Privacy Policy
Effective date: February 5, 2020
ExpatBuddy Inc. (“us”, “we”, or “our”) operates the ExpatBuddy mobile application and
website (hereinafter referred to as the “Services”).
Your privacy is important to us. So, we have developed a Privacy Policy that covers how we
collect, use, disclose, transfer, and store your information. Please take a moment to familiarize
yourself with our privacy practices and let us know if you have any questions.
Collection and Use of Personal InformationPersonal information is data that can be used to identify or contact a single person.
You may be asked to provide your personal information anytime you are in contact with us or an
affiliated company. We and our affiliates may share this personal information with each other and
use such information in a manner consistent with this Privacy Policy. We may also combine your
personal information with other information to provide and improve our products, services,
content, and advertising. You are not required to provide the personal information that we have
requested, but, if you choose not to do so, we may not be able to provide you with our Services
or respond to any queries you may have.
Here are some examples of the types of personal information we may collect and how we may use it: What Personal Information We CollectWhen you use our Services or interact with our company, we may collect a variety of information,
including but not limited to, your location, name, mailing address, phone number, email
address, contact preferences, shopping preferences, your calendar, and information about
yourself and your contacts. We may collect this information from our application, from credit card
information, and from other social media platforms, such as your login credentials, your “real”
name, profile picture, and other information that you share or your social network shares with
you.
When you share content with our Services or any connected third-party source, whether inside
or outside your company community, we may collect data about such posts including but not
limited to, content, likes, views, comments, and other responses. We may collect the information
you provide about others such as names, mailing address, email addresses, and phone numbers.
We will use such information to provide our Services, link your account with us to your social
networking account, or for anti-fraud purposes. Furthermore, information that you share through
our Services could become collected and viewed by other members of the company
community.
In certain jurisdictions, we may ask for a government issued ID in limited circumstances and when
required by law, However, we do not currently conduct background checks or verify the identity
of our Users.
We do not guarantee anything about the Services, including the actions of our users. We do not
guarantee matches, the frequency of your matches, that you will be compatible with those you
match with, or that the people you match with are safe people to meet. You must exercise your
own diligence and caution in using the Services and communicating with its users.
How We Use Your Personal InformationThe personal information we collect allows us to create a platform so Expats around the world
can communicate and interact to help acclimate to life in a new environment. You can opt out at
any time by deleting the application from your device. This will not delete previously collected
data. Expat Buddy is a communication tool, any content you send to another user could be
collected and stored by that user in another format. Any content you post publicly could be
saved and stored in a different medium by a third party. We cannot control what a third party will
do with the content you upload or a communication that you have with any other user or the
public. If a third party copies or saves such content anywhere other than our system, we will not
be able to access or delete that information. It is your sole responsibility to act prudently when
posting content to or communicating through our Services.
We also use personal information to help us create, develop, operate, deliver, and improve our
products, services, content, and advertising, and for loss prevention and anti-fraud purposes.
We may use your personal information, including date of birth, to verify identity, assist with
identification of users, and to determine appropriate Services. For example, we may use date of
birth to determine the age of our users, and we may use that information to deny access to
Services to users that do not meet our minimum user requirements.
From time to time, we may use your personal information to send important notices, such as
communications about changes to our terms, conditions, and policies. Because this information
is important to your interaction with us, you may not opt out of receiving these communications.
If you would like to unsubscribe to any other emails, follow the instructions at the bottom of each
email and we will remove you from our subscribers list.
We may also use personal information for internal purposes such as auditing, data analysis, and
research to improve our Services and customer communications. We may occasionally ask users
of our Services to complete online surveys and opinion polls about their activities, attitudes, and
interests. These surveys help us better serve you and improve the usefulness of the Services.
Our Services may allow you to use social media outlets to log in to your account or to share
content with the social media outlet. The personal information a social media outlet has collected
from you is obtained and maintained by them independently of our Services. Other Services
follow different rules regarding the use or disclosure of the personal information you submit to
them. We encourage you to read the privacy policies or statements of the other online services
you use.
You may be able to add or import your contacts from another device or program. When you
import your contacts, we will ask you if you wish to invite your contacts. If you indicate that you
would like to invite them, we will send them an invitation from you to activate an account and join
the community.
We may share the information in your account, and user content you elect to share via the
Services, with the social media outlets with whom you choose to share user content. By
publishing user content to your social media outlet, you are allowing us to access your social
media outlet account information and you are agreeing to the applicable social media outlet
terms and conditions. Other than what we may share with a social media outlet in connection
with your use of the Services, the personal information a social media outlet has collected from
you is obtained and maintained by them independently of our Services. Other services follow
different rules regarding the use or disclosure of the personal information you submit to them.
