General Privacy Policy

1. General

1.1 This general privacy policy (the “Privacy Policy”) contains information about how Bumpa collects, uses, stores, discloses and or processes your personal information through devices, products, services, applications and other mediums affiliated to Bumpa.

1.2 The General Terms of Use, Acceptable Use Policy, and Merchant Terms of Service (where applicable) are incorporated by reference into this Privacy Policy.

1.3 In our mission to make commerce better for everyone at Bumpa, we collect and use information about you, our

• merchants using Bumpa to power your business

• customers who shop at a Bumpa-powered business

• visitors to Bumpa’s websites, or anyone contacting Bumpa support

1.4 This Privacy Policy will help you better understand how we collect, use, and share your personal information. If we change our privacy practices, we may update this Privacy Policy. If any changes are significant, we will let you know (for example, through the Bumpa admin or by email). If you are a Merchant, please also see the Merchant Privacy Policy. If you are a customer of a Bumpa Merchant, you should please read our Customer Privacy Policy, in addition to reading that Merchant’s Privacy Policy. If you are a visitor to our Website, please see the Visitor Privacy Policy. The Merchant Privacy Policy, the Customer Privacy Policy and the Visitor Privacy are as applicable incorporated by reference into, and form an intrinsic part of, this Privacy Policy.

1.5 Any capitalized terms used in this Privacy Policy, not defined herein, have the meanings assigned in the General Terms of Use or the Merchant Terms of Service, unless the context specifically requires otherwise.

2. Application of the Privacy Policy

2.1 This Privacy Policy applies to systems, operations and processes of Bumpa that involve the collection, use, storage, handling and disclosure of personal information. This Privacy Policy applies generally to the business of Bumpa and serves to set out our approach to personal data, inclusive of personal data of our consumer-users (“Users”). For our Users, this Privacy Policy is part of our Terms of Service as it applies to the use of our Services.

2.2 This Privacy Policy applies to your use of (regardless of means of access to) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”). This Privacy Policy also applies to offline interactions with Bumpa.

2.3 By accessing or using any of our Services, you agree to this Privacy Policy.

2.4 This Privacy Policy does not apply to services that are not owned or controlled by Bumpa, including third-party websites and the services of Bumpa’s Merchants.

3. Why we process your information

3.1 We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the Bumpa platform), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). Some legal systems call these reasons “legitimate interests.” These “legitimate interests” include:

• preventing risk and fraud

• answering questions or providing other types of support

• helping merchants find and use products

• providing and improving our products and services

• providing reporting and analytics

• testing out features or additional services

• assisting with marketing, advertising, or other communications

3.2 We only process personal information for these “legitimate interests” after considering the potential risks to your privacy — for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

3.3 One of the ways in which we are able to help merchants using Bumpa is by using techniques like “machine learning” (some legal systems refer to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications.

3.4 We may process your personal information where you have provided your consent, in particular, where we cannot rely on an alternative legal basis for processing, where your data is sourced and it already comes with consent or where we are required by law to ask for your consent in the context of some of our sales and marketing activities. At any time, you have a right to withdraw your consent by changing your communication choices, opting out from our communications or by contacting us.

4. Categories of information Bumpa collects and how we collect it

4.1 The personal data we collect depends on how you interact with us, the Services you use, and the choices you make. We may collect information from different sources and in various ways, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

4.2 Bumpa collects the following broad categories of information

• Information provided to us by you;

• Information about your transactions;

• Information from third parties; and

• Information automatically collected.

• Information provided to us by you

4.3 Generally, you can visit our Websites and mobile applications without telling us who you are or revealing any information about yourself. When you submit an inquiry to us via any means, register a Bumpa account, register to attend a Bumpa event, interact with us on social media, partake in competitions and promotional activities and volunteer information to us, we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, image and other information that identifies you (collectively, “Personal Information”). By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.

4.4 As a User, we will also ask you to create login information for your Bumpa account, such as a username and password. When you provide your mobile phone number, we may ask for your consent for us to send you text messages relating to our Services on that number.

4.5 Generally, we collect Personal Information you give us by filling in forms or by communicating with us by phone, email, social media posts and messages, and other mediums.

Information about your transactions

4.6 We collect Personal Information about your transactions with us and others through our Services.

Information from third parties

4.7 We also collect Personal Information about you from other companies or entities. For instance, we may receive Personal Information about you from a consumer reporting agency or we may collect Personal Information from your employer where your employer is providing a service to Bumpa or is using any of our Services.

4.8 We may collect your Personal Information from a User where your Personal Information is filled in a Next-of-Kin form.

Information automatically collected

4.9 We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

4.10 Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Bumpa account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

• The Device's Internet Protocol (IP) address

• Identification numbers associated with your Devices

• Device event information, such as crashes, system activity, and hardware settings

• Location preferences

• Date and time stamps of transactions

• System configuration information and

• Other interactions with our Services

5. Information collected through Cookies and other similar technologies

5.1 Our Services may use cookies and tracking technology depending on the features offered. Cookie and tracking technology are useful for information such as browser type and operating system, tracking the number of visitors to our Website, and understanding how visitors use the Website. Cookies can also help customize the Website for visitors. Personal Information cannot be collected via cookies and other tracking technology. However, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

5.2 We and our partners use cookies and similar technologies on our Website to help collect information and operate the site. We use cookies to remember Users and make your user experience easier; customise our Services, content and advertising; help you ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website. Cookies are small text files placed by a website and stored by your browser on your device.

