Last modified: May, 2021
CBB Inc. and its fully owned subsidiary, C.B.B Ltd. (“CBB”, "us", "our"or "we") offers algorithm-based solutions and financing schemes to drive e-commerce sellers’ activities (the "Services"),and it is committed to respecting its clients and online users’ privacy rights.
1. THE INFORMATION WE COLLECT
Such collection of Personal Information may include:
1.1. your name, age/date of birth and gender, professional experience;
1.2. your contact details; postal address including billing and delivery addresses; telephone numbers(including mobile numbers) and e-mail address;
1.3. your online browsing activities on our Website;
1.4. your password(s);
1.5. your interests, preferences, feedback and survey responses;
1.6. your location;
1.7. your correspondence and communications with CBB; and
1.8. other publicly available personal data, including any which you have shared via a public platform (for example, your LinkedIn profile).
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
2.1. CBB collects information, including Personal Information, during the registration process to our Service, and your online brewing activities on our Website.
2.2. CBB may also collect billing and account information such as credit cards, payment cards or other payment methods from Clients, and share this information with our billing and payment processors.
2.3. We do not store credit card or payment card numbers after they have been forwarded to our billing and payment processors.
2.4. Cookies. Like many other websites, CBB uses “cookies” to collect data in order to provide our users with a personal experience when accessing our Website.
What are Cookies? Cookies are small data files which are sent to your device (e.g., computer or mobile device) by a website or other online application, to enable the storing of information which uniquely identifies you(e.g., remembering web pages that you have viewed).
How do you disable cookies? If you want to disable cookies, you will have to change your browser's settings to reject cookies.Please note that if you disable all cookies, some (or all) of the features and functionality of our Service may not be available to you.
Below are links to commonly used web browsers. Information about cookies is usually found in the “Help” section of the web browser.
For other browsers, please consult the documentation that your browser manufacturer provides.
Mobile Devices – You can-opt out of certain types of interest-based advertising (or “cross-app” advertising), by accessing the“settings” on your device:
If you’re using an Apple device you can configure your device to limit ad tracking to by clicking on “settings” >“privacy” > “advertising” and toggling “limit ad tracking” to ‘on.’
If you’re using anAndroid device you can opt out of most app-based tracking for advertising by opening the “GoogleSettings” app on your device, selecting “Ads”, and then selecting the option to opt-out of interest-based ads.
Please note that the above information may change when the above manufacturers updates their systems. Also note, that your device may use another platform, not described above. In that case, please consult the manufacturer documentation for further instructions.
You can also learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party webpages:
3. HOW WE USE YOUR INFORMATION
3.1. CBB (and its fully owned subsidiary C.B.B Ltd.) uses your Personal Information for its legitimate interests, as follows:
3.1.1. To provide our Service.
3.1.2. To audit and improve our Service.
3.1.3. To manage any registered account(s) that you hold with us.
3.1.4. To perform marketing activities, including, the use of web banner advertisements and targeted ads, all as set forth in Section3.5 below.
3.1.5. To verify your identity.
3.1.6. For crime and fraud prevention, detection and related purposes.
3.1.7. With your agreement, to contact you electronically about promotional offers, products, and services which we think may interest you, as well as send you periodic updates, tips, reports and Newsletters (as defined below).
3.1.8. For market research purposes - to better understand your needs.
3.1.9. To enable the team of CBB to interact with you.
3.1.10. Where it has a legal right or duty - to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
3.1.11. For customer relations, queries, complaints, or disputes, including providing support.
3.1.12. For managing insurance claims.
3.1.13. Cybersecurity needs, fraud detection and misuse of our Website.
3.1.14. Enhancements and improvements to your and others experience with our Website.
3.2. Marketing (Promotional communications)
3.2.1. CBB uses your Personal Information for electronic marketing purposes (with your consent) and may send you electronic mail to update you about promotional offers, products and services which we think may interest you and relevant to you as an individual (the "Newsletters").
