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Webbula Privacy Notice

Webbula, LLC (“We,” “Our,”, “Us”, or “Webbula”) has developed this Privacy Notice to explain how we collect, retain, process, share and transfer your personal information when you visit https://webbula.com (“Website”) and to help you make informed decisions when using our Website or accessing our data services ( together, the or our “Services”).

To review the “California Addendum” we have created specifically to address disclosures required under the California Privacy Rights Act, please see our “CPRA PRIVACY NOTICEwhich is an addendum to this Privacy Notice.   (Formerly known as the California Consumer Privacy Act.)

To “opt out” of our databases – which means we will no longer “sell” and will instead suppress the personal information we have associated with you, please see Section 13.

To learn about personal information that we collect from our own Clients – e.g., the organizations that we work with, or business prospects for our own Services – please see Section 7.

  1. Background About Our Services

Webbula provides a variety of data services to advertisers, marketers and other organizations.  Generally, these services (our “Services”) are designed to help these organizations market to and communicate with their consumers and prospective consumers, or others that may wish to interact with their organizations (for instance, donors, where the organization is a charitable organization).   Sometimes we have a direct relationship with these organizations.  At other times, we have an indirect relationship with them, such as through another data or advertising platform, or a reseller, or an agency that engages on behalf of their own client.   We refer to all end users as “Clients,” whether they are brands, data or ad platforms, agencies or other types of organizations.

Our Services are described in more depth in this Privacy Notice:   they often involve either (a) performing “hygiene” on the consumer information our Clients have – for instance, to correct inaccuracies and prevent fraud, (b) helping organizations to maintain and expand their consumer or donor base, and (c) helping organizations better reach, target and communicate with consumers or donors online or through other marketing channels.

We often collect consumer information, including information known as “personal information” or “personal data” under state privacy laws, from other companies who have a direct (or indirect) relationship with the consumer at issue.   We therefore often do not have a direct relationship with the consumer:  rather, we often act as a data intermediary, between either multiple “first parties” who do have relationships with the consumer, or “first” and “third” parties who wish to do so.

As we have described elsewhere in this Privacy Notice, in order to “opt out” of our databases – which means we will no longer “sell” and will instead suppress the information we have associated with you, please see Section 13.

To learn about information that we collect from our own Clients – e.g., the organizations that we work with, or business prospects for our own Services – please see Section 7.

  1. The Information That We Collect and Use in Our Services

In order to provide and operate our Services, we collect certain personal information.  Under some state privacy statutes, this information is referred to as “personal information,” and in other states “personal data.”  Some statutes refer to it (or certain such data) as “personally identifiable information.”  We use the term “personal information” for purposes of this Privacy Notice to refer to that type of information, and we use the term “the Information” to refer to the personal information that we collect in providing our Services.

We describe this personal below, in tabular form (which we do because certain statutes encourage or favor that type of presentation).

The tables below explain the categories of information we collect and the purposes for which we use them.  Further detail about each of the purposes is set out in the “Additional Information on Purposes” table below.  Our descriptions of “Identifiers” follow common statutory, categorical examples:  we do not necessarily collect all example types of all identifiers shown.

Categories of personal information we collect Purposes of use Sources of Information
Identifiers
E.g., name; alias; postal address; online identifiers; IP address; telephone number; email address, mobile ad identifiers.
  • Provide the Services

 

  • Data compilers and consumer data resellers, informational and retail websites (collectively “Commercial Sources”).
  • Public records, government entities (such as the US Census Bureau), and other publicly available sources (collectively, “Public Sources”).
Characteristics of protected classifications under California or U.S. law, including Sensitive Personal Information E.g., race; color; religion; sex/gender, marital status; military or veteran status; national origin; ancestry.
  • Provide the Services
  • Commercial Sources.
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Provide the Services
  • Commercial Sources.
Internet or other electronic network activity information E.g., information on a consumer’s interaction with a website.
  • Provide the Services
  • Commercial Sources.
Geolocation data
  • Provide the Services
  • US Postal Service.
Professional or employment-related information E.g., job titles or categories.
  • Provide the Services
  • Commercial Sources.
  1. The Purposes for Which We Use the Personal Information We Collect