5.3 We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services.

5.4 The cookies we use in connection with our Services include:

• Session cookies

• Persistent cookies and

• Third party cookies

Session cookies

5.5 Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant Users access to content and to enable actions they must be logged into their Bumpa Account to perform.

Persistent cookies

5.6 Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire, or you manually delete them. We use persistent cookies to better understand usage patterns so that we can improve our Services. For example, we may use a persistent cookie to associate you with your Bumpa Account or to remember your choices for our Services.

Third party cookies

5.7 We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and User demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

5.8 By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

6. How We Use Information

We may use Analytics for research and commercial purposes, such as to improve our Services. We may use Personal Information for the purposes described in this Privacy Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and products and services of third parties that we think you might find of interest. Only Bumpa and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose. We may use your email address to respond to your inquiries and to provide information about our Services. You may elect not to receive promotional emails from us either by “unsubscribing” to an email you receive from us or by contacting us as indicated below. As a User, if you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your Bumpa Account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Service.

7. How We Share Information

7.1 Bumpa does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your personal data with a third party without your consent except as necessary to provide the Services or as described in this Privacy Policy.

Merchants: We may share your contact information with merchants as part of your purchase details for record purposes. We will not share this information with other third parties except as a necessary part of providing our website and services. We do not share your card information with merchants. Please review your merchant’s privacy policy to understand the privacy policies guiding the merchant you transact with.

Service providers: We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support, to assist in protecting and securing our systems and services, or to perform sanctions screening and identity verification services may need access to personal data to provide those functions. The processing by such third parties shall be governed by a written contract with Bumpa to ensure adequate protection and security measures are put in place for the protection of personal data in accordance with the terms of this Privacy Policy.

Financial services & payment processing: When you provide payment data, for example to make a purchase, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.

Affiliates: We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our Services and operate our business.

Corporate transactions: We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

Legal and law enforcement: We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.

Security, safety, and protecting rights: We will disclose personal data if we believe it is necessary to:

• Protect our customers and others, for example to prevent fraud, or to help prevent the loss of life or serious injury of anyone;

• Operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or

• Protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

7.2 We may share your Personal Information with unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) for our everyday business purposes; or (4) for publication of our events and competitions on digital and print media. We also share your Personal Information with delivery companies and may publish your image where you have won a gift in our competitions, giveaways and promotions or as permitted by applicable law or otherwise described in this Privacy Policy.

7.3 Third party analytics and advertising companies also collect personal data through our website and apps including, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. These third party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our Website to help us understand how users interact with our Website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

7.4 Finally, we may share de-identified information in accordance with applicable law.

7.5 Please note that Merchants, sellers, and other Users you buy from or contract with have their own respective privacy policies, and although Bumpa’s Merchant Terms of Service does not allow the other transacting party to use your information for anything other than as authorised by you, Bumpa is not responsible for their actions, including their data protection practices. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy policies. If you are a customer of a Bumpa Merchant, you should read that Merchant’s privacy policy and direct any privacy inquiries to that Merchant. If you are a Merchant, please see the Merchant Privacy Policy.

7.6 When you are no longer our User, we may continue to share your information as described in this Privacy Policy.

7.7 We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

8. Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of this Privacy Policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that if you are a User, you are not able to opt out of receiving communications about your Bumpa Account or related transactions with us.

9. Other Rights to your Personal Information with Us

9.1 Beyond your right to opt out of our processing of your Personal Information, you also have the option of exercising any of the below rights with respect to your Personal Information:

Request correction of your Personal Information

9.2 We respect your wishes to correct inaccurate information and as such, you must notify us of any change in your Personal Information. If you are a User, you can change some of your Personal Information by updating your Bumpa Account profile through our Services. If you are not a User, you can contact us as indicated at the end of this Privacy Policy to make any changes or request on Personal Information we hold about you. Any changes will affect only future uses of your Personal Information and we may need to verify the accuracy of the new data you provide to us.

Request access to your Personal Information

9.3 You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Request us to refrain from doing certain things with your data or restrict the extent of our collection or processing of your data.

9.4 You may object to the processing of your Personal Information where you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request partial or complete erasure of your Personal Information.

9.5 You may request for us to delete or remove Personal Information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note however that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Request the transfer of your Personal Information to another party.

9.6 You possess the right to request us to transfer your Personal Information to third parties in limited circumstances. But we may not always be able to comply with your request of transfer for specific legal or other reasons which will be notified to you, if possible. You may also object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.

9.7 Your request will be reviewed and answered by Bumpa’s Data Protection Officer within a 30-day period.

10. Information you share on Social Platforms

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends. Our Services may also allow you to connect with us on and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

11. Security and Storage of your Personal Information

11.1 We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your Personal Information on our instructions. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11.2 We require from our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration. But no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Bumpa Account and do not share them with others. If we receive instructions using your Bumpa Account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Bumpa Account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Bumpa Account, and to remove or edit your content.

11.3 Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will retain your Personal Information for as long as is necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

12. Data Retention

We retain Personal Information about you for as long as you have a Bumpa Account with us or as otherwise necessary to provide you Services. In some cases, we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule, or regulation. Afterward, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means, and the applicable legal requirements. We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain the data for a longer period.

13. Protecting Children's Privacy

Our Services are not directed, or intended to be attractive, to children under the age of eighteen (18). We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

14. Links to Third-Party Websites

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

15. Changes to our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

16. How can I contact Bumpa?

If you have any questions, comments, complaints or concerns with respect to your Personal Information or this Privacy Policy, please contact us by mail at our operational address, by email to [email protected] or through Bumpa Support.

Last updated on: 25 November 2022