3.2.2. You are not obligated by law to receive our Newsletters and you have the right to opt out of receiving such communications at any time, by:
220.127.116.11. following the unsubscribe instructions included in each Newsletter; and/or
18.104.22.168. contacting CBB via firstname.lastname@example.org.
3.3. Sharing your information with third parties
3.3.1. We may use and share your name, business name, e-mail address and other information related to the Service (in this Section 3.3, the "Information") with certain third parties that help us operate our Service, such as cloud providers, newsletter distribution service providers and other similar service providers.When we use such third parties, we restrict them from using or disclosing theInformation, except as required to perform the services on our behalf or to comply with legal requirements.
3.3.2. Other than as described in this Section 3, CBB will not disclose yourInformation to any third party.
3.3.3. We will never sell or lease our customers' data to other organisations for marketing purposes.
3.3.4. We may share your data with:
22.214.171.124. governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so (a) to comply with our legal obligations; (b) to exercise our legal rights (for example in court cases); (c) for the prevention, detection, investigation of crime or prosecution of offenders; and (d) for the protection of our employees and customers.
126.96.36.199. If CBB becomes involved in a merger, acquisition, or any form of sale of some, or all, of its assets, it may transfer all the Information that was collected from users in connection with such a transaction.
3.3.5. We may post our own Clients' testimonials on our Website which may contain personally identifiable information. We will obtain your consent to post your name along with its testimonial (unless such information was made public by you).
3.4. International transfer of information
3.4.1. For US-residents. CBB is a US-based company. To deliver our Services to you, it may sometimes be necessary for us to share your data outside of the United States. CBB is providing access to your data, to its fully owned subsidiary C.B.B Ltd., which is located in theState of Israel. These transfers are subject to special rules under data protection laws.
3.4.2. For EU-residents. CBB is a US-based company. To deliver our Services to you, it will be necessary for us to share your data outside of the European Economic Area. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here.
3.5. Advertising andAnalytics Services.
3.5.1. CBB may use standard analytics tools such as Google Analytics, Facebook Business, Chart beat, Polar, PostUp, LiveIntent, Parse.ly, Outbrain, Quantcast, and Lytics, etc. to learn more about how you and other users use our Service, and how we should improve our user experience. CBB and its third-party partners and vendors may use tracking technologies or methods of web and mobile analysis(such as pixels, beacons, etc.) to collect, track and store certain information about you when you use or interact with our Services, communications, content or third party’s websites links, to provide you with targeted advertising based on your interests and browsing activities on our Website, personalize the advertising content, and to serve you advertisements that are relevant to your regional location.
3.5.2. YourIP address or mobile device identifier will be automatically shared with such third parties when you access the Services or the third party’s websites.
3.5.3. These tools maintain their own privacy practices in accordance with their own privacy policies to provide their service. Further information about how Google uses data when you use our Service, can be found here.
3.5.4. If you do not want us to share yourPersonal Information for marketing and advertising purposes, you may opt-out in accordance with provisions below section below or contact us using the details provided below. Please note that even if you unsubscribe, we may still use and share your Personal Information with third parties for non-marketing purposes(for example to fulfill your requests and orders, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Information are authorized to use your Personal Information only as necessary to provide these non-marketing services.
3.5.5. How to opt-out?
188.8.131.52. Emails. If you no longer wish to receive emails from us, you may opt out of receiving them at any time, by clicking ‘unsubscribe’ on any e-mail communication, or sending an email with your request to email@example.com.
Please note that even if you opt out of receiving marketing communications by postal mail, we may continue to send you transactional communications about your subscription or orders by postal mail.
184.108.40.206. Turning Off TrackingTechnologies.You can choose to have your computer warn you each time a persistent or session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser’sHelp menu to learn the correct way to modify your cookies as described inSection 2.4 above.
3.7. We reserve the right to disclose your information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, or court order. Also, please note that we may disclose general, aggregated, non-personal and non-identifiable information about our users to potential business partners, investors, or the public.
4. HOW LONG WE KEEP YOUR DATA
4.2. Without derogating from the aforementioned, CBB will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any PersonalInformation is seven (7) years.