Generally, we use the personal information we collect to provide, maintain, operate and improve our Services.   The below table provides additional specifics as to those uses:

Additional Information on Purposes of Personal Information Use
Uses to Provide the Services:

 

Data marketing services, for example:

  • Generally, creating data marketing tools and products for our marketer Clients, as more fully described in our Privacy Policy (and on our websites). This may include, at any given time, our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), data hygiene services (helping Clients to evaluate, validate and correct personal information they hold), and security and anti-fraud services (helping Clients to identify potentially fraudulent activity).
  • Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
  • Assisting our Clients with use our Services to provide their consumers and prospects with better service, improved offerings, and special promotions, for instance, advising on which consumers or prospective consumers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

  • Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to help brands and other organizations target and measure ad campaigns online across various display, mobile and other media channels.
  • Assisting Clients in creating “identity” graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).

Additional marketing services, for example (which may overlap with “data marketing services” above):

  • Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
  • Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
  • Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
  • Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.

Operating our Services, for example:

  • Improving, testing, updating and verifying our own database.
  • Developing new products.
  • Operating, analyzing, improving, and securing our Services.

Personalize the experience, for example:

  • Creating and updating profiles and audience segments that can be used for analytics, interested-based advertising and marketing on the Services
  • Using inferences about your preferences and interests for any and all of the above purposes

Send you marketing and advertising, for example:

  • Sending you customized newsletters, surveys and information about products, services and promotions offered (with your consent where required) based on your activities and interests including at a household level
  • Providing you with advertising, including targeted advertising, based on your activities and interests including at a household level

Build and manage business-to-business relationships, for example:

  • pursuing potential business opportunities, including identifying and contacting the correct person within the company
  • Sending communications for business purposes
  • Managing Client, supplier and other business relationships
  • Sending event invitations, marketing emails and campaigns, and tracking the effectiveness of such communications
  • Issuing or paying invoices, and fulfilling contractual commitments
  • Providing business contacts with access to our systems, and managing that access
  • Communicating with you as an influencer about a shared social media campaign, and associated analytics

Market and advertise for third parties, for example:

  • Send you newsletters, promotional emails, surveys and information about products, services and promotions offered by our partners and other organizations with which we work
  • Customize content that our third-party partners deliver on the Services (e.g., targeted third-party advertising)
  • Create and update inferences about you and audience segments that can be used for interested-based advertising and marketing on the Services, third party services and platforms, and mobile apps
  • Create profiles about you, including adding and combining information we obtain from third parties and matching your interests across devices, which may be used for third-party marketing and advertising, including targeted advertising, third party services and platforms, mobile apps and/or websites, connected devices (such as browsers, mobile devices, tablets and TVs) and offline marketing.

Compliance and risk management activities for business-to-business relationships, for example:

  • Compliance with laws and regulations
  • Managing third party and other risks to our business
  • Protecting the reputation of our businesses
  • Following the principles of ethical business conduct set out in our Code of Conduct

Protect our users, Services and properties, for example: 

  • Protecting the safety and security of users and visitors to the Services
  • Protecting our digital and physical properties
  • Detecting and preventing other activities that may be illegal or in violation of our Terms of Service

 

We may combine all the information we collect from or receive about you for the outlined purposes. We may aggregate or deidentify your information and may use, share, rent or sell aggregated or deidentified information for any purpose, and such information is not subject to this Privacy Policy.

  1. How We Share Information with Third Parties, including Service Providers

Webbula may share the Information with Clients, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future).  This includes sharing in the following ways:

  • With Our Clients: We license your information in various ways to our Clients (and sometimes to partners and resellers, who license the Information to their Client), when we provide our Services.  We may sometimes share your information with those Clients’ service providers (for instance, a provider that sends communications for or on behalf of a Client, including their own customer).
  • With Our Advertisers and Partners: We also may share the Information, including personally identifiable information and Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our Clients’ behalf.
  • With Our Service Providers: We share your information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s).  For instance, we may share the Information with tech and Client support providers, marketing and advertising providers, other data providers (such as to enhance or verify your information), security vendors, payment vendors (as to our business to business information), and other companies help us deliver or develop Services.
  • Corporate transfers: If Webbula, its stock or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.
  • Affiliates, parent companies and subsidiaries: Webbula may share some or all of the Information in our possession with any affiliated or subsidiary companies (if we ever have any).
  • As required by law or to protect any person or entity: Webbula may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Webbula, our Clients, or any other person or entity.
  1. Your Marketing and Opt-Out Choices

