Thank you for taking the time to read our privacy policy (the “Privacy Policy”). At Bouncr Labs, Inc. (“Bouncr”, “we”, “our”, or “us”), your privacy is of the utmost importance. We want you to be fully informed about the information we collect, how it is used, shared, protected, and the choices you have with it at Bouncr.
Bouncr operates a Software as a Service platform designed to help our retail, hospitality, nightlife, entertainment and other customers (“Customers”) verify the age or identification associated with our Customers’ patrons and guests (“Patron(s)”), enable Patron payments or otherwise manage the inflow of Patrons (collectively, the “Services”).
This privacy policy sets out how we collect, use, process, store, and disclose personal information on our mobile application (the “App”), and https://bouncr.io/ and website, https://bouncrlabs.com/ (collectively with the App, the “Website”) and in providing the Services.
1. Sources of Personal Information
We may collect or process your personal information from the following sources:
When you provide information through our Website, including when you contact us.
When you visit our Website where we may use online tracking technologies and other automatic data collection technologies, such as using pixels, web beacons, software developer kits, and cookies. Learn more about our cookies and online tracking technologies below.
When our Customers’ use our Services to process information about you.
When we receive information from our business partners or vendors, including data providers, fraud prevention service providers, or publicly available sources.
We may also create inferences or associate other information based on our analysis of any of the information we process about you.
2. Categories of Personal Information We Collect
Customer Information
In order to serve our Customers, we will collect various information from, or about, our Customers, including:
Professional contact information including your name, title, company email, company name, phone number, and company website URL.
Correspondence, which may include any personal information provided during an email correspondence or Customer service engagement.
Username and password associated with your account.
Billing and administrative finance information.
Automated information, including metadata and analytics for your use of our Website and Services, including cookie IDs, IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages. Learn more about our cookie and online tracking use below.
Our Customers’ Patron Information
When our Customers use our Website and Services, they may enable us to process various types of personal information on their Patrons. Below, we provide a list of the commonly processed personal information of Patrons from our Customers or directly from our Patrons. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.
Identity information such as name, date of birth, gender, eye color, height, weight, and nationality.
Contact information, including email address and phone number.
Residential address associated with Patrons’ ID.
Government-issued identification (“ID”) information, including government issued ID number, ID photo, document type (license, state identification card, or passport), issuing state or country, issue date, expiration date, and barcode data. Please note, government identifier information may be considered sensitive personal information under data privacy laws.
Records of previous Patron visits to our Customers, including Customer venue, date of visit, time of entry, and any notes created by our Customers regarding those visits, including ban status or other flags.
In addition, we may collect various types of personal information on Patrons from business partners or publicly available sources for the purpose of confirming Patron identities or otherwise facilitating the Services. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.
Identity or historical contact information, such as alternate names or nicknames, date of birth and/or age, current or previous home addresses, email addresses, phone numbers, and social media usernames or handles.
Names and ages of relatives and known associates.
Publicly available information, which may include voter registration information, court records, property ownership records, public registries, education and athletics history, personal or professional website references including social media profile information and professional employment history.
Inferences that may be drawn from or created based on any of the information identified above.
3. Business Purposes for Collecting Personal Information
We may use Customer personal information for the following business purposes:
To provide and improve our Website and Services.
To communicate with you.
To process payments securely.
For customer support.
To send our Customers marketing and promotional communications in accordance with individual marketing preferences.
To authenticate, verify or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.
Subject to the terms of our Customer agreements, we may use Patrons’ personal information for the following business purposes:
To provide our Services to all of our Customers, including to mitigate risk of fraud in verifying Patrons’ IDs to help Customers enforce their legal requirements related to age-gating and verification.
To improve our Services.
For any legal purpose necessary, including intellectual property protection, or if we are required to process information as a result of a court order or other legal or regulatory proceeding.
We may otherwise use personal information with your consent.
We may also use aggregated and/or anonymous information for any purpose.
4. How We Disclose Personal Information
The Services by default discloses select associated Patron information we have processed from our various sources to our Customers. We also utilize various service providers to operate our Website and Services, which may include sharing Customer and/or Patron personal information. Some of the types of vendors or service providers include:
Customer relationship management platforms and customer billing software.
Communications providers, including ActiveCampaign, LLC dba Postmark for email communications and Twilio Inc. for SMS/MMS communications to Customers.
Banking and payment processing providers, including Stripe, Inc. and Stigg Inc.
Service providers that help verify ID records, including IDScan.net, Inc. and Modal Labs, Inc.
Service providers that help verify purported residential addresses on IDs, including Dotsquare LLC dba Geocodio, Mapbox, Inc., and Hexasoft Development Sdn. Bhd. dba IP2Location.
Data partners and public-records providers to help us verify Patrons’ IDs.
Service providers that help manage and optimize our Website and Services (see ‘Cookies and Other Tracking Technologies’ below).
In addition, we may share personal information in order to:
Protect the legal rights of our Customers, our company, our employees, our agents, and our affiliates.
Protect the safety and security of those who access and use our Website and Services.
Detect and protect against fraud.