4.3. When you send an email or other communication to firstname.lastname@example.org or any other correspondence that you have with us, we may retain those communications to process and respond to your requests and improve our Service.
4.4. Please DO NOT send us any communication which contains confidential or sensitive information, since we are unable to evaluate whether your content constitutes as confidential or sensitive information, or not, and we may retain or use such communication as described herein above, and such retention or use shall not be deemed as a breach of any of our obligations pursuant to this Policy.
5. INFORMATION SECURITY STANDARD
5.1. Because we value your privacy, CBB uses industry standard measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of data which is stored in our records. These measures include internal reviews of our data collection, storage and processing practices and standard measures.
5.2. Nonetheless, we cannot guarantee a perfect and absolute security measure, as no method of transmission over the Internet and or electronic storage is perfectly secure or invulnerable. However, should we become aware of a security breach, we will notify any affected user, so that they can take appropriate protective steps.Such notification shall be issued by CBB in accordance with the applicable(local) laws and regulations, as well as CBB's internal policies.
5.3. Physical Standard. CBB follows Amazon’s Privacy and Security Policy security standards with respect to physical access. You can read more about it here.
6. HOW YOU CAN HELP PROTECT YOUR DATA
6.1. First, please remember that CBB will never ask you to confirm your account password, bank account or credit card details via email or text message. If you receive such communication asking you to provide such information, please ignore it and do not respond. You can let us know you received such communication by emailing email@example.com.
6.2. If you are using a device in a public location, we highly recommend that you always log out and close the browser after completing your session.
7. YOUR RIGHTS IN CONNECTION WITH YOUR INFORMATION
7.1. You have the right to request that CBB will provide you with a copy of any Personal Information that we keep about you.
7.2. You have the right to ask that CBB shall update and correct any outdated or inaccurate PersonalInformation that we keep about you. Should you find that the PersonalInformation related to you is not accurate, complete, or updated, then please provide us the necessary information to correct it.
7.3. If you wish to exercise any of the rights set forth in this Section 7, please notify us via email to firstname.lastname@example.org and we will use commercially reasonable efforts to accommodate your request. CBB shall not charge you for requesting to exercise any of the rights set forth in thisSection 7.
8. SPECIFIC PROVISIONS FOR EU-RESIDENTS
8.1. This Section 7applies to citizens of the European Union which resides in the EU. CBB adopted these provisions to comply with the EU 2016/679 Directive General DataProtection Regulation (“GDPR”),pursuant to which CBB will be considered as a "Data Controller" with respect to our use of your Personal Information.
8.2. Legal Basis. We base our processing of personal data as a Data Controller on the following lawful grounds:
8.2.2. CBB may collect and use your Personal Information when it is necessary for one of the legitimate uses set out in Section 3 above, which we believe are not overridden by your fundamental rights. For example, we may process your Personal Information as a preliminary necessary step prior to initiating an engagement with you as ourClient.
8.2.3. We may process yourPersonal Information to comply with a legal obligation and to protect our users' vital interests.
8.2.4. If, at any time, you wish to exercise your rights in accordance with the provisions provided by law(including as provided under Section 7 of this Policy) you may send us an email to email@example.com and request:
220.127.116.11. To access your PersonalInformation together with information about how and on what basis such information is being processed. Should you desire to receive such information in a different format than the one that was provided to you, you can email us at firstname.lastname@example.org and we shall use commercially reasonable efforts to accommodate your request, if applicable.
18.104.22.168. To rectify any of thePersonal Information being held when such information is inaccurate.
22.214.171.124. To delete or restrict access to Personal Information related to you in limited circumstances as described under the GDPR. Please note that if we need to delete any PersonalInformation related to you following your request, it can take time until we completely delete residual copies of Personal Information from our servers and backup systems.
126.96.36.199. To withdraw your consent to the processing of your Personal Information. However, please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal.
188.8.131.52. The transfer of PersonalInformation related to you in accordance with your right to data portability.
184.108.40.206. To object to the processing of Personal Information related to you, for example in relation to direct marketing (Newsletters) or if you believe that we have no legitimate reasons to use or hold such information.
