, or delete their personal information. We provide Clients and Users with a mechanism to update their information. If you would like to purge any and all data about you from our records, you may do so by making a request to email@example.com. We will use commercially reasonable efforts to honor your request. Please note that purging your data may have a negative impact on our ability to offers services to you. For example, if you’re a Client, purging your data means we will no longer be able to provide you with our Services. If you’re a User, purging your data means you will automatically lose all of your accrued your Button Rewards Points balance because those points will be deleted from the Button Platform. Please note that we may retain an archived copy of any information as required by applicable law.
You may opt-out of receiving promotional emails from us by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as certain updates about your account and/or use of the Services.
We may change this Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy's effective date. If you have any questions or suggestions regarding this Policy, please contact us at:
Attn: Privacy Officer
220 E 23rd St, Penthouse
New York, NY 10010
Button has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with Privacy Shield.
Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
Button has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.