We encourage you to read the privacy policies or statements of the other online services you use.
If you email us through the website, we may ask you for additional information so we can
respond to your questions and comments. If you choose to correspond with us via email, we may
retain the content of your email messages, your email address, and our response to you. In
certain cases, we may post content from your emails addressed to us.
Collection and Use of Non-Personal InformationWe also collect data in a form that does not, on its own, permit direct association with any
specific individual. We may collect, use, transfer, and disclose non-personal information for any
purpose. The following are some examples of non-personal information that we collect and how
we may use it:
We may collect information such as occupation, language, zip code, area code, unique device
identifier, referrer URL, general location, time zone, and other details, so that we can better
understand user behavior and improve our Services and advertising.
We may collect information regarding customer activities on our website, mobile applications,
and from our Services. This information is aggregated and used to help us provide more useful
information to our customers and to understand which parts of our Services are most effective.
Aggregated data is considered non-personal information for the purposes of this Privacy Policy.
We may collect and store details of how you use our Services. This information may be used to
improve the relevancy of results provided by our Services. In limited instances, to ensure the
quality of our Services over the Internet, such information could be associated with your IP
address.
If we do combine non-personal information with personal information, the combined information
will be treated as personal information for as long as it remains combined.
Cookies and Other TechnologiesOur Services, email messages, and advertisements may use “cookies” and other technologies
such as pixel tags, clear GIFs, and web beacons. These technologies help us better understand
user behavior, streamline the user experience, tell us which parts of our websites people have
visited, and facilitate and measure the effectiveness of our Services. We treat information
collected by cookies and other technologies as non-personal information. However, to the
extent that internet protocol (IP) addresses or similar identifiers are considered personal
information by local law, we also treat these identifiers as personal information. Similarly, to the
extent that non-personal information is combined with personal information, we treat the
combined information as personal information for the purposes of this Privacy Policy.
You can choose to limit the transmission of this data in your account preferences, or via your web
browser. If you do not accept cookies you may be unable to utilize the full functionality of the
Services.
We also use cookies and other technologies to remember personal information when you use
our website, online services, and applications. Knowing your contact information, hardware
identifiers, and information about your computer or device helps us reduce bugs and coding
errors to provide you with the best customer service possible. Collecting user usage data allows
us to prioritize the aspects of our Services that are used more frequently and to generate statistics
about how the Services are being used.
As is true of most internet services, we gather some information automatically and store it in log
files. This information includes Internet Protocol (IP) addresses, browser type and language,
internet service provider (ISP), referring and exit websites and applications, operating system,
date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about
user behavior on the site, to improve our Services, and to gather demographic information about
our user base as a whole. We may use this information in our marketing and advertising.
Pixel tags enable us to send email messages in a format which customers can read, and they tell
us whether mail has been opened. We may use this information to reduce or eliminate messages
sent to customers.
In some of our email messages, or as a feature of the Services, we use a “click-through URL”
linked to content on our website or the website of third parties. When customers click one of
these URLs, they pass through a separate web server before arriving at the destination page on
our website. We track this click-through data to help us determine interest in particular topics and
measure the effectiveness of our customer communications. If you prefer not to be tracked in this
way, you should not click text or graphic links in email messages. If you click on another third-party link, you will be directed to that third party’s website. The fact that we link to a website is
not an endorsement, authorization, or representation of our affiliation with that third party, nor is
it an endorsement of their privacy or information security policies or practices. We do not
exercise control over third-party websites. These other websites may place their own cookies or
other files on your computer, collect data, or solicit personal information from you.
Disclosure to Third PartiesAt times we may make certain personal information available to strategic partners that work with
us to provide the Services, or that help us market to customers. Before sharing personal
information with third parties we will take all reasonable measures to ensure that the third parties
will abide by this policy.
At times we may make certain non-personal information available to third parties for reasons
other than providing the Services. We may disclose non-personally identifiable aggregate
statistics regarding user behavior as a measure of interest in, and use of, our Services to third
parties in the form of aggregate data, such as overall patterns or demographic reports, which do
not describe or identify any individual user. Information relating to aggregate statistics may be
collected through the use of third-party cookies and other third-party tracking devices. We may
share aggregated information that does not include personal information and we may otherwise
disclose non-identifying Information and log data with third parties for industry analysis,
demographic profiling, and other purposes. Any aggregated information shared in these
contexts will not contain your personal information.
Service ProvidersWe also use your personal information to provide, maintain, protect, and improve the Services,
to authenticate you as a user, to communicate with you, and to assist you in using the Services.
