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Privacy Policy

VanGoux Inc. ("Bubbles", “our”, “us” or “we”), respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”).

Please read this Privacy Policy carefully to understand how Bubbles uses and protects the information that we collect from visitors to our website at usebubbles.com, all other websites owned and operated by Bubbles that redirect to usebubbles.com and all subdomains of usebubbles.com (collectively, the “Bubbles Site”) the users (“Users”) of the Bubbles Properties (as defined below), and viewers of our Users’ videos, screenshots, and links (“Viewers”).

This Privacy Policy applies to information collected by Bubbles through the Bubbles Site, any Bubbles computer software downloadable or otherwise available from the Bubbles Site ("Bubbles Software") and any Bubbles services purchased or otherwise made available from the Bubbles Site ("Bubbles Services") (collectively, the "Bubbles Properties").This Privacy Policy does not apply to the practices of any third party websites, applications or services that Bubbles does not own or maintain (collectively, “Third Party Services”) or to any third parties that use the Bubbles Application Programming Interface (API) to perform any function related to the Bubbles Properties (“Integrated Platforms”). In particular, this Privacy Policy does not cover any information or other content you can view via the Bubbles Properties on Integrated Platforms or information you provide to Third Party Services accessed via the Bubbles Properties. As further detailed below, we cannot take responsibility for the content or privacy policies of any Third Party Services. If you are a Viewer we encourage you to carefully review the privacy policies of the Bubbles User whose Content you view and the privacy policies of any Integrated Platforms or Third Party Services used by such User which you may access via the Bubbles Properties.

This Privacy Policy also does not cover any information, recorded in any form, about more than one individual where the identity of the individuals is not known and cannot be inferred from the information (“Aggregated Information”). Bubbles retains the right to use Aggregated Information in any way that it reasonably determines is appropriate.

By using a Service or otherwise providing us with your Personal Information (as defined below), you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time, and agreeing to our collection and use of your information in accordance with this Privacy Policy. If you do not agree to the collection, use and disclosure of your information in this way, please do not use any of the Bubbles Properties or otherwise provide Bubbles with Personal Information.

Please refer to our Privacy Overview at https://www.usebubbles.com/privacy for additional details regarding how Bubbles Properties may use your information, including Bubbles’ use of certain applications and platforms operated by Third Party Services, and how you may export your data.

WHAT INFORMATION BUBBLES COLLECTS FROM YOU
Bubbles collects only the information required to provide products and services to you. The amount of information provided by you and collected by Bubbles depends on the circumstances. Bubbles may collect two (2) types of information about you: Personal and Non-Personal.

1.“Personal Information.” Personal Information means any information relating to an identified or identifiable individual. An identifiable individual is one 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. Bubbles may collect Personal Information when you use the Bubbles Properties including, without limitation, setting up account information, filling out surveys, corresponding with Bubbles, or otherwise volunteering information about yourself.

2.“Non-Personal Information.” Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or website visitations). Bubbles may collect Non-Personal Information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.

HOW BUBBLES COLLECTS YOUR INFORMATION
1. Registration. Prior to using one or more of the Bubbles Properties, Bubbles may require you to provide us with certain Personal Information and Non-Personal Information to create an account (“Account”) or to enable features or functionality of the Bubbles Properties.

2. Users. Bubbles may gather Personal Information about organizational representatives via various methods (phone, email, online forms, in-person meetings) but only if such Personal Information is submitted voluntarily. Bubbles may use such Personal Information for sales, marketing, and support of the Bubbles Properties. This Personal Information is never shared with third parties other than Third Party Service Providers utilized by a User in connection with Bubbles Services.

3. User communications. When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve the Bubbles Properties.

4. Payment Information. When creating an Account, for certain Bubbles Properties, or when you make online purchases, you may be asked to provide information, which may include your payment instrument number (e.g., credit card), your name and billing address, and the security code associated with your payment instrument (e.g., the CSV) and other financial data (“Payment Information”). We use Payment Information to complete transactions, as well as for the detection and prevention of fraud. When you provide Payment Information while authenticated, we will store that data to help you complete future transactions without your having to provide the information again. We do not, however, retain the security code associated with your payment instrument (e.g., the CSV) in this manner. To remove or modify Payment Information, please contact us. After you close your account or remove Payment Information, however, we may retain your Payment Information for as long as reasonably necessary to complete your existing transaction and for the detection and prevention.

