Effective as of December 6, 2023.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” as should be understood accordingly) below.
Information you provide to us. Personal information you mayprovide to us through the Site or otherwise includes:
We may combine personal information we receive from you with personal information we obtain from other sources, such as:
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Site, our communications and other online services, such as:
Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Site.
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Site delivery and operations. We may use your personal information to:
Analytics, research and development. We may use your personal information for research and development purposes, including to analyze your usage of the Site (including which pages are most and least visited and how visitors move around the Site), analyze and improve the Service and our business, to develop new products and services and to train machine learning models and artificial intelligence algorithms. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We, our service providers and our third-party advertising partners, may collect and use your personal information for marketing and advertising purposes.
Events, promotions and contests. We may use your personal information to:
Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events.
Compliance and protection. We may use your personal information to:
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as 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.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
Affiliates. Our affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services such as sweepstakes, raffles, and promotions. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we co-sponsorevents or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Butter, financing of Butter, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Butter as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights in the relevant sections below.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. For information about cookies employed by the Site and how to control them, see our Cookie Notice.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
The Site may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ a number of technical, organizationaland physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
If you are based in Europe, please refer to the Notice to European Users for further details on international data transfers from Europe.
The Site is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Site froma child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Additional personal information we collect in Europe. In addition to the personal information set out in the ‘Personal information we collect’ section above, we may also process:
We receive Transaction Data from our business customers when we provide the Platform to them. We may use Transaction Data for the purposes described in the ‘Our legal bases for processing’ section below.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:
Our Representative in the EU. Our EU representative appointed under the EU GDPR is European Data Protection Office. You can contact them:
Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO UK Ltd. You can contact them:
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.
|Categories of personal information involved
|Site delivery and operations
-Third-Party Source Data
|Analytics, research and development
-Online Activity Data
We have a legitimate interest in understanding how our Service and Platform are being used and who uses our Service and Platform in order to identify patterns and trends to improve the Services
Consent, in respect of any optional cookies used for this purpose
We have a legitimate interest in promoting our Platform and business and sending marketing communications for that purpose
Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to send marketing communications
|Events, promotions and contests
|Contractual Necessity for the purposes of administering the event, promotion and/or contest
We have a legitimate interest in hosting or (co-)running events, promotions and/or contests in order to promote our business and Platform and optimize engagement
|Data sharing in the context of corporate events
|-Any and all data types relevant in the circumstances
We have a legitimate interest in sharing personal information in the context of certain corporate events to ensure the continuity of the Service and the ongoing operation of our business
|Compliance and protection
|-Any and all data types relevant in the circumstances
|Compliance with Law
Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.
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.
When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
Exercising These Rights. You may submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Services, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside your home country.
It is important to note that the U.S. is not the subject of an ‘adequacy decision’ under certain international privacy laws, such as the GDPR, which means that the U.S. legal regime is not considered by certain relevant governmental bodies to provide an adequate level of protection for personal information.
Where we share your personal information with third parties who are based outside your home country, if required by applicable international privacy law, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
Where provided for under applicable international privacy laws, you may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of your home country.