We may combine your personal information with non-personal information and aggregate it with
information collected from other users to attempt to provide you with a better experience, to
improve the quality and value of the Services, and to analyze and understand how our Services
are used. For example, we may use your personal information to provide you with a list of expats
who share your interests, or whom we believe you are likely to enjoy their company and we may
also use your personal information to add you to such lists for other users. We will not share, rent,
or sell your personal information to other parties, except to our service providers as set forth
below.
We may match information collected from you through different means or at different times,
including both personal information and site usage information, and use such information along
with information obtained from other sources, including (without limitation) any of our other
websites and third parties. We may send you notices (for example, in the form of emails,
mailings, and the like), and otherwise correspond with you about products, services, companies,
events sponsored by us and others, and other information that we think might interest you.
We may share personal information with, agents, contractors, controllers, third party individuals
and other companies to assist us in providing the Services, or who provide ancillary services such
as information processing, extending credit, fulfilling customer orders, delivering products,
managing and enhancing customer data, providing customer service, assessing customer
interest in our products operation and maintenance of the Services, database management, web
analytics, and improvement of the Services, and conducting customer research or satisfaction
surveys. These third parties have access to your personal information and other information
collected as set forth in this policy, only to perform these tasks on our behalf and are obligated
not to disclose your personal information or use it for any other purpose. Said third parties may
be located anywhere in the world. Furthermore, your private information may be transferred and
processed in the United States of America or abroad.
Accountability for Onward TransferWhen transferring personal information to a third party acting as a controller, we must comply
with the Notice and Choice Principles (“Principles”). We must also enter into a contract with the
third-party controller that provides that such data may only be processed for limited and
specified purposes consistent with the consent provided by the individual and that the recipient
will provide the same level of protection as the Principles and will notify us if it makes a
determination that it can no longer meet this obligation. The contract shall provide that when
such a determination is made, the third-party controller ceases processing or takes other
reasonable and appropriate steps to remediate.
When transferring personal data to a third party acting as an agent, we must: (i) transfer such data
only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at
least the same level of privacy protection as is required by the Principles; (iii) take reasonable and
appropriate steps to ensure that the agent effectively processes the personal information
transferred in a manner consistent with the organization’s obligations under the Principles; (iv)
require the agent to notify us if it makes a determination that it can no longer meet its obligation
to provide the same level of protection as is required by the Principles; (v) upon notice, including
under (iv), take reasonable and appropriate steps to stop and remediate unauthorized
processing; and (vi) provide a summary or a representative copy of the relevant privacy
provisions of its contract with that agent to the Department of Commerce or its designated agent
upon request.
ExpatBuddy shall remain liable under the Principles if its agent processes such personal information in
a manner inconsistent with the Principles, unless ExpatBuddy proves that it is not responsible for the
event giving rise to the damage.
Changes to Privacy PolicyAs ExpatBuddy evolves, we may revise this Privacy Policy from time to time. The most current
version of the policy will govern our use of your information and will always be available at expatbuddy.com/privacy-policy. We reserve the right to change this Privacy Policy at any time
and for any reason. If we make a material change to this policy, we will notify you via email or by
posting a notice within ExpatBuddy or on our website. By continuing to access or use the
Services after those changes become effective, you agree to be bound by the revised Privacy
Policy.
OtherIt may be necessary − by law, legal process, litigation, and/or requests from public and
governmental authorities within or outside your country of residence − for us to disclose your
personal information. We may also disclose information about you if we determine that for
purposes of national security, law enforcement, or other issues of public importance, disclosure
is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably
necessary to enforce our terms and conditions or protect our operations or users. We cooperate
with government and law enforcement officials and private parties to enforce and comply with
the law. We will disclose any information about you to government or law enforcement officials or
private parties as we, in our sole discretion, believe necessary or appropriate to respond to
claims and legal process (including but not limited to subpoenas), to protect our property and
rights and the rights of our suppliers, or other third parties, to protect the safety of the public or
any person, or to prevent or stop activity we may consider to be, or to pose a risk of being,
illegal, unethical, or legally actionable activity. Additionally, in the event of a reorganization,
merger, or sale we may transfer any and all personal information we collect to the relevant third
party.
Our organization and activities are subject to investigatory and enforcement powers of the
Federal Trade Commission, the Department of Transportation, and the Department of
Commerce, and we comply with the Fair Information Practices act, the CAN SPAM Act, and the
California COPP Act. It may be possible, under certain conditions, for you to invoke binding
arbitration under Annex I of the Privacy Shield Act. We adhere to the Individual Redress Principle,
which requires that individuals have a right to pursue legally enforceable rights against data
collectors and processors who fail to adhere to the law. Individuals must have enforceable rights
against data users, and recourse to courts or government agencies to investigate and/or
prosecute non-compliance by data processors. We have chosen to fully comply with the Data
Protection Authorities, and you may utilize the International Centre for Dispute Resolution-American Arbitration Association to resolve any violation of the Privacy Shield Act.
