BuzzGram Privacy Policy

Introduction

BuzzGram ("we," "us," "our," or "BuzzGram") is committed to protecting your privacy and ensuring you have a positive experience on our platform. This Privacy Policy ("Policy") explains how we collect, use, disclose, and otherwise process personal information in connection with your use of the BuzzGram platform, including our website at buzzgram.co and any related mobile applications, services, and content (collectively, the "Platform").

This Policy applies to individuals located in Canada and the United States, and it is designed to comply with applicable privacy and data protection laws in both jurisdictions, including:

• In Canada: the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial privacy laws;
• In the United States: the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable state and federal privacy laws.

Please read this Policy carefully. If you do not agree with our privacy practices, you must not use the Platform.

1. Personal Information We Collect

1.1 Information You Provide Directly

When you interact with the Platform, you may choose to provide personal information, including:

• Account Registration Information: Name, email address, password, date of birth, phone number, and residential address (province/state and city).
• Profile Information: Profile photos, business or professional information, interests, and other details you choose to include in your user profile.
• Review and Ratings Data: When you submit a review, rating, or comment about a Business, we collect the content you submit, along with the date, time, and location (if applicable).
• Contact and Communication Data: Messages, inquiries, support requests, and any correspondence you have with BuzzGram customer support or other Users.
• Payment Information: If you choose to use paid features, we collect billing address, payment method details, and transaction history (though payment processing is handled by third-party payment processors; see Section 7 for details).
• Preferences and Settings: Information about your language preferences, notification settings, privacy preferences, and other customization choices.

1.2 Information Collected Automatically

When you use the Platform, we automatically collect certain information about your device and your interactions:

• Device Information: Device type, operating system, browser type, device identifier (such as advertising ID), and device settings.
• Usage Data: Pages or features accessed, links clicked, time spent on the Platform, search queries, and types of content viewed.
• Geolocation Data: Approximate location information based on IP address or, with your permission, precise GPS location. This helps us show you relevant local Businesses in your area. We operate in the following cities: Los Angeles, New York City, Miami, Chicago, and Phoenix (United States) and Toronto, Vancouver, Calgary, Montreal, and Ottawa (Canada).
• Log Data: IP address, access times, referral URL, and pages visited.
• Cookies and Similar Technologies: Information collected through cookies, pixels, web beacons, and similar tracking technologies to recognize you, remember your preferences, and understand how you use the Platform.

1.3 Information from Third Parties

We may receive personal information about you from:

• Other Users: If another User mentions you in a review or comment, or sends you a message through the Platform.
• Service Providers: Third-party service providers who assist with analytics, payment processing, customer service, and marketing.
• Business Partners: Information shared by Businesses or other partners in connection with integrated services or features.
• Social Media Platforms: If you choose to link your social media account to BuzzGram, we may collect information from your public profile with your permission.
• Publicly Available Sources: Information from public directories, government records, or other publicly accessible sources to enhance User profiles or verify information.

1.4 Sensitive Personal Information (United States and Canada)

We do not knowingly collect or request the following categories of sensitive personal information:

• Social Security numbers or similar government identifiers
• Racial or ethnic origin
• Religious or philosophical beliefs
• Biometric information for identification purposes
• Genetic information
• Health or medical information
• Sexual orientation or gender identity
• Financial account information (beyond what is needed for payment processing)

If you inadvertently provide such information, we will take steps to delete or de-identify it promptly.

2. How We Use Your Personal Information

We use the personal information we collect for the following lawful purposes:

2.1 Core Platform Functionality

• Creating and maintaining your account
• Providing, maintaining, and improving the Platform and its features
• Processing and fulfilling your requests
• Delivering customer support and responding to your inquiries
• Sending transactional communications (e.g., account confirmations, password resets, order confirmations)

2.2 Personalization and Recommendations

• Personalizing your experience on the Platform
• Showing you relevant local Businesses based on your location and interests
• Tailoring search results and recommendations to your preferences
• Remembering your preferences and settings

