Privacy Policy

Introduction

Last updated: March 21, 2024

Button, Inc. (“Button”, “we”, “us”, or“our”) is a technology company. We offer a technology platform (our “Platform”) that enables companies to drive higher value from their traffic through optimizing user experiences as required by contract for the remittance and accounting of e-commerce fees while facilitating the mitigation of fraud in a privacy-first method. Brands, publishers, and creators (our “Clients”) use the Platform to enable people who use the Internet (“Users”) to optimize functionality across multiple properties. This privacy policy ("Policy") explains how information is collected and used pursuant to offering our products and services (the "Button Services" or“Services”). This Policy also explains how information is collected and used when people visit (“Site Visitors”) our corporate website located at usebutton.com (the “Corporate Website”). Collectively, Site Visitors, Clients, and Users will be referred to as “You”(or “Your”).

By using or accessing the Platform or the Corporate Website, You acknowledge and accept the practices described in thisPolicy. We reserve the right to modify this Policy from time to time; updates will be published on the Corporate Website. Your continued use of the ButtonPlatform and Corporate 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-related information at usebutton.com/gdpr-notice.

Collection & Use of Info: Corporate Website

Contact Information

In the course of delivering our services, Button may collect Personally Identifiable Information (“PII”) from the Corporate 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 may include, but is not necessarily 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 Corporate Website, or by registering to be aButton Client. Button uses this information only to contact You to respond toYour inquiry or to service Your account. Once collected, Button will store YourPII for a reasonable time for record-keeping purposes and/or to fulfill any request you make.

Metadata

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 the Corporate Website, the referring URL, and Your computer’s operating system.

Cookies

The Corporate Website uses cookies in order to help manage our relationship with Site Visitors. For more information about cookies, please visit https://www.allaboutcookies.org/cookies.

Collection & Use of Info: Platform

Overview: Platform

Button offers a Platform that enables companies to drive higher value from their traffic through optimizing user experiences as required by contract for the remittance and accounting of e-commerce fees while facilitating the mitigation of fraud in a privacy-first method.

Certain of our Clients install code (the“SDK”) in their mobile app or website while others  provide their users with Button links from their mobile app, website, or social media profile. Smart connections are facilitated via a deep linking technology which utilizes machine learning technology to intelligently route users to a certain variation of their destination according to a number of factors to enable companies to drive higher value from their traffic through optimizing user experiences.

In fulfilling its services to Clients,Button collects and uses certain data on behalf of such Clients. This information may include:

Computer, Mobile Device and Browser Information. We utilize certain information about Users’ computer or mobile device such as hardware model, browser model, operating system version, unique device identifiers, IP addresses and, only if affirmatively provided, the mobile platform advertising identifiers, 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; please see more information on Button’s use of cookies below. Depending upon the mobile operating system that You use, we may be able to see those mobile apps downloaded onto the User’s device which are relevant to a user action.

Location Information. We may collect and process the location of the computer or device You are using such as latitude/longitude. 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 and to provide geographically-relevant services or offers, where applicable.

Information Obtained By Client.Clients may choose to pass certain information to Button, including accountID’s, email addresses, and telephone numbers of their registered Users. This information is intended to optimize the User’s experience and to customize each User’s experience on Client apps (such as by creating User segments on behalf of our Clients) but is not passed from one Client to another; instead, any such information is associated with an anonymized Button identifier.  We require Clients not to send or facilitate the sending of credit card information, passwords, or other sensitive information via the Platform. Button stores only what is required to facilitate the Services and any such data is securely stored in a format that cannot be used to track Users’ activities across Clients or target Users for products, offers, or advertisements from other Clients. We require that our Clients utilize our Service responsibly and in accordance with applicable law.

Cookie Collection Policy

Button uses cookies to optimize our product offering and to provide users with a better experience, for example, to maintain your preferences and to monitor and improve performance of the Platform. Cookies are small pieces of text that are sent to a browser, which provides the pieces of text to the originating server when a User returns so that we can respond accordingly. Such cookies may be either “first-party cookies” (set by us) or“third-party cookies” (set by third-party providers) with which we work.  

We use the following types of cookies on our Platform:

●     Strictly Necessary Cookies: These cookies are necessary for the functioning of the Platform; the Platform would not work properly without these cookies. They allow the Platform to properly attribute transactions, deliver experiences to Users, keep Users logged into the Platform when necessary, and enable accurate reporting for Clients.

●     Statistic Cookies: These cookies help us understand howUsers interact with the Platform by collecting and reporting information anonymously.

The use of cookies on the Platform varies depending on the specific use case. By continuing to use the Platform, you consent to Button’s collection of cookies. To opt out of the use of cookies (other than Strictly Necessary Cookies, which are necessary for the functioning of the Platform), email privacy@usebutton.com.

Info Sharing, Onward Transfer

In addition to the uses described above, we reserve the right to share and transfer information under the following circumstances:

To develop, offer, and deliver our Corporate Website, Platform and Services (such as offering new or improved Button products and services or products and services of our Clients through the Platform, as described above); To conduct market research, project planning, troubleshoot problems, detect and protect against error, fraud or other criminal activity, to enforce Our terms of use and for other purposes, as otherwise set forth in this Policy and as otherwise authorized by You.

We may be required to disclose an individual’s PII 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 Corporate Website, Platform, and Services in accordance with this Privacy Policy. 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. Button also employs technical protections, including role-based access, to ensure that only those individuals who need information to fulfill tasks inherent with their role are provided with such access.

We may de-identify and aggregate data such that it does not constitute or include any PII and share it without restriction. 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.

Data Integrity

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.

Age Restriction

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 13 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.

Security

We employ reasonable industry-standard 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 securely stored 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.

Data Retention

We may store PII such as email address or billing details so long as You continue to have a business relationship with Button or with one of Button’s Clients 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 indefinitely.

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 privacy@usebutton.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 offer services to You. 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.

Questions and Changes to this Privacy Policy

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
Button, Inc.
PO Box 8176
PMB 90775
Greenwich, CT 06836-8021