Protection of Personal InformationWe take the security of your personal information very seriously. Our online services protect your
personal information during transit using encryption such as Secure Sockets Layer (SSL). When
your personal data is stored by us, we use computer systems with limited access housed in
facilities using physical security measures. We restrict access to personal information to those
employees, contractors, and agents who need to know that information in order to process it for
us, and who are subject to strict contractual confidentiality obligations. Data is stored in
encrypted form including when we utilize third-party storage. All transactions are processed
through a gateway provider and are not stored or processed on our servers.
We will make any legally required disclosures of any breach of the security, confidentiality, or
integrity of your unencrypted electronically stored “personal data” (as defined in applicable state
statutes on security breach notification) to you via email or conspicuous posting via the Services
in the most expedient time possible and without unreasonable delay, insofar as consistent with (i)
the legitimate needs of law enforcement, or (ii) any measures necessary to determine the scope
of the breach and restore the reasonable integrity of the data system. While we endeavor to
protect the security and integrity of sensitive personal information provided to us, we cannot
guarantee that information, during transmission through the Internet or while stored on our
systems or otherwise in our care, will be safe from intrusion by others. In the event of a data
breach and consistent with the above, we will notify users over email within seven (7) business
days after becoming aware of a data breach.
When you use some products, services, or applications or post on a forum, chat room, or social
networking service, the personal information and content you share is visible to other users and
can be read, collected, or used by them. You are responsible for the personal information you
choose to share or submit in these instances. For example, if you list your name and email
address in a posting, that information is public. Please take care when using these features.
Identity theft and the practice currently known as “phishing” are of great concern to us.
Safeguarding information to help protect you from identity theft is a top priority. We do not and
will not, at any time, request your credit card information, login information, or national
identification numbers in a non-secure or unsolicited email or telephone communication. For
more information about phishing, visit the Federal Trade Commission’s website.
Integrity and Retention of Personal InformationWe intend to make it easy for you to keep your personal information accurate, complete, and up
to date. We will retain your personal information for the period necessary to fulfill the services and
other purposes outlined in this Privacy Policy unless a longer retention period is required or
permitted by law. All authorized users may review, update, correct, or delete the personal
information in their account by making edits via the Services. If you would like us to delete your
account in our system, please contact us at help@expatbuddy.com with a request that we delete
your personal information from our database. We will use commercially reasonable efforts to
honor your request. We may retain an archived copy of your records as required by law or for
legitimate business purposes such as data back-ups or other security measures. Individuals may have
the right to limit the use and disclosure of their personal information as required by the Privacy Shield’s
Principles, such as whether your personal information is disclosed to a third party or used for purposes
materially different from the purpose for which the personal information was originally collected or
subsequently authorized by you. If you wish to limit the use and disclosure of personal information in
accordance with the Privacy Shield Principles, please contact us at help@expatbuddy.com.
Access to Personal InformationYou can help ensure that your contact information and preferences are accurate, complete, and
up to date by updating your account preferences. For other personal information we hold, we
will provide you with access for any purpose including to request that we correct the data if it is
inaccurate or delete the data if we are not required to retain it by law or for legitimate business
purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the
privacy of others, are extremely impractical, or for which access is not otherwise required by local
law. Access, correction, or deletion requests can be made by email in the contact us page on our
website.
Usage of the Services by MinorsWe understand the importance of taking extra precautions to protect the privacy and safety of
minors using our Services. Minors under the age of eighteen (18), or the equivalent minimum age
in the relevant jurisdiction, are not permitted to create accounts. However, it is not possible for us
to independently verify the age of our customers. It is the responsibility of every parent to
monitor his or her child’s online activities. These Services are not directed to minors. We do not
knowingly collect personal information from minors. If a parent or guardian becomes aware that
his or her child has provided us with personal information without their consent, please contact
us. If we become aware that a minor has registered for the Services and has provided us with
personal information, we will delete such information from our files.
Location-Based ServicesTo provide location-based services on our platform we, our partners, third-party servicers, and
licensees may collect, use, and share precise location data, including the real-time geographic
location of your computer or device. Where available, location-based services may use GPS,
Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower
locations, and other technologies to determine your devices’ approximate location. By
accepting the terms and conditions you have consented to transmission of your location data.
This location data is not anonymous, could personally identify you, and is used by us and our
affiliates to provide and improve our Services.