2.3 Analytics and Improvement

• Analyzing Platform usage patterns and User behavior
• Identifying trends and areas for improvement
• Conducting research and analytics to enhance Platform functionality
• Testing new features and services

2.4 Safety and Security

• Detecting, preventing, and addressing fraud, abuse, and security incidents
• Enforcing our Terms of Service and other agreements
• Protecting the rights, property, and safety of BuzzGram, Users, and Businesses
• Complying with legal obligations and responding to lawful requests

2.5 Marketing and Communications (with Consent)

• Sending promotional emails, newsletters, and marketing communications (only if you have opted in)
• Notifying you about Platform updates, new features, or special offers
• Conducting surveys or requesting feedback
• Running contests, promotions, or other marketing campaigns

For Users in California and other U.S. states, and Canada: We will only send marketing communications if you have provided explicit consent. You may withdraw consent and opt out of marketing communications at any time by following the unsubscribe instructions in the email or by contacting us directly (see Section 11).

2.6 Legal Compliance

• Complying with applicable laws, regulations, and legal processes
• Responding to lawful requests from government agencies or law enforcement
• Maintaining records for tax, accounting, and financial reporting purposes
• Establishing, exercising, or defending legal claims

2.7 Aggregate and Anonymized Data

We may use de-identified or aggregated data (data that cannot identify you) for any purpose, including marketing, research, and analytics. This use does not require your consent.

3. How We Disclose Your Personal Information

3.1 Service Providers

We may share your personal information with third-party service providers who assist us in operating the Platform, providing services, and improving our offerings. These include:

• Cloud Storage and Hosting Providers: Amazon Web Services (AWS), Google Cloud, or similar providers that host our Platform and store data
• Payment Processors: Third-party payment processors that handle billing and transactions (e.g., Stripe, Square, PayPal)
• Analytics Providers: Google Analytics, Mixpanel, or similar tools to analyze Platform usage
• Customer Support Platforms: Help desk and communication tools
• Marketing and Email Services: Email marketing providers, advertising platforms, and analytics tools
• Data Security and Fraud Prevention: Services that help detect fraud and protect against unauthorized access

All service providers are contractually obligated to use your information only as necessary to provide services to us and are required to maintain appropriate safeguards.

3.2 Business Partners

If you interact with a Business through the Platform, certain information (such as your name and review content) will be visible to that Business and potentially to other Users.

3.3 Legal Requirements and Enforcement

We may disclose your personal information if required to do so by law, or in response to:

• Court orders or legal processes
• Requests from government agencies or law enforcement
• Investigation of suspected violations of our Terms of Service
• Protection of public safety or the safety of others

3.4 Business Transfers

If BuzzGram is involved in a merger, acquisition, bankruptcy, dissolution, restructuring, or similar transaction or proceeding, your personal information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

3.5 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information (information that cannot identify you) with third parties for research, marketing, analytics, and other purposes without restriction and without your consent.

3.6 Sale or Sharing of Personal Information (CCPA/CPRA Disclosure)

For California Users (and those subject to CCPA/CPRA):

In the past 12 months, we have disclosed the following categories of personal information to service providers, advertising partners, and analytics providers in ways that may constitute a "sale" or "sharing" under the CCPA/CPRA:

• Identifiers (name, email, IP address, cookie identifiers)
• Commercial information (review history, preferences)
• Internet or other electronic network activity data
• Geolocation data
• Inferences drawn from your activity

We do not knowingly sell or share personal information of minors (under age 16).

4. Data Retention

4.1 Retention Principles

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law. The retention period depends on the nature of the information and the purpose for which we use it:

4.2 Data Deletion Upon Request

For all Users: You may request deletion of your personal information at any time, subject to legal and operational limitations. See Section 6 (Your Privacy Rights) for details on how to make a deletion request.

Note: Under Canadian privacy law (PIPEDA), we are not obligated to delete information if it is still necessary for the purposes for which it was collected. However, we will delete information when it is no longer necessary or when you request deletion, except where retention is required by law.

