Effective Jan 28, 2024
OVERVIEW
Bonbon (“we” or “us”) offers consumers a new way to login to sites using a Single Sign On Solution (“Solution”) that allows you to earn chances to win or earn rewards, unlock more content, see fewer advertisements, and/or access other benefits offered by sites or apps in our network (“Partner(s)”). We also offer an automated solution to login across Bonbon partner websites to access benefits with even less clicks, but only if you voluntarily opt-in to this feature.
To deliver these benefits, our Solution is integrated with Partner websites or applications that may offer you rewards including digital content, like articles, videos, games, and more. When you sign in with the Bonbon SSO, an account is also created with the Partner website. By creating an account with our Partners, they are able to deliver you more personalized advertisements and content. Ultimately, you benefit through rewards and a more personalized experience, and our Partners are able to deliver more relevant ads which increases their advertising revenue and supports their sites.
It is important for you to understand who has access to your Personal Information (defined below) and how your Personal Information is being used. It is just as crucial for you to have control over how your Personal Information is used. We would like to highlight a few commitments that are explained in more detail in this policy:
-
We will never log you into a Partner or offer a Partner the ability to deliver personalized advertising to you without your consent.
-
We will only share Account Information (defined below) with Partners when you consent.
-
We will always give you the ability to control how your data is used on an ongoing basis.
Read on to understand more about how the data you provide and we collect is used within our Solution and with our Partners. Our Solution also includes our website (“Site”), www.bonbon.tech, and this policy discusses the Personal Information we collect through our Solution and our Site.
This policy only discusses Bonbon’s Solution and Site, not the technology or systems of our Partners. We always require that our Partners abide by our policies and applicable laws when they use our Solution.
FULL PRIVACY POLICY
1. Personal Information we collect, how we use Personal Information, and with whom we may disclose Personal Information:
Some of the information we collect may be considered “Personal Information” or “Personal Data” under certain privacy laws. In the table below, we outline how we may collect, use, and/or disclose to third-parties Personal Information about you when you log-in using our Solution. Immediately following the table below, we provide additional detail about how we may use Personal Information and/or disclose Personal Information to third-parties.
We use your Personal information to:
Provide you with the Solution: We will use your Personal Information to allow you to create an account and use our login Solution across websites. The Personal Information we process when doing so includes your Account Information, additional information you provide to us when using the Solution (i.e. demographic or interest group information), information you generate when using the Solution (i.e. cookie IDs), and information regarding your use of the Solution (i.e. URLs you visit). We will also use your Personal Information to allow you to manage your consent preferences across our Partners.
Provide personalized advertising: We will use your Personal Information to provide our Partners with data for personalized online advertising. The Personal Information we process when doing so includes Self-Declared Demographic & Interests Information, Inferred Interests developed from Browsing Activity, and Advertising Identifiers developed from Account Information. Any data sharing for personalized advertising purposes will be done with your consent. Browsing Activity (i.e. the URLs of webpages you visit) will only be shared with Advertising & Marketing Clients with your consent and only associated with Advertising Identifiers (not with Account Information).
Provide data verification, measurement & modeling services: We and our Advertising & Marketing Partners may use your Personal Information for measuring and reporting on the performance of the Solution, to create models which indicate likely characteristics about various users, to measure marketing and ad performance, and to enable our Advertising Partners to verify connections between various pseudonymous identifiers to better understand or validate the relationship between households, people, and digital devices.
Administer Rewards: When you login to a Partner website or app with Bonbon, your Account Information is shared with the Partner for the purposes of creating an account in their systems so that you can claim and access offered rewards where applicable (e.g.chance(s) to win prizes, fewer ads, more free content, a donation to the site, and/or other rewards). Where available and with your consent, Self-Declared Demographics & Interest Information, and/or Inferred Interests may also be shared with the Partner when you log in with Bonbon. Unless you consent to automatic logins in the Bonbon Portal, we only share Account Information on a Partner-by-Partner basis, meaning that logging into one Bonbon Partner website means that your information will only be shared with that Partner.
Product and Services development: We may collect Personal Information, including the URLs of the sites you visit, to monitor and improve the Solution. We may also collect and use data on usage and device information to inform product innovation, new product offerings and to improve the solution.