International TransferYour information may be transferred to, and maintained on, computers located outside of your
state, province, country, or other governmental jurisdiction where the privacy laws may not be as
protective as those in your jurisdiction. If you are located outside the United States and choose to
provide information to us, we may transfer said personal information to local or foreign
processing centers and process it there.
International UsersAll the information you provide may be transferred or accessed by entities around the world as described
in this Privacy Policy. Personal information, relating to our Services, regarding individuals who reside
in a member state of the European Economic Area, the United Kingdom, and Switzerland is subject to the
Privacy Policy and we make all reasonable efforts to remain in compliance with European Privacy laws.
ExpatBuddy, Inc., complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of personal information transferred from
the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield.
ExpatBuddy, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles
in respect to such information. If there is any conflict between the terms in this Privacy Policy and the
Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield
program, and to view our certification, please visit https://www.privacyshield.gov.
In compliance with the Privacy Shield Principles, ExpatBuddy, Inc. commits to resolve complaints about our
collection or use of your personal information. EU, Swiss, and British individuals with inquiries or
complaints regarding our Privacy Shield policy should first contact ExpatBuddy, Inc. at: help@expatbuddy.com. ExpatBuddy, Inc. has further
committed to cooperate with the panel established by the EU data protection authorities (“DPAs”) with regard
to unresolved Privacy Shield complaints concerning data transferred from the European Union, the United Kingdom,
and Switzerland.
We will also make reasonable efforts to abide by the Asia-Pacific Economic Cooperation (APEC)
Cross Border Privacy Rules System (CBPR). The APEC CBPR system provides a framework for
organizations to ensure protection of personal information transferred among participating APEC
economies.
Residents living outside the United States should investigate local privacy laws and are only
licensed to use our products if our products are in compliance with local laws.
Our Company-Wide Commitment to Your PrivacyTo make sure your personal information is secure, we communicate our privacy and security
guidelines to our employees and strictly enforce privacy safeguards within the company.
Privacy QuestionsIf you have any questions or concerns about our Privacy Policy or data processing or if you would
like to make a complaint about a possible breach of local privacy laws, please contact us.
All such communications are examined, and replies are issued where appropriate as soon as
possible. If you are unsatisfied with the reply received, you may refer your complaint to the
relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with
information about relevant complaint avenues which may be applicable to your circumstances.
You may contact us by email at help@expatbuddy.com.
Or by mail at: 13359 North Highway 183 STE 406-707 Austin, Texas 78750-7153.
California Privacy RightsFor users who are California residents, you have the following rights under the California
Consumer Privacy Act, and you have the right to be free from unlawful discrimination for
exercising your rights under the Act:
- You have the right to request that we disclose certain information to you and explain how
we have collected, used, and shared your personal information over the past 12 months.
- You have the right to request that we delete your personal information that we collected
from you, subject to certain exceptions.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to
respond to requests from California customers asking about the businesses’ practices related to
disclosing personal information to third parties for the third parties’ direct marketing purposes. If
you wish to find out about any rights you may have under California Civil Code section 1798.83,
you can write to us at help@expatbuddy.com.
From time to time we may disclose your contact information to third parties to allow them to
market their products or services to you or for other marketing purposes. This may be information
we received from you offline and online. If you want us to stop further sharing your email contact
information with third parties (if we have your email contact information), you may notify us at help@expatbuddy.com. Please follow the instructions provided to you by third parties to
unsubscribe from their messages. If you have opted-out as described above, and thereafter you
choose to use a service or promotion that requires us to contact you or share your information
with a third party, then your previous opt-out preferences will not apply to such service.
In addition, under California law, operators of online services are required to disclose how they
respond to “do not track” signals or other similar mechanisms that provide consumers the ability
to exercise choice regarding the collection of personal information of a consumer over time and
across third party online services, to the extent the operator engages in that collection. At this
time, we do track our users’ personal information over time and across third-party online services.
This law also requires operators of online services to disclose whether third parties may collect
personal information about their users’ online activities over time and across different online
services when the users use the operator’s service. We do not knowingly permit third parties to
collect personal information about an individual user’s online activities over time and across
different online services when using the Services.
Removal of Content for MinorsWe offer interactive services which allow you to post content to share publicly or with coworkers,
friends, and family. At any time, you can delete or remove content you have posted using the
deletion or removal options within our Services. If you have questions about how to remove
content in a specific Service or if you would like additional assistance with deletion, you can
contact our support team directly. Although we offer deletion capability for our Services, you
should be aware that the removal of content may not ensure complete or comprehensive
removal of that content or information posted through the Services.