Last Updated October 5, 2022.
If you have questions about our privacy practices or would like to make a complaint, please contact us at email@example.com.
1. What is “Personal Information”?
- Identifiers (e.g., name, email, telephone number, address, username);
- Sensitive Personal Information (e.g., government identification; precise geolocation; contents of messages when we are not the recipient);
- Legally protected information (e.g., race, citizenship, marital status, sex);
- Employment-related information (e.g., current or past employment);
- Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
- Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
- Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other similar activity (e.g., browsing history; content interactions); and
- Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Information that is not protected as Personal Information includes publicly available information; aggregated information (meaning data summaries or reports with Personal Information removed); and anonymized information that cannot be linked back to an individual.
2. Collection and Use of Information
Billups only collects, uses, retains, and discloses Personal Information as reasonably necessary and proportionate to provide our Services or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Information. As a B2B service provider, Billups has no direct relationship with consumers, but sometimes leverages consumer Personal Information on behalf of Clients to support their advertising goals. Billups may collect Personal Information (a) with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law.
During the preceding 12 months, we have collected Personal Information in the following categories: (i) identifiers; (ii) employment-related information; (iii) commercial information, and (iv) internet or similar activity. We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without prior notice to you.
Billups collects Personal Information from the following sources:
- Clients, with consent. For each Contact with a Client, we collect professional contact information including name, email and other identifiers and employment-related information like company name and job title, as well as any information included in the Contact’s communications with us. We collect this information with consent, and we use it to provide the Client with the requested Services and to send service and marketing emails and other communications according to the Contact’s preferences.
- Prospective Clients, with consent. If you signup to receive Billups emails or request information about our Services, we collect your name, email address, and other identifiers. We collect this information with your consent and use it for the purposes stated at the time of collection and to communicate with you or send you marketing information.
- Online profiles and other public data sources, with a legitimate interest. Billups uses trusted third-party data sources to identify potential new Clients seeking our Services. We collect identifiers and employment-related information about the prospective Client’s Contact like name, email address, and job title. In many cases, the data collected from these public data sources is not protected as Personal Information under applicable privacy laws. Billups uses these public data sources in compliance with the third party’s terms of service and privacy requirements. We collect this information to achieve our legitimate interest of identifying and marketing our Services to potential new Clients.
- Third Party Data Sources, with a legitimate interest. Billups receives licensed data from third party data brokers, such as technical data and Personal Information retrieved from mobile application users and other online sources. For example, we receive a feed of geolocation data of mobile application users within the viewshed of an advertising placement. Our data sources collect this Personal Information with consent or another lawful basis according to their own privacy practices. We receive and use this information to achieve our legitimate interest of measuring the effectiveness of our Services and to identify successful advertising strategies.
- Automatically from your Site visit, with a legitimate interest. Billups may automatically collect technical data, including some Personal Information, from your interactions with the Services, such as your (i) device information (e.g., IP address, operating system, browser type, device ID); (ii) content interactions; (iii) usage details (e.g., traffic data, communication data and the features or resources you access and use); and (iv) stored information (e.g., metadata). We collect this information to achieve our legitimate interest of providing and improving our Services. We may also use this information to deliver targeted advertising according to your communication preferences.
- Essential. Billups uses first-party cookies to monitor website traffic and track session counts as well as Hubspot and LinkedIn cookies to store user consent and provide a Site experience that matches your country location. Most of these cookies do not collect any Personal Information, and those that do collect minimal identifiers as necessary for the cookies to function.
- Functionality. Billups uses its own first-part cookies, HubSpot and LinkedIn cookies to provide Site functionality like user authentication and Site language preferences.
- Reporting. The Site uses first-party cookies in combination with Google Analytics and HubSpot cookies to track and analyze interactions with the Site, monitor traffic, and distinguish unique users.
- Targeting. Billups first-party targeting cookies are powered by Google Analytics, Google AdSense, and Meta to track and provide enhanced ad efficiency on the Site and deliver targeted ads on other platforms. Doubleclick cookies track content interactions on the Site. LinkedIn cookies are set to track use of embedded services on the Site and for retargeting purposes to serve visitors more relevant ads across platforms.