4.3 Secure Destruction

When we delete personal information, we use industry-standard secure deletion methods:

• Digital Data: Encrypted deletion or overwriting using secure protocols
• Cloud Data: Deletion through cloud provider interfaces with automatic purging
• Physical Records: Shredding or incineration
• Anonymization: Where possible, we may retain anonymized data indefinitely

5. Cross-Border Data Transfers

5.1 Data Transfer Notice

Your personal information may be transferred, stored, and processed in Canada, the United States, and other jurisdictions where BuzzGram or its service providers maintain facilities. These jurisdictions may have different privacy laws than your home country.

5.2 Safeguards for Cross-Border Transfers

For Canadian Users:

Under PIPEDA, we ensure that personal information transferred outside Canada receives appropriate protection. Safeguards include:

• Contractual Protections: Data Processing Agreements with service providers that impose privacy obligations equivalent to PIPEDA
• Encryption: Data is encrypted in transit and at rest
• Service Provider Selection: We carefully vet service providers and conduct due diligence
• Notice: We notify you that data may be transferred internationally and accessed by foreign authorities

For Quebec Users (Law 25 Compliance):

If you are a Quebec resident, we acknowledge that Law 25 imposes stricter requirements. We will:

• Conduct Transfer Risk Assessments for data leaving Quebec
• Ensure equivalent protection standards
• Provide explicit notice of transfers to non-Quebec jurisdictions
• Obtain explicit consent for optional processing outside Quebec

For U.S. Users:

We comply with applicable U.S. federal and state privacy laws, including requirements that data not be transferred to jurisdictions or foreign entities with inadequate privacy protections (to the extent applicable).

5.3 Service Provider Locations

Our primary service providers and data processors are located in:

• Canada: Ontario, British Columbia
• United States: New York, California, Virginia
• Cloud Providers: AWS and Google Cloud (multiple data centers, primarily in North America)

6. Your Privacy Rights

6.1 Rights Common to All Users

All Users have the right to:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete personal information
• Deletion: Request deletion of your personal information (subject to legal and operational limitations)
• Opt-Out of Marketing: Opt out of promotional communications at any time
• Data Portability: Request a copy of your personal information in a portable, machine-readable format (where applicable)

6.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a resident of California, you have the following additional rights:

• Right to Know: Request what personal information BuzzGram collects, uses, or shares
• Right to Delete: Request deletion of personal information we have collected from you (with some exceptions)
• Right to Correct: Request that we correct inaccurate personal information
• Right to Opt-Out: Opt out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising
• Right to Limit Use of Sensitive Personal Information: Request that we limit the use of sensitive personal information to necessary purposes
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your privacy rights

For Minors (under 16): California residents under 16 may request that we not sell or share their personal information. Minors between 13 and 16 can provide consent themselves; we require parental consent for those under 13.

6.3 Additional Rights for Canadian Residents (PIPEDA and Provincial Laws)

If you are a Canadian resident, you have the right to:

• Access: Request access to your personal information we hold
• Correction: Request correction of personal information that is inaccurate or incomplete
• Complaint: File a complaint with the Privacy Commissioner of Canada or your provincial privacy commissioner
• Opt-Out of Marketing: Withdraw consent for marketing communications

Note: Canadian law does not provide a general right to deletion, but you may request deletion of information that is no longer necessary for the purposes for which it was collected.

6.4 How to Exercise Your Rights

To exercise any of the above rights, please contact us:

Email: buzzgramco@gmail.com

Mailing Address:
BuzzGram
Toronto, Ontario, Canada

When you submit a request, please include:

• Your full name
• The email address associated with your BuzzGram account
• A clear description of your request
• Proof of identity (we may request additional information to verify your identity)

Timeline for Response:

• Canada (PIPEDA): We will respond within 30 days or explain why we need additional time
• California (CCPA/CPRA): We will respond within 45 days, extendable by 45 days if necessary

6.5 Authorized Agent

If you are a California resident, you may authorize an agent to make requests on your behalf. We may require the authorized agent to provide proof of authorization (such as a power of attorney).