8.3. Please note that you have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
8.4. If you have any concerns about how we process your Personal Information, or if you wish to withdraw your consent for any reason, kindly let us know by sending an email to email@example.com.
8.5. CBB shall not charge you for requesting to exercise any of the rights set forth in this Section 8.
9. SPECIFIC PROVISION FOR CALIFORNIA RESIDENTS
9.1. This Section 0applies to you only if you reside in the State of California, United States.CBB adopted the following provisions to comply with the California ConsumerPrivacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section 0.
9.2. The following categories reflect to type of Personal Information's categories which we have collected within the last twelve (12) months:
9.2.1. Identifiers and Personal information as listed in the California Customer Records statute (Cal. Civ.Code § 1798.80(e)), for example, first names, sure names, alias, signatures, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account names and financial information.
9.2.2. Electronic network activity information, including, but not limited to, browsing history, search history and any additional information related to your interaction with ourWebsite, location data, etc.
9.3. We have obtained suchPersonal Information as listed above from the following sources:
9.3.1. Directly from you(including as part of the Client Evaluation Process), or indirectly through your browsing activity on our Website.
9.3.2. Third parties such as our reliable service providers and professional advisers or as part of the Information Access Rights you have granted to us.
9.4. We use the PersonalInformation we collect or receive for our legitimate interests (as set out inSection 3 above), which we believe are not overridden by your fundamental rights. We may also disclose such Personal Information to third parties for our legitimate purposes as described in Section 3 above.
9.5. In the preceding twelve(12) months, CBB has disclosed the following Personal Information for its business purposes:
9.5.2. Personal Information's categories as listed in the California Customer Records statute.
9.5.3. Internet or another similar network activity.
9.5.5. Growth Plan details.
9.6. In the preceding twelve (12) months, CBB has not sold your Personal Information.
9.7. Your rights as aCalifornia Resident. As a California resident, you are entitled to request the following specific rights under the CCPA, solely with respect to PersonalInformation related to you:
9.7.1. Request to know (a) what categories and specific components of Personal Information we collect about you and from which sources; (b) categories of Personal Information that we disclosed for the purpose described in Section 3 above, and the categories of third parties with whom we have shared any particular category of your PersonalInformation. If we disclose any of your Personal Information to a third-party, we will provide you, after authenticating your identity, with a list that will identify the specific category of your Personal Information which was disclosed.
9.7.2. Request that we delete any Personal Information we collect about you. After authenticating your identity, we will delete (and direct our service providers to delete) anyPersonal Information related to you from our records, unless an exception applies. Please note that if we need to delete any Personal Information related to you following your request, it can take time until we completely delete residual copies of Personal Information from our servers and backup systems.
9.7.3. Instruct us not to sell any Personal Information related to you that was collected by us.
9.7.4. You have the right not to be discriminated against by CBB, for exercising your rights under the CCPA.
9.8. If you have any concerns about how we process Personal Information related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to firstname.lastname@example.org. Please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal. Also, please note that CBB shall not charge you for requesting to exercise any of the rights set forth in thisSection 9.
If you believe that we have not adhered to our Policy as outlined herein, please notify us by email to email@example.com. CBB will review any query and make commercially reasonable efforts to resolve any existing or potential dispute.
Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location, and therefore we may ask you to provide us credentials to make sure that you are who you claim to be, thus we may further ask questions to understand the nature and scope of your request.
11. CHANGES TO THIS POLICY
We reserve the right to change this Policy from time to time, so please review it frequently. If we make material changes to this Policy, and you are a registered user of the Service, we will notify you by email when we make any changes.
12. GOVERNING LAW
ThisPolicy shall be construed in accordance with and governed for all purposes by the substantive laws of the State of Texas, US, without regard to conflicts of law provisions. You agree that any claim or dispute you may have against theCompany and its affiliates, directors, officers, employees, and representatives must be resolved by a court located in Austin, Texas, US and waive any jurisdictional, venue or inconvenient forum objections to such courts.
13. CONTACT US
If you have any questions about this Policy, please contact us via firstname.lastname@example.org.