You can change your cookie preferences by adjusting your device settings to block cookies or alert you when a cookie is set. For further assistance, contact firstname.lastname@example.org. Please note that blocking cookies may disable certain website features.
4. Disclosure of Personal Information
Billups will only disclose Personal Information to the third parties as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed Personal Information for a business purpose to the following third parties:
- Our Service partners such as payment processors, email providers, vendors, and cloud hosting providers to enable the provision of Services you request.
- Law enforcement, and other governmental agencies, as permitted or required by law.
- Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
Aggregated and Deidentified Information. We reserve the right to share aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.
5. Retaining Personal Information
Billups only retains Personal Information for the minimum period necessary to provide our Services or achieve our business goals. If you are on our email or other contact list, we will retain your contact information until you update it or ask us to delete it. If you are a Client, Billups retains a record of the transactions conducted under your account for 180 days after the transaction for customer service purposes and to document the concluded transaction in the event of a dispute, which may delay our completion of a request to delete Personal Information. Billups reserves the right to retain data for longer periods as required by law or court order or if doing so is critical to our business. Billups securely deletes data at the conclusion of the applicable retention period.
6. Your Privacy Rights
Depending on where you live or are located, you may have certain rights over your Personal Information that we collect and retain. Billups will facilitate your exercise of those rights as described in this section.
- Controlling Your Personal Information
Billups provides you a variety of methods and options to directly control how we collect and use your Personal Information, including but not limited to:
- Your Account. If you have Client account, you have the option to access, correct or update, or delete certain Personal Information through your account settings. If you require assistance, please contact us at email@example.com.
- Emails. Billups will send you service or marketing emails according to your stated preferences. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails or send a request to firstname.lastname@example.org. If you are a Client and opt-out of marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
- Device Settings. You can control the data we collect through cookies and related technologies by adjusting your device settings or your cookie preferences on the Site.
- Texting. If you provide us with your wireless phone number, you consent to Billups sending you informational or service text messages. We will only send you marketing text messages if you opt-in to receive these notifications from us. For all text messages, the number of texts you receive will depend on the information you request from us. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any of these messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
- Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.
- Privacy Requests. Depending on where you reside, you may be entitled to additional controls over your Personal Information as detailed below. If you wish to exercise your rights under your applicable privacy laws beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please contact email@example.com. Billups can only assist with or fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction.
- Privacy Rights for California and Certain Other U.S. States
This section provides the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”) and offers informational notices to residents of Virginia, Colorado, Nevada, and other U.S. states with laws providing similar protections. The following paragraphs apply solely to residents of the State of California and other states to the extent the same legal protections apply (each a “Consumer”). Depending on residency or location, a Consumer may have some or all of the privacy rights described below.
- Right to Correct. You have the right to request that we correct inaccurate Personal Information about you on our systems. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
- Right to Deletion. You have the right to request that we delete your Personal Information that we collected and retained, with certain exceptions. Billups may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a Consumer Privacy Request to delete your Personal Information, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
- Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you. If you submit an access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Billups may be prohibited by law from disclosing pieces of Personal Information that would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Under the CCPA, Billups is only required by law to provide access to Personal Information collected over the past 12 months and we are only required to respond to two access requests within a 12-month period.
- Right to Disclosure. You may request that we disclose information to you about our collection and use of your Personal Information, such as: (a) the categories of Personal Information we have collected about you; (b) the categories of sources for the Personal Information we have collected about you; (c) our business purpose for collecting, using, processing, sharing or selling that Personal Information, as applicable; (d) the categories of third parties with whom we share that Personal Information; and (e) if we sold or shared your Personal Information under the CCPA, two separate lists stating: (i) sales or sharing, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Under the CCPA, Billups is only required to make disclosure with respect to the preceding 12 months and must only respond to two disclosure requests within a 12-month period.
- Limited Use and Disclosure of Sensitive Personal Information. Billups does not seek to collect sensitive Personal Information about any individual, and in no case do we disclose sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of sensitive Personal Information.
- Opt-Out of Sharing Personal Information. Billups may share Personal Information third parties for cross-contextual behavioral advertising purposes. To opt-out of this sharing, you can adjust your device settings to block our cookies, submit a request to opt-out of sharing, or submit a request to firstname.lastname@example.org.