There are multiple ways that you can opt-out of having the Information used to market to you:

  • First, you may visit our “opt out” page at https://webbula.com/opt-out-request/ or call us at 800-533-5853 to have your personal information removed from our database. We will then remove your personal information from our active marketing databases We may in certain cases request additional information, if required.
  • If you wish to opt out of online targeted ads (sometimes referred to as “interest-based” or “personalized” advertising), you can also visit the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages. Please note that these online opt-outs are cookie-based (unlike Webbula’s direct opt-out.  Thus, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you change browsers or clear your browser cookie cache, you will need to perform this opt-out function again.  Opting-out in this way will not prevent you from seeing all types of online ads; it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.
  • If we market to you by email, in our corporate capacity – such as if you are a Client or prospective Client of ours and we send information about our Services — you may “unsubscribe” from our marketing emails through a link placed in your emails.
  1. Cookies and Similar Technologies

Cookies and How We Use Them

While Webbula does not generally use cookies (for instance, third party cookies) in providing its Services to Clients, on this website Webbula its business partners do use certain industry-standard technologies, including cookies and similarly functioning technologies, which we describe below.

Our partners, on the other hand, may use cookies and similar technologies in their own marketing services.  We thus may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form.   These business and platform partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages.  When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed.  Pixel tags are used in combination with cookies to track the activity on a site by a particular device.  When you turn off cookies, pixel tags simply detect a given website visit.

We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see.   Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Necessary / Regulatory

Cookies that are necessary for the site to function properly and ensure your consent choices are saved for GDPR regulations.  The Necessary / Regulatory cookies used on this site including the following:

  • gdpr – This cookie associated with Webbula, LLC through this website’s consent manager. This cookie is used to request and store your consent of Webbula’s Privacy Notice and cookie choices. It is set to expire after 1 year.

Statistics / Analytics

Google Analytics provides anonymous statistical information for us. They process IP addresses and information from other cookies used on our sites so we know how many page views we have, how many users we have, what browsers they are using (so we can target our resources in the right way to maximize compatibility for the majority of our users) and, in some cases, in which country, city or region they are located.

  • _ga – This cookie is associated with Google Universal Analytics. This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. It is set to expire after 2 years.
  • _gid – This cookie is associated with Google Universal Analytics. This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. It is set to expire after 24 hours.
  • _gat – This cookie is associated with Google Universal Analytics, it is used to throttle the request rate – limiting the collection of data on high traffic sites. It expires after 1 minutes.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

  1. Data Collected Through Our Corporate Website
Additional information that we collect for business-to-business relationships only
Categories of personal information we collect Purposes of use Sources of Information
Business contact information

For example: company name, your name, email address, and job.

  • Build and manage business-to-business relationships
  • You
  • Your company
  • Trade associations
  • Social media
  • Business data resellers
Transactional information

For example: bank details of suppliers, credit/debit card details, purchase history, delivery address.

  • Build and manage business-to-business relationships
  • You
  • Publicly available sources
Device information and identifiers

For example: IP address, cookie IDs, browser type and language, operating system, platform type, device type, and advertising and app identifiers.

  • Provide the Services
  • Personalize your experience
  • Provide seamless experience across platforms and devices
  • Protect our users, Services and properties
  • Send you marketing and advertising
  • Market and Advertise for third parties
  • Build and manage business-to-business relationships
  • You
Demographics

For example (as permitted by law): ethnicity (minority owned businesses), gender (women-owned businesses)

  • Build and manage business-to-business relationships
  • You
  • Your company

How Webbula Shares the Information We Collect Through Our Websites

We may sometimes share or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:

  • We may share the Information with service providers who help us deliver the services you request or we provide. For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our business to business information), and other companies that may help us deliver or develop Services.
  • We may share the Information to communicate with you and market to you, including through email, direct mail or display media (which in turn may rely on cookies and similar technologies, described elsewhere in this Privacy Notice, including in Section 6).
  • We will disclose your information if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
  • If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process leading up to any such transaction.