5. Information Collected Through Technology. Bubbles automatically collects and receives certain information from your computer or mobile device, including the activities you perform on the Bubbles Site, the Bubbles Software and the Bubbles Services, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies (see below). If you have an Account, we may link this Non-Personal Information to your Account to better understand your needs and the needs of Users in the aggregate, diagnose problems, analyze trends, provide services, improve the features and usability of the Bubbles Properties, and better understand and market to our customers and Users.

6. We use technology to automatically gather information by the following methods:
- Cookies. Bubbles uses cookies on the Bubbles Site and other aspects of the Bubbles Properties. Cookies, including local shared objects, are small pieces of information that are stored by your browser on your computer's hard drive which work by assigning to your computer a unique number that has no meaning outside of the Bubbles Properties. Cookies do not generally contain any Personal Information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the Bubbles Properties unavailable to you.
- IP Address. You may visit many areas of the Bubbles Site anonymously without the need to become a registered User. Even in such cases, Bubbles may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an Internet services provider. Each time you access the Bubbles Site and each time you request one of the pages of the Bubbles Site, the server logs your IP address.
- Web Beacons. Web beacons are small pieces of data that are embedded in web pages and emails. Bubbles may use these technical methods in HTML emails that Bubbles sends to Users to determine whether they have opened those emails and/or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is Personal Information.
- Tracking Content Usage. If you use the Bubbles Services and you post audio visual materials including, without limitation, videos, screenshots, links, logos, artwork, graphics, pictures, advertisements, sound and other related intellectual property contained in such materials (collectively, “Content”) to your website or to a third party website, Bubbles tracks and captures Non-Personal Information associated with User accounts and the use of Content by those that access your Content.

7. Information You Provide About a Third Party. You may have the opportunity to communicate with others from the Bubbles Properties, such as by sending an invitation to a friend. If you choose to take advantage of this functionality, we may ask you to provide us with certain information about the person with whom you wish to communicate (e.g., name, email address, etc.). Bubbles collects such information for the purposes of facilitating the requested communication, which may contain a specific promotional message from you (e.g., an invitation to watch a video, screenshot, or link). Unless we explicitly say otherwise, Bubbles will not use this information for other marketing purposes without first obtaining consent from the person to whom the relevant information pertains. Please be aware that when you use any invitation functionality on the Bubbles Properties, your email address, name or username, and message may be included in the communication sent to your addressee(s).

HOW BUBBLES USES YOUR INFORMATION
1. Personal Information. Bubbles identifies the purpose for which your Personal Information is collected and will be used or disclosed. If that purpose is not listed below, we will identify any additional purposes for which we will collect your Personal Information, before or at the time of collection, and we will obtain your consent to collect, use or disclose your Personal Information for such additional purpose(s).

2. By using the Bubbles Properties, you will be deemed to consent to our use of your Personal Information for the purposes of:
- communicating with you generally;
- processing your purchases;
- processing and keeping track of transactions and reporting back to you;
- protecting against fraud or error;
- providing information or services requested by you;
- administering and managing the Bubbles Properties and our business operations;
- personalizing your experience with the Bubbles Site, as well as evaluating statistics on Bubbles Site activity;
- performing statistical analyses of your behavior and characteristics, in order to measure interest in and use of the various sections of the Bubbles Site;
- communicating with you on other websites;
- email gating;
- delivery of content and information to Third Party Services Providers;
- complying with legal and governmental requirements; and/or
- fulfilling any other purpose that would be reasonably apparent to the average person at the time that we collect it.

3. Users utilize Bubbles Properties to manage and deliver Content to Viewers. As part of this process, Bubbles may collect Personal Information from you.

4. Otherwise, we will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your Personal Information. You can change your consent preferences at any time by contacting us (see the “How to Access, Change and Erase Your Personal Information” section below).

5. Bubbles extends the rights granted to “data subjects” under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) to all of its Users. Consequently, you have the right to withdraw your consent to our processing of your Personal Information at any time (if our processing is based on consent) and the right to object to our processing of your Personal Information (if processing is based on legitimate interests).

6. Non-Personal Information. Bubbles may use Non-Personal Information for the following purposes:
- System Administration: Bubbles may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with Bubbles servers, monitoring Bubbles' system performance and traffic on the Bubbles Properties and to gather broad demographic information about Bubbles Users.
- Personalization: Bubbles uses cookies and IP addresses to track features such as delivering Content specific to your interests and informing you of new, relevant services or certain third party offerings.
- Advertising: Bubbles may use Non-Personal Information to assist in optimizing the delivery of advertisements to viewers of your Content.

