Privacy Policy
This privacy policy (the “Policy”) describes how personal information is collected, used, and disclosed by Esublu Inc. (“ESUBLU”), in connection with the operation of ESUBLU, the ESUBLU mobile application (the “Mobile Application”), the Website <https://esublu.com/> (the “Website”), our products, services, software, accompanying documentation and related software provided by us (the “Software”), (hereinafter referred to as the “Services”). If you do not agree with this Policy, please do not use our application and/or our Website. Your continued use of our Services will signify your acceptance of this Policy.
What personal information do we collect?
The type of personal information we collect will depend on your relationship with ESUBLU and the nature of the Services or information you request from us. The personal information we collect may include:
- Our Services enable you to create an account. If you do, we may collect your name, email address, mailing address, phone number, date of birth, gender, login credentials, government issued photo identification and employment information and any further account information you provide.
- Our Services include access to certain features for purchase. We collect data about the transactions you engage in with respect to our Services. Your orders and/or transaction history will be associated with the accounts under which you log into our Services.
- Our Services may facilitate the collection of your payment, banking and billing information by us or our third-party payment service providers.
- If you create an account with us, we collect all information you post, share, or otherwise submit or provide while using the Services on the Website or Mobile Application, including Third Party Content.
- User information and content from Third Party Services that you agree to share with us, including tokens, username, follower information, profile photos.
- Information about products and services that you have received
In general, providing the above information is optional. You can opt out of providing information to us by not entering it or not using our Services. However, not providing personal information to us may hinder our ability to provide and/or your ability to use our Services.
We may collect other information that you choose to provide to us, or that we collect with your consent.
Information We Collect Automatically
We use data collection tools to automatically collect information when individuals visit our Website.
We use technologies like cookies and pixel tags to provide, monitor, analyze, and improve the Website. You consent to our collection of information through our use of cookies on our Website, in accordance with our privacy policy, by clicking accept on the banner displayed. You can block cookies on your web browser; however please be aware that some features of the Website may not function properly if the
ability to accept cookies is disabled.
Log Files
When you use the Website, our servers automatically record certain information in server logs. These
server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with content and links on the Website, domain names, landing pages, pages viewed, mobile carrier, and other such information. Log files help us to monitor, analyze, improve and maintain the Website and to diagnose and fix any service- related issues.
Usage Information
We may collect information about how you use and engage with our Services, such as searches you conduct within our Services, how long you spend on specific pages, information or features you engage with, customizations or preferences you request or create, and other activity you engage in while using our Services. We collect this information directly from you and/or your device or browser.
Device Identifiers
When you access the Website using a mobile device, we collect specific device information contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your account and will use data associated with your device identifier to customize our Website to your device and to analyze any device related issues.
Location Information
We may collect and process information about the location of the device from which you are accessing the Website, in order to provide certain location-based services. You can disable location-based services in settings associated with the Website; however please be aware that some features of the Website may not function properly if location services are turned off.
Analytics
We may use third party service providers like Google Analytics to collect information about your use of the Website, such as the features used and time spent on the Website, to help us better understand our users and improve our Website. The information we gather is used in an aggregate, non-identifiable form. For information about information is processed in connection with Google Analytics please read the Google Analytics Policy here.
For what purposes do we use personal information?
We use personal information to provide our Services and operate our business. This includes:
- To operate, manage, and provide our business and our Services.
- For administrative purposes such as creating and maintaining business records; billing, processing payments.
- For operational purposes such as management and improvement of our software, planning, evaluating, and monitoring our Services and to conduct quality assurance and risk management activities.
- To communicate with you in the provision of our Services, and respond to inquiries and requests;
- To comply with, establish, assert, exercise, defend against, or enforce any legal claims, legal rights, legal obligations, legal process, government requests.
- To detect and prevent fraudulent activity on the Website or Mobile Application.
- To send targeted communications for the purposes of marketing or promotions, with your consent.
- To generate de-identified data, which is not reasonably capable of identifying any particular individual. We use de-identified data to improve our products and services, for market research purposes, and for other lawful purposes.
- Establishment, realization or protection of legal rights.
We may use personal information for other purposes with your consent or as permitted or required by law.
When and to whom do we disclose personal information?
Service providers: We may transfer (or otherwise make available) personal information to service providers service providers and business partners who provide services to us or otherwise help us operate our business or the Services, such as (without limitation) by hosting data or our Services, processing payments, and detecting and preventing payment and other fraud. Personal information may be maintained and processed by our service providers in Canada.
Business transactions: In the event that ESUBLU is sold, restructured or involved in a similar business transaction, we may transfer your personal information to the parties involved in that transaction. We will ensure that your personal information is transferred in accordance with legal, regulatory and professional obligations.
Compliance- and Security-related Transfers: We may share personal information with third parties in connection with (a) complying with, establishing, asserting, exercising, defending against, or enforcing any legal claims, legal rights, legal obligations, legal process, policies, government requests, or prudent security or business practices; (b) protecting the health, safety, welfare, rights, or interests of you, us, any third party, or the general public; or (c) protecting the safety and integrity of our Services, troubleshooting issues, and detecting and preventing errors, fraudulent activity, or other potentially wrongful, harmful, or
illegal activity.
Disclosures with consent: We may disclose your personal information in other circumstances with your consent.
What are your rights with respect to your personal information?
You have the right to request access to or correction of your personal information in our control. You also have the right to withdraw your consent to our collection, use or disclosure of your personal information. To exercise any of these rights, please contact us in writing using the contact information in the “How can you contact us?” section below.
These rights are subject to applicable contractual and legal restrictions. We may take steps to verify your identity before providing access or making corrections to your personal information.
How secure is your information?
We have implemented reasonable physical, technological, and administrative security measures designed to protect the personal information in our control against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Please note, however, that while we believe our security measures are appropriate and minimize risk, no security measures can guarantee absolute security of information.
How long do we keep information?
Personal information is maintained at our offices or on our servers (or those of our service providers) and will be accessible by our authorized employees and contractors who require access for the purposes described in this Privacy Policy.
We retain personal information for as long as necessary to fulfil the purposes for which the information was collected or as otherwise required by law or pursuant to our professional obligations.
Children’s Privacy
Our Services are intended solely for use by adults. If you are under the age of majority in your province or territory of residence, you may not use our Services.
Links to Other Sites
Our Services may contain links to other websites or platforms. These websites operate independently from us, and their privacy practices are subject to their own privacy notices or policies, which we strongly encourage you to review to understand their procedures for collecting, using and disclosing personally identifiable information. We are not responsible for the content of the linked websites, any use of these sites, or the privacy practices of these sites.
Changes to this privacy policy
We may revise this Privacy Policy from time to time. If we change our Privacy Policy, we will post the revised Privacy Policy on the ESUBLU Website. You may obtain a copy of our current Privacy Policy at any time by visiting our Website or contacting us.
How can you contact us?
Please contact ESUBLU’s Privacy Officer at esubluglobal@gmail.com to:
- Request access to or correction of your personal information;
- Withdraw your consent to our processing of your personal information, including if you would like to opt-out of receiving tailored marketing communications;
- Ask questions about how your personal information is handled; or
- Escalate a concern to the Privacy Officer.