Effective Date: February 10, 2021
We provide our clients a platform to reduce customer churn. We collect limited technical information related to payment that does not identify the End User and process such information to reduce customer churn. The End User may choose to enter additional information, such as their email address and month and day of birth.
Later, when the End User makes a payment at another Butter client, we may automatically recognize them, which enables us to provide enhanced churn reduction and other services described below.
In addition to the above, our clients may provide us with personal data (usually about their current and potential customers), such as customer contact or point-of-sale information. As permitted by applicable law, we may also collect information from third-party sources (such as social networking platforms). We may enhance the data we receive from or on behalf of a particular client with data that we receive from other data sources or that we have inferred or modeled ourselves.
Cookies and Other Technologies:
If you are interested in more information about tailored browser advertising and how you can generally control certain cookies from being put on your device to deliver tailored advertising, End Users may visit the Network Advertising Initiative’s Consumer Opt-Out Link, the Digital Advertising Alliance’s Consumer Opt-Out Link or the European Interactive Digital Advertising Alliance Opt-Out Link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, an End User can visit the Google Ads Settings page. Please note that they will still receive advertising content even if they opt out of tailored advertising. Also, we do not control the four opt-out links above and are not responsible for any choices made using these mechanisms or the continued availability or accuracy of these mechanisms. If a browser is configured to reject cookies when visiting an opt-out page, or an End User subsequently erases cookies, or uses a different computer or changes web browsers, the opt-out may no longer be effective. Additional information is available on the websites accessible by the above links.
Uses of Information
We use the information described above (sometimes in combination with other information we obtain) for the following business and commercial purposes:
2. Privacy Practices for Information We Collect on Our Own Websites
We collect information, including when clients or customers provide information directly to us and when we passively collect information.
Visitors to our website may submit contact information, such as their name, address, email address and phone number, as well as information required to make payments. They also may submit information about their business.
Job applicants on our site may submit their employment details and other information typically found in résumés. On a strictly voluntary basis, job applicants can also submit responses to certain demographic and life-history questions that we ask for equal employment compliance purposes.
Section 1 above describes the collection of various types of information from website visitors using automated technologies (such as cookies). On our website, we and our third-party providers may collect the same sorts of information, using the same sorts of automated technologies, for the same sorts of purposes, and with the same opt-out options.
Uses of Information
We use the information collected on our website (sometimes in combination with other information we obtain) for the following purposes:
3. Additional Information about Privacy Practices
Disclosures of Information
We disclose information as described below:
To Our Clients. When we collect information for or on behalf of a client, we may share certain information with that client to help our clients learn more about their current customers, and to assist them (or others) in identifying trends, inferences, affinities or patterns among customers (whether those customers are identified, de-identified or aggregated). We also share anonymized data (e.g. when churn reduction is optimized) among our clients to assist them in communications and marketing activities (such as to provide content recommendations and optimization, ad targeting, and other promotional activities).
Affiliates. We may share information with our affiliates who provide services to us.
To Agents & Contractors. We may share information with third parties that help us operate our business and provide our services, such as contractors that provide us with technology, services, data or content (e.g., a hosting provider).
For Legal Reasons. We may share information when we believe that doing so is appropriate to comply with the law; enforce or apply our agreements; or protect the rights, property, or safety of Butter, our clients, our employees, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Changes in the Structure or Ownership of the Company or its Assets. We may transfer the information we hold in the event we sell or transfer all or a portion of our business or assets (such as in connection with a merger, acquisition, reorganization, dissolution or liquidation) or take steps in anticipation of such a transaction.
Aggregated or De-identified Information. We may share aggregated or de-identified data without restriction.
At a Client’s Request. At the request of a client, we may also make additional disclosures of information we hold for that client.
Consent or Legal Permission. We may engage in additional sharing of information with the consent of the individual to whom it pertains or when otherwise permitted by law.
OUR LEGAL BASES FOR USE OF YOUR INFORMATION
The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:
Opt-out and Privacy Rights
Your Legal Rights Under Local Laws:
Residents of the European EU and European Economic Area Countries
Your local laws (e.g., laws of the E.U.) may permit you to request that we:
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
To exercise any of these rights, please contact us as described in the “Contacting Us” section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
Please see below for details on rights for California residents.
How long we keep information
We generally retain information for so long as it may be relevant to the purposes above and in compliance with applicable law. To dispose of any personal data, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional period of time.
If you believe that any child under 13 has provided us with any personal information, we ask that the parent or guardian of that child contact us to ensure that such information is deleted from our files in accordance with applicable law. We also will honor similar requests from parents and guardians in jurisdictions where the age threshold provided by law is 16 or higher.
1 Letterman Dr Bldg C
San Francisco CA, 94129.
Supplemental Privacy Notice for California Residents
Summary of Information We Collect
California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.
We or our service providers may collect the below categories of information for the following business purposes (as those terms are defined in applicable law):
We may also use the personal information we collect for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
Butter may collected the following categories of personal information about California consumers:
We collect personal information from the following categories of sources:
We may share each of the categories of personal information identified above to the following categories of third parties for business purposes:
Our clients also receive personal information about End Users directly from the End Users or where End Users direct us to share their data.
If End Users are a California resident, they may have certain rights. California law may permit you to request that we:
They may have the right to receive information about the financial incentives that we offer, if any. They also have the right to not be discriminated against (as provided for in applicable law) for exercising certain rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services. If clients ask us to delete it, they may no longer be able to access or use the Services.
If an End User would like to exercise any of these rights, please submit a request at www.butterpayments.com. They will be required to verify their identity before we fulfill their request. They can also designate an authorized agent to make a request on their behalf. To do so, they must provide us with written authorization or a power of attorney, signed by them, for the agent to act on their behalf. They will still need to verify their identity directly with us. Please note that we cannot honor requests with respect to personal information that we process on behalf of our clients as a service provider. For such data, they need to contact our clients directly.
California residents may opt out of the “sale” of their personal information. Butter does not “sell” personal information as we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations.
California Shine the Light
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If they would like to make such a request, please contact us at www.butterpayments.com.
California Do-Not-Track Disclosure
We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.