HOW TO ACCESS, CHANGE AND ERASE YOUR PERSONAL INFORMATION
Upon request, Bubbles will allow Users to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests. Additionally, upon request, Bubbles will delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information may be submitted to hello@usebubbles.com.

Users also have the right to receive their Personal Information from us in a structured, commonly used and machine-readable format, and the right to transmit their Personal Information to another controller without hindrance from us (data portability).

EMAIL PREFERENCES
Bubbles may use your Personal Information to send you emails periodically listing promotions or events relating to the Bubbles Properties. You have the choice to opt-out of receiving such promotional emails by sending an email to hello@usebubbles.com and/or following the instructions in such correspondence. Once Bubbles' has processed your opt-out request, Bubbles will not send you promotional emails unless you opt back in to receiving such communications.

DISCLOSURE OF INFORMATION TO THIRD PARTIES
Except as described below, we do not sell, transfer or otherwise disclose, sell, trade, or otherwise transfer your Personal Information to outside parties. This statement does not include trusted third party service providers who assist us in administering and providing the Bubbles Properties or provide services to us. Examples include storing and managed Content, analyzing data, providing marketing assistance, integrations of Third Party Services such as CRM and MAP services, processing credit card payments, and providing customer service. These third party service providers will have access to Personal Information needed to perform their functions, but may not use it for other purposes.

We may use service providers located outside of the United States, and, if applicable, your Personal Information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries. You explicitly consent and agree to such transfer, storing and/or processing of your Personal Information outside of the United States or other country in which you are located.

We may share Payment Information with third parties for purposes of fraud prevention or to process payment transactions.

We may also release your information when we believe release is appropriate to comply with the law, enforce our policies, or protect our or others’ rights, property or for safety. We may also provide non-Personal Information to other parties for marketing, advertising or other uses.

Information, including Personal Information, which we collect from Users and Viewers, is considered to be a business asset. As a result, in the unlikely event that we go out of business, enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction.

Lastly, we may provide Users with certain identifiable usage information directly related to the videos, screenshots, links and/or other Content that they make available through the Bubbles Properties. Such information may include how many and which Content of a particular User was watched by a particular Viewer, from where a particular Content was watched by a particular Viewer and how many times a particular Content was watched by a particular Viewer. In addition, if you, as a Viewer, provide Personal Information (e.g. email address) as part of accessing and viewing Content, that Personal Information may be collected by us, a provider of Third Party Services or an Integrated Platform on behalf of the User who owns the Content and shared with that User or Third Party Service providers to that User, as we and others are their service provider. The use of such information will be subject to the information and privacy practices and policies of such Users and Bubbles will not be responsible or liable or the use of any information by such Users and any Bubbles will not be responsible for their use of your information.

Under certain exceptional circumstances, Bubbles may have a legal duty or right to collect, use or disclose your Personal Information without your knowledge or consent. In accordance with applicable laws, We will not disclose any consumer information (which may include Personal Information) without your written consent, except where consumer information is required to be disclosed: (i) for billing or market operation purposes; (ii) for law enforcement purposes; or (iii) for the purpose of complying with a legal requirement.

You are deemed to consent to disclosure of your information for the above purposes. If your Personal Information is shared with third parties other than Users, those third parties may be, but are not always, subject to appropriate agreements with Bubbles and/or its Users to secure and protect the confidentiality of your Personal Information.

SAFEGUARDING YOUR PERSONAL INFORMATION
Bubbles takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Information. These include, but are not limited to, internal reviews of: (a) Bubbles' data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Bubbles stores Personal Information.

Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your Personal Information, we cannot ensure or warrant the security of any information you provide to us.

All Bubbles employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information.

Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

RETENTION OF INFORMATION
Bubbles retains the Personal Information that we collect about you for as long as reasonably necessary for the purposes set out in this Privacy Policy. We also may retain your Personal Information for a longer period of time on the basis of our legitimate interests in providing or marketing our services to you or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use information that has been aggregated or anonymized so that it can no longer be used for personal identification.

CHILDREN AND STUDENTS
Bubbles takes the privacy of students and children extremely seriously. The Bubbles Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Bubbles Site. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on the Bubbles Site or via the Bubbles Services. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at hello@usebubbles.com.