Last updated: September 15, 2020
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 and Website, as applicable, 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.
EEA Individuals: Natural persons located in the European Economic Area (“EEA”) should review the General Data Protection Regulation (“GDPR”) privacy notice for their specific rights, remedies, and other GDPR/Privacy Shield-related information here.
Collection & Use of Info: Website
Button collects Personally Identifiable Information (“PII”) from the Website when Site Visitors 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 only 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 online identifiers and associated metadata (“Metadata”) from Site Visitors. Metadata is information that often cannot by itself be used to identify a particular person or entity but may still be considered PII in certain jurisdictions, 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.
Collection & Use of Info: Platform
Button offers a Platform that enables smart connections between mobile apps that drive installs, increase engagement, and facilitates mobile commerce. Our Clients install code (the “SDK”) in their mobile app or website 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 for Clients, and Button (on Clients’ behalf), to collect and 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. Our Services are designed to help our Clients leverage cross-app and cross-site 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 use apps and websites where Button’s SDK is installed.
Keep in mind that Button collects and uses this information on behalf of its Clients. This information includes:
Computer, Mobile Device and Browser Information. We collect information about the computer or mobile device such as User’s hardware model, browser 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 the User’s 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 the User’s device.
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 (as Button process such data on Client’s behalf).
User Rewards Program Information. We may collect PII such as email address to administer the Technology as described in our Terms of Service.
Information Obtained By Client. 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 (such as by creating User segments on behalf of our Clients). 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.
Info Sharing, Onward Transfer
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 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 under “Your Choices” 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.
IV. Your Choices
Changing or Deleting Your Information
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 firstname.lastname@example.org. 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. Please note that we may retain an archived copy of any information as required by applicable law.
Opt-out from Promotional Emails
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 provide links to instructions for both Apple iOS and Android device
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: Data Protection Officer
PO Box 8176
Greenwich, CT 06836-8021