Our website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).

  1. Links

This website may provide links to other websites that Webbula thinks users will find interesting or useful.  For instance, if we present information about a webinar by another company. Webbula is not responsible for the privacy practices of these other sites or companies.

  1. Security and Data Integrity

Webbula uses various electronic, physical, technical, and procedural safeguards to protect and limit access to the information you provided to us via this online service. Unfortunately, no data transmission or storage system can be guaranteed to be 100 percent secure; you therefore should not rely on our (or any) security protocols to be foolproof. Additionally, please note that information you send to us electronically may not be secure when it is transmitted to us because we do not control the security of your delivery channel.

  1. Children’s Privacy

Our online services are not intended for children, and Webbula provides no products or service geared towards children. Our website at www.webbula.com does not knowingly solicit or collect personal information online from children under age 18.

  1. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy.  Any changes to it will become effective when it is posted to our website.  Please check back to learn of any changes to this Privacy Policy.

  1. Storage of Information in the United States

If you are accessing our website from outside of the United States, your connection likely will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States.  (We generally store the Information used in our Services in the United States.)   Thus, you should be aware that in accessing this website or otherwise communicating with us, the Information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

  1. Your Privacy Rights

Depending on where you live, you may have certain rights with respect to your information.  For example, under several state laws (as they become effective), you may be able to ask us to:

  • provide access to certain information we hold about you, in some cases in a portable format, if technically feasible
  • update or correct your information
  • delete certain information
  • restrict the use of your information

We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.

Do Not Sell:  First, consumers may opt out of the “sale” of their personal information.  (This is required in some states, but we endeavor to extend this right to all consumers.)   Those laws may broadly defines “sale” in a way that may include allowing third parties, such as advertisers, advertising networks, to receive certain information such as cookies, IP address, device identifiers or other hashed identifiers, interests, browsing behavior and/or other activity to add to a profile about your device, browser, or you.

Depending on the consumer (and depending on whether the consumer is a Client of ours or a member of the public with whom we lack a direct relationship), we may disclose the following categories of information for such purposes which may be considered a sale (as defined by applicable law):

  • identification and demographics;
  • inference data, such as whether you may be likely to purchase certain goods in the near future.

To opt out of this type of sale, please go to https://webbula.com/opt-out-request/ and follow the instructions on that web page or call us at 800-533-5853.

Do Not Share/Do Not Target:  Consumers also may opt out “targeted” advertising, which is also sometimes referred to as “interest based” or “personalized” advertising.  We refer to it here as “targeted” advertising.  (It is also referred to as “cross-context” advertising under California law.) (This “opt out” right is required in some states, but again, we endeavor to extend this right to all consumers.)

We do not directly control the sending or initiation of targeted advertising, which is generally performed with cookies and similar technologies.  However, we do sometimes provide personal information that is used in association with cookies and similar technologies for cross-context advertising.

In turn, to opt out of this type of targeting, you may request that we not “sell” your Information (see above instructions).   When you do so we will cease providing your Information for purposes of cross-context advertising.  You may also visit industry websites such as those operated by the National Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA), which provide cookie-based opt-outs in respect to cross-context advertising.  (These opt-out solutions are generally cookie-based and specific to a particular browser, so if you switch browsers, or clear your cookies, you will generally need to refresh your opt-out.).  Finally, to the extent you have enabled a global opt-out preference signal, the providers we work with may recognize that signal to the extent required under applicable state laws.

In addition, to the extent you have enabled a global opt-out preference signal, we will recognize that signal to the extent required under applicable state laws.