Communicate with you and provide you with support: We will use your Personal Information when we provide you with key security notifications and support, and to respond to your requests or complaints, or to facilitate support (e.g. retrieve a forgotten password). These are critical communications and cannot be turned off unless you delete your Bonbon Account through the Bonbon Preferences Portal and cease use of the Solution.
Our marketing activities: We partner with third-party partners to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests or to measure the effectiveness of our advertising.
Manage our Website: We also use Google Analytics and other third-party partners to understand how our website is being used and how to improve it. Google Analytics is a website analytics service that tracks and provides insights on website traffic. The data Google Analytics collects may be used by other Google services, including their advertising network. To learn more about Google Analytics, including how to opt out of it, please visit https://tools.google.com/dlpage/gaoptout.
In addition to the uses detailed above, we may also use your Personal Information for the following purposes:
Protect our Services: We may use Personal Information to prevent fraud, identify activities that violate our policies, terms of service, or the law, or to prevent criminal activity that compromises our ability to protect our rights and property, secure our Solution, your data, or the safety of our customers, employees, or others.
Comply with Law & Industry Standards: We may process Personal Information to comply with applicable laws, regulations, court orders, or legally-binding requests from law enforcement or other similar government bodies. We may also process Personal Information to align our Solution to industry standards, or to comply with industry standards.
We may share Personal Information with selected third parties, including:
Our Partners (with Consent): When you login with Bonbon, we share your Account Information with Partners to create accounts in their systems. By consenting to this sharing, you will receive the respective rewards or sweepstakes entries (where available and eligible). With your consent, we may also share Self Declared Demographic & Interest Information, as well as Inferred Interests (where available). With your consent, we or our Partners may also use pseudonymous Advertising Identifiers generated from your email address or phone number to deliver personalized advertisements to you.
Advertising & Marketing Clients (with Consent): With your consent, we may also share your Browsing Activity, Inferred Interests, Advertising Identifiers and/or Device Information (as described above) with Advertising & Marketing Clients for their personalized advertising solutions and data verification, measurement & modeling services.
Sharing with service providers & for business purposes: We may share personal information with our contractors and service providers who help us administer our business operations (e.g. AWS for cloud compute & storage). These service providers are contractually obligated to keep your personal information confidential, and only process it in accordance with our instructions.
In addition to the Partners and Service Providers above with whom we regularly share your Personal Information, we may also share your Personal Information in the following cases:
Sharing to comply with law and protect our rights: We may disclose personal information to comply with applicable laws, regulations, court orders, or legally-binding requests from law enforcement or other similar government bodies, or when we believe disclosure is needed to fulfill our legal obligations.
Sharing for corporate transactions: In the unlikely event we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your personal information as part of that transaction.
2. Security
We will take reasonable steps to protect your data and minimize the personal information we process. Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure, though we do take all reasonable precautions to protect against security incidents.
3. How long we store your information
Your data is kept for as long as you are registered and using our SSO Solution.
If you would like to delete your account and associated information, use the Request links in the “Your Privacy Choices” section below. If you choose to delete your Bonbon account, we will forward that deletion request to our Partners and you may lose access to any rewards you claimed from that Partner by signing in with Bonbon.
If necessary to comply with legal obligations (e.g. if we are required to retain your data to comply with applicable laws), resolve disputes, or enforce our legal agreements and policies, we may retain your Personal Information only to fulfill such obligations.
4. Your Privacy Choices
Our solution is built around transparency and consent, and we believe that you should be in control of how your data is used. In addition to deleting your entire Bonbon account (as described above), you can also change which Partners have access to your Personal Information on a site-specific basis including the ability to opt-out of Partner emails, or delete accounts with Partner(s) that you have previously logged-into using Bonbon. When you request to opt-out of Partner emails or delete a Partner account, we will pass along the request to that Partner. However, to ensure your request is processed by the Partner, we request you make opt-out or delete requests directly to that Partner as well.