Comply with law or legal process.
Conduct due diligence or complete a legal transaction related to the sale of our business or any assets.
We may also disclose personal information with your consent.
We may disclose de-identified, aggregate, or anonymous information for any purpose. This means that the information does not identify specific individuals.
5. Privacy Choices
We provide our Customers with the following choices with our use of your personal information:
Access or correct the personal information we maintain about you.
Delete the personal information we maintain about you. Please note we may be required by law to retain certain information in compliance with accounting, tax or other legal obligations.
Opt out of certain uses of your personal information, notably:
Marketing Emails: To opt out of marketing e-mail communications, you may click the ‘unsubscribe’ link in the marketing emails. We may continue to send you non-commercial service messaging if legally necessary.
You can exercise these rights by contacting us at privacy@bouncrlabs.com.
If you are a Patron associated with one of our Customers, depending on your state-specific residency, you may be entitled to the privacy choices above and/or additional privacy rights related to our processing of your personal information. See the ‘State-Specific Notice’ below for more information. However, if your request is exclusive to the information we have processed from a Customer using our Services, we encourage you to exercise these rights by reviewing the Customer’s privacy policy to determine the correct contact method for that Customer.
6. Cookies and Other Tracking Technologies
Like many companies, we use cookies, pixels, and other tracking technologies to collect information about your interactions with our Website. We currently do not enable the use of third party pixel tags or cookies for advertising purposes, but may do so in the future. Please check back periodically if you would like to review and/or opt out of these future uses.
7. Security
We maintain reasonable safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. Despite our efforts, we cannot guarantee that unauthorized access or use will never occur. It is important that you take steps to keep your information safe and secure. Choose an account password that is hard for others to guess and don’t reveal it to third parties. If you use a shared public computer, do not opt to have your login ID or password remembered and be sure to log out of your account when you finish.
8. Retention
We will retain Customer personal information for as long as it is necessary for the purposes of fulfilling our Website and Services or otherwise as described in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. U.S. State-Specific Notice
Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Florida Digital Bill of Rights (“FDBR”), the Montana Consumer Data Privacy Act (“MTCDPA”), the Iowa Consumer Data Protection Act (“IADPA”), the Delaware Personal Data Privacy Act (“DEPDPA”), the Nebraska Data Privacy Act (“NEDPA”), the New Hampshire Privacy Act (“NHPA”), the New Jersey Data Privacy Act (“NJDPA”), the Tennessee Information Protection Act (“TNIPA”), the Minnesota Consumer Data Privacy Act (“MNCDPA”), the Maryland Online Data Privacy Act (“MDODPA”), the Indiana Consumer Data Protection Act (“INCDPA”), the Kentucky Consumer Data Protection Act (“KYCDPA”), the Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA”) the Oklahoma Consumer Data Privacy Act (“OCDPA”), the Louisiana Data Privacy Act (“LDPA”), the Alabama Personal Data Protection Act (“APDPA”), and the Vermont Data Privacy and Online Surveillance Act (“VDPOSA”) create additional privacy obligations for businesses and provide their residents with additional privacy rights.
Additional Privacy Rights
In addition to the rights granted in ‘Privacy Choices’ above, if you are Patron and a resident of the above states, you may have the right to:
Limit the use and/or disclosure of select personal or sensitive personal information. Unless our use is otherwise permitted by applicable law, Patrons may have the right to opt out of the use of their sensitive personal information.
You can exercise these rights by contacting us at privacy@bouncrlabs.com. Please note we may require additional information in order to verify privacy rights to access, correct or delete personal information.
Appeal
You may exercise any privacy request in the ‘Privacy Choices’ section above. If we deny your privacy request, you may appeal that decision by emailing us at privacy@bouncrlabs.com. We will respond to your appeal within a reasonable period of time and as required by law. If, after we have processed your appeal, you are still unsatisfied with our response, you may have the right to file a complaint with your state attorney general.
Authorized Agent
If you are an authorized agent submitting a request on behalf of another person, you must provide a copy of a lawful power of attorney or written authorization signed by the consumer. If you make a request as an authorized agent, you may receive additional instructions. Depending on the type of request, we may contact you or the consumer as permitted by law.
Right to Non-Discrimination
We do not discriminate against customers who exercise their privacy rights.
10. Children’s Privacy
We do not intentionally collect any personal information from children under the age of 13. If you believe we have obtained personal information associated with children under the age of 13, please contact us at privacy@bouncrlabs.com and we will delete it.
11. Third-Party Links
The Website and Services may contain links to other websites or services. We do not exercise control over the information you provide, or is collected by these third party websites. We encourage you to read the privacy policies or statements of the other websites you visit.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time as we update or expand our Website and Services. If we make material changes, we will post the updated Privacy Policy on this page with a ‘Last Updated’ effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Website and Services.
13. Contact Us
If you have any questions about our privacy or security practices, or if you would like to submit a privacy request, you can contact us by email at privacy@bouncrlabs.com or at:
Bouncr Labs, Inc.
131 Continental Drive,
Suite 305
Newark, DE 19713