Finally, although we do not obtain mobile device information, we work with business partners who may associate the personal information we provide to them with mobile ad identifiers.  You may opt-out of cross-context advertising or targeting performed by these companies through the mobile device settings for Android and Apple iOS devices. To exercise this type of opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android). Also, you may visit  https://youradchoices.com/appchoices to download the AppChoices Tool to control interest-based advertising on apps on your mobile device and https://thenai.org/opt-out/mobile-opt-out/ for more information and instructions on opting out on mobile devices.

Accessing the Personal Information We Have About You

In certain states you may have a right to “access” or “know” about the specific information we hold about you, such as to deliver our Services.   If you would like to request access of your personal information, you may do so by contacting us at 888-993-2285 ext 4 or you may visit our “Data Access Request” page at https://webbula.com/ca-eu-data-request/.

For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights.  For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.

Authorized Agents

If you or (in certain states where required by law) your authorized agent would like to opt out of Webbula’s use of your information for such purposes (to the extent this is considered a sale, share, or targeted advertising), you may do so as outlined on the following page:  https://webbula.com/opt-out-request/ or call us at 800-533-5853.

Sensitive Data

  • Some states, like Colorado, Connecticut, and Virginia, provide their residents (upon the applicable effective dates), the right to opt-in to the processing of their sensitive personal information or personal data. To the extent you believe you may have opted in to the collection of such personal information/data, you can opt out at any time so by providing your email here https://webbula.com/opt-out-request/ or call us at 800-533-5853.
  • Some states, like California and Utah, provide their residents (upon the applicable effective dates), have the right to opt-out of certain uses of their sensitive personal data. You can do so by providing your email here https://webbula.com/opt-out-request/ or call us at 800-533-5853.

In some cases, you may appeal a decision made relating to your rights. Please contact us at privacy@webbula.com or call us at 888-993-2285 ext 4 if you would like to inquire about an appeal.

Nevada Residents

Certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.  If you would like to opt out, you can do so by providing your email here https://webbula.com/opt-out-request/ or call us at 800-533-5853.

 

  1. EU-US DATA PRIVACY FRAMEWORK AND THE UK EXTENSION TO THE EU-U.S. DPF

EU-U.S. Data Privacy Framework Certification: Webbula complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Webbula has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.  We may alternatively process personal data our clients in the EU submit via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. (As to any third-party service providers we may use to process information subject to the EU-U.S. DPF, we may have liability under the EU-U.S. DPF if both (i) the agent processes the information in a manner inconsistent with the EU-U.S. DPF and (ii) we are responsible for the event giving rise to the damage.)

Accessing Your Data: European residents may have certain legal rights to access certain personal data and to obtain its correction, amendment, or deletion. You may contact us via our privacy center or using the contact information below to request access, correction, amendment, or deletion. Because our personnel have limited rights to identify and access an individual user’s personal data that our client has submitted to us, and because we process that data on behalf of our clients, we may first refer you to the client who submitted your data, and we will support them as needed in responding to your request.

Resolution of Complaints: In compliance with the EU-U.S. DPF, Webbula commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to ANA DPF Dispute Resolution, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit ANA DPF Dispute Resolution for more information or to file a complaint. The services of ANA DPF Dispute Resolution are provided at no cost to you.

If neither Webbula nor the ANA DPF Dispute Resolution can resolve your complaint, you may be able to invoke binding arbitration, in accordance with the Data Privacy Framework requirements, through the Data Privacy Framework Panel. For more information on this option, see Annex I of the Principles.

 

 

  1. EUROPEAN UNION REPRESENTATIVE

VeraSafe has been appointed as Webbula’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to using our Privacy Center, however only on matters related to the processing of personal data of EU residents.

To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Czech Republic s.r.o
Klimentská 46
Prague 1, 11002
Czech Republic
 
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
 
  1. UNITED KINGDOM REPRESENTATIVE

VeraSafe has been appointed as Webbula’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the United Kingdom. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of using our Privacy Center, however only on matters related to the processing of personal data of UK residents.

To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London, SE1 7TL
United Kingdom

 
  1. Contact Us

Webbula has a designated privacy contact.  If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:

Webbula, LLC
ATTN: Privacy / Compliance
5000 Stonewood Drive
Suite 310
Wexford, PA 15090
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DATE OF LAST MODIFICATION November 3, 2023