If you are a resident of California or certain other US states, you may also have certain rights as to how your Personal Information is collected, processed, and used. In particular, you have the right to know what Personal Information Bonbon collects about you, request access and receive a copy of that Personal Information, correct any inaccuracies in the Personal Information, and request that Bonbon delete the Personal Information about you. You also have the right to opt-out of the sale and/or sharing of your Personal Information.
If you are located in the European Union, Switzerland, or the UK, you may have certain rights as to how your personal information (also referred to as personal data) is collected, processed, and used. In particular, you have the right to request access and receive a copy of that Personal Information (including for transfer purposes), correct any inaccuracies in the Personal Information, and request that Bonbon delete the Personal Information about you. You also have the right to object to or restrict our processing of your Personal Information that we process [treat as deletion]. And you have the right to withdraw your consent to our processing of your Personal Information at any time at portal.bonbon.tech/account.
Bonbon also offers these rights to all data subjects, regardless of the jurisdiction where they are a resident. In addition to the links above, to exercise these or other privacy rights, you may also send an email to support@bonbon.tech with details on which of the above requests you would like to exercise. In the event that you are an Authorized Agent making a request, please email us at support@bonbon.tech. In some instances we may require verification of your identity prior to disclosing any personal data pursuant to applicable data protection laws.
We will not discriminate against you for exercising your rights and choices. You may have the right to appeal our decision with respect to a request you have submitted. If we are unable to resolve your concerns, you have the right to contact a data privacy supervisory authority in the country where you live or work, or where you consider that the data protection rules may have been breached or seek a remedy through the courts.
Annual Request Statistics:
During the 2023 calendar year, we received and fulfilled the following types of privacy rights requests from individuals globally:
5. Additional Information for California Residents
If you are a resident of California, please review these additional privacy disclosures, which may apply where we collect information as a “business” under California law.
California law requires us to disclose the categories of personal information we collect and how we use them, the categories recipients with whom we disclose personal information, and the purposes of the disclosures.
Within the preceding 12 months, we have collected the following categories of personal information: Account Information, Self-Declared Demographic & Interest Information, Browsing Activity, Inferred Interests, Advertising Identifiers, Device Information, Necessary Cookies, and Website Cookies. For details about the precise data points we collect and the categories of sources of such collection, please see the “Personal Information we collect, how we use Personal Information, and how we may disclose Personal Information” section above. We may use and disclose the Personal Information we collect for the purposes described in the same section of this Policy, including to: Provide you with the Solution, Administer Rewards, Product and Services development, Communicate with you and provide you with support, Manage our Website and Online Advertising, Protect our Services, and Comply with Law & Industry Standards. In the preceding 12 months, we have disclosed the following categories of Personal Information for business purposes to the following categories of recipients:
Your Rights
We are also required to communicate information about rights you have under California law—for information about these rights, please see “Your Privacy Choices” above. You may exercise these rights by using the same request links or other communication methods detailed in “Your Privacy Choices” above.
If an authorized agent submits a request on your behalf, we may require that the authorized agent provides written proof of their authority and we may separately verify your identity and confirm your request with you.
Do Not Sell My Personal Information:
Bonbon’s disclosure of Personal Information may sometimes constitute a “sale” or “sharing” under California law which requires offering consumers the ability to limit our use of such Information, and our Partners may buy or sell personal information as defined by California law. You may opt out of the sale and sharing of your Personal Information, as well as the use of your Personal Information for personalized advertising purposes by clicking here.
Notice of Financial Incentive:
Bonbon offers consumers a Solution that rewards them for signing into Partner websites and, with their consent, allowing Partners to use their Personal Information for personalized advertising. When you sign up for a Bonbon Account, we ask you to provide Account Information. Because Account Information includes Personal Information,and administering rewards involves the collection of Personal Information, the rewards offered by Partners may be interpreted as a “financial incentive” program under California law. The value of your Personal Information to Bonbon and our Partners is related to the value of the rewards you are offered.
You may delete your Bonbon account at any time using the instructions provided above, and we will forward your deletion request to all Bonbon Partners you have previously signed-in with. If you delete your Bonbon account, or toggle off permissions for a Partner you previously logged-into using Bonbon, you may lose access to any rewards you claimed from that Partner by signing in with Bonbon.