- Right to Nondiscrimination. We will not discriminate against you for exercising your privacy rights. Unless permitted by law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.
- Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
If you are a Consumer, you may exercise the rights available to you under applicable privacy laws subject to our receipt of a verifiable Privacy Request email@example.com and any exceptions and limitations that may apply.
- Privacy Rights for the European Economic Area and United Kingdom
This section provides the disclosures and notices required under the General Data Protection Regulation (“GDPR”) and its counterpart regulation applicable to residents of the United Kingdom. This section applies solely to residents of the European Economic Area (“EEA”) and the United Kingdom (“Data Subjects”). When serving our Customers, Billups collects and processes Personal Information of Data Subjects as a controller. Data Subjects have the following rights over their Personal Information, subject to applicable limitations:
- Right to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information and details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example, to protect the rights of other individuals.
- Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if: (a) the data is inaccurate; (b) the processing is unlawful; (c) we no longer need the Personal Information; or (d) you exercise your right to object.
- Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
- Right to data portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used and machine-readable format.
- Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, we must delete your Personal Information in certain circumstances and where required by law. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
- Right to object to certain processing of your Personal Information. Upon your request, we will limit our processing of your Personal Information as you request in certain circumstances and where we are required to do so by law.
- Right not to be subject to automated decision-making. Billups does not use automated decision-making to provide the Services. If this changes in the future, we will update this posting to describe our use of automated decision-making and your options to exercise your privacy rights related to your Personal Information processed using automated decision-making.
- Right to lodge a complaint with a supervisory authority. Data Subjects can submit requests, questions, or complaints to Billups using the methods described under Privacy Requests. If, after contacting us, you feel a privacy issue has not been resolved, you have the right to file a complaint with a supervisory authority.
Data Subjects may exercise these rights subject to our receipt of a verifiable Privacy Request firstname.lastname@example.org and any exceptions and limitations that may apply.
This section provides the disclosures and notices required under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Information offering details on an identifiable person without the inclusion of name, title, telephone number, and business address of an employee of a business or organization. The rights afforded under PIPEDA are described below.
- Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
- Right to access your Personal Information. Upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. We may not be able to provide access to some or all of the Personal Information you request if limited by law or potential infringement of another’s privacy rights. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps that are available to you.
Canadian Consumers may exercise these rights subject to our receipt of a verifiable Privacy Request email@example.com and any exceptions and limitations that may apply.
7. Consent to Cross-Border Data Transfers
Billups is a United States company using technical infrastructure in the United States and elsewhere. If you access the Services, please be aware that your Personal Information may be transferred to, processed, stored, and used in the United States or other jurisdictions. When your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those of the country where you live. For example, if your information is in the United States, it may be accessed by government authorities under United States law.
Billups is committed to transferring Personal Information using a lawful data transfer mechanism. Generally, we only transfer data from your home country to another country in an aggregated, deidentified, or anonymized form. If we do transmit Personal Information from the EEA to the United States or other jurisdictions, we do so pursuant to a lawful data transfer mechanism approved by the European Commission. Billups does not warrant that the Services are appropriate or authorized in any particular jurisdiction. By allowing using the Services, you consent to the transfer and processing of your Personal Information as described in this section.
Billups has implemented reasonable security measures to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. For example, we encrypt that information using secure socket layer technology (SSL) and we follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of online transmission or electronic storage is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Please bear in mind that submission of information over the Internet is never entirely secure. You are responsible for keeping your device access and login information confidential. You are also encouraged to install anti-virus and anti-malware software on your devices and keep all software updated to avoid security risks. We cannot guarantee the security of information you submit via our Services while it is in transit over the Internet, and any such submission is at your own risk.
9. Children’s Privacy
Billups Services are intended for use by adults, not children. No individual under the age of 18 should attempt to use the Services or provide any personal information to Billups. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact firstname.lastname@example.org.
10. Third-Party Services
When using our Services, you may have the option to link from or access third-party services via Billups’s Services. Please note that Billups has no control over third-party websites, apps, devices, or systems, and you should exercise caution when deciding to disclose your Personal Information.