Right to Non-Discrimination:
We do not discriminate against California residents who exercise any of their rights described in our Privacy Policy.
6. Additional Information for EU, Swiss, and UK Users
If you are an end user located in the EU, Switzerland, or the UK, please read these additional disclosures below.
Your Rights:
You have the right to access, correct, and request deletion of your Personal Data and to object to certain processing, including profiling. You also have the right to receive personal data concerning yourself in a machine readable format. If you would like to exercise your rights, please see the “Your Privacy Choices” section above.
Legal Basis for Processing:
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
In all situations where you have been specifically asked by our partners or by us for your consent prior to processing, we may rely on that consent until you withdraw it. If we rely on consent to collect and/or process your Personal Data, we will obtain such consent in accordance with applicable law. In some cases, we need to process your Personal Data because we have a legal obligation to do so.
You can withdraw your consent and opt-out from the use of your data for advertising purposes, and opt out of the further processing of your data. Please see the “Your Privacy Choices” section above.
When we collect data, we rely on several legal bases, these include:
Contract Performance
When the processing is necessary to perform our contract with you, such as our Terms of Service. This may include providing you with our Solution.
Legitimate Interests
When the processing is necessary for our legitimate business interests (or those of our partners), except where such interests are overridden by your data-protection interests or fundamental rights and freedoms. We may rely on legitimate interest for purposes including but not limited to, maintaining the Solution or providing the Solution. Purposes may include internal validating or verifying information such as email addresses & telephone numbers, detecting potentially fraudulent activities, and ensuring data security.
Consent
When you have given us your consent, including as described in this Privacy Policy. You may withdraw your consent to processing at any time using the settings in your Bonbon account.
Legal Obligation
When we have a legal obligation to do so, as described in this Privacy Policy.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided under the “Contact Us” section below.
Right to Lodge a Complaint:
You have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority. For contact details of EU data protection authorities, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. The Swiss data protection authority can be contacted at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html. The UK data protection authority can be contacted at https://ico.org.uk
If you are based in the EU or UK you can also contact the following representatives:
For EU requests: Bonbon@lionheartsquared.eu
Lionheart Squared (Europe) Ltd (FAO – BonBon),
2 Pembroke House, Upper Pembroke Street 28-32,
Dublin, DO2 EK84, Republic of Ireland.
For UK Requests: bonbon@lionheartsquared.co.uk
Lionheart Squared Ltd (FAO – BonBon),
17 Glasshouse Studios, Fryern Court Road
Fordingbridge, Hampshire SP6 1QX United Kingdom
7. International Data Transfers
In order to provide you with our Solution, your Personal Information will be processed by our employees and service providers in the United States. If you provide us with your Personal Information, you consent to that Information being transferred and processed in the United States.
The countries your data is processed in may not have the same data protection laws as the country in which you reside. When transferring your data outside the EU, Switzerland, or the UK, Bonbon will comply with applicable data protection laws. We will rely on all modules of the EU Commission’s Standard Contractual Clauses available here or other appropriate safeguards under the GDPR as well as the UK Addendums to the EU Standard Contractual Clauses and other appropriate safeguards under the UK data protection law. Where the international data transfer programs do not apply, when you use our Solution, you consent to the transfer of your data.
8. Children’s privacy
Our SSO Solution is not available on websites targeted at children, our Solution is not targeted at children, and we do not knowingly collect information from individuals under the age of 16. If you are under the age of 16, you will not pass our age verification requirements and are not permitted to use our Solution. If you learn that your child has provided us with information in violation of this Policy, please contact us at support@bonbon.tech.
9. Third Party Websites
We are not responsible for the practices employed by websites or applications (including widgets) linked to or from our website nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our website. Please remember that your browsing and interaction on any other website, including websites which have a link on our website, is subject to that website’s own rules and policies.
10. Contact & complaints
We welcome questions, comments, and requests regarding this Policy. If you wish to offer comments or to make a complaint about how we process your personal information, please send a detailed message to our Data Protection Officer or Bonbon at support@bonbon.tech.
11. Changes to this Policy
If we make any material changes to this Policy, we will post the updated Policy and notify our users via email (to the last email you provided us). Please check this page to see any updates or changes to this Policy.