7. Cookies and Tracking Technologies

7.1 Cookies and Similar Technologies

We use cookies, pixels, web beacons, and similar technologies to:

• Recognize you and remember your preferences
• Understand how you use the Platform
• Deliver personalized content and advertisements
• Improve Platform functionality and security
• Analyze Platform performance and user behavior

7.2 Types of Cookies

• Essential/Functional Cookies: Required for the Platform to operate (e.g., login credentials, session management)
• Analytics Cookies: Track usage patterns and performance (e.g., Google Analytics)
• Advertising Cookies: Enable personalized advertisements and measure campaign effectiveness
• Third-Party Cookies: Placed by advertising partners and analytics providers

7.3 Your Cookie Choices

Most web browsers allow you to control cookies through your browser settings. You can:

• Delete existing cookies
• Block all cookies or specific types of cookies
• Receive a warning before cookies are set

Note: Disabling essential cookies may impair Platform functionality. Advertising and analytics cookies are not essential and can be disabled without affecting core functionality.

7.4 Do Not Track (DNT) and Global Privacy Control (GPC)

Some browsers include "Do Not Track" features. We do not currently respond to DNT signals, but we do respect Global Privacy Control (GPC) signals and will honor GPC preferences for opting out of data sales and sharing (for applicable users).

7.5 Opt-Out Links

You may opt out of interest-based advertising through:

• Network Advertising Initiative (NAI): https://optout.networkadvertising.org/
• Digital Advertising Alliance (DAA): https://optout.aboutads.info/

8. Third-Party Links and Services

The Platform may contain links to third-party websites, applications, and services that are not operated by BuzzGram. We are not responsible for the privacy practices of third-party services. This Policy applies only to information collected through the BuzzGram Platform.

When you link to a third-party website or use a third-party service, you are subject to their privacy policy. We recommend reviewing their privacy policies before sharing personal information.

9. Children's Privacy

The Platform is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13, we will take steps to delete such information promptly.

For Users between 13 and 18 (Minors):

• In California, minors between 13 and 16 can provide consent for data collection themselves; those under 13 require parental consent
• Parents or guardians of minors may contact us to review, update, or delete their child's personal information
• We will not sell or share personal information of minors (under 16) for cross-context behavioral advertising

10. Data Security

10.1 Security Measures

We implement industry-standard technical and organizational safeguards to protect your personal information from unauthorized access, alteration, disclosure, and destruction:

• Encryption: Data in transit is protected using SSL/TLS encryption; sensitive data at rest is encrypted
• Access Controls: Only authorized personnel have access to personal information, and access is restricted based on need-to-know
• Firewalls and Intrusion Detection: Multiple layers of security to prevent unauthorized access
• Regular Security Audits: Periodic assessments to identify and remediate vulnerabilities
• Employee Training: Staff are trained on privacy and data security best practices
• Incident Response: We have a protocol in place to respond promptly to security breaches

10.2 Breach Notification

In the event of a personal information breach that poses a risk to your privacy or security, we will notify affected individuals and relevant authorities as required by law:

• Canada (PIPEDA): Notification without unreasonable delay
• United States (State Laws): Notification as required (typically without unreasonable delay)
• Notice Content: Our notification will include information about the breach, the information affected, measures we are taking, and contact information

11. Your Choices and Opt-Outs

11.1 Marketing Communications

You may opt out of promotional emails and marketing communications by:

• Clicking the "Unsubscribe" link in any promotional email
• Logging into your account and updating your communication preferences
• Contacting us at buzzgramco@gmail.com with your opt-out request

Note: Even if you opt out of marketing communications, we will continue to send you transactional emails (e.g., account confirmations, support responses) and important notices.

11.2 Geolocation Data

If you have enabled location services on your device, you can disable them in your device settings. Note that disabling location services may limit certain Platform features that rely on your location.

11.3 Interest-Based Advertising

You may opt out of interest-based advertising by:

• Disabling cookies in your browser settings
• Using the opt-out tools provided by the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA)
• For California residents: Using our "Do Not Sell or Share My Personal Information" link (to be included on the Platform homepage)

12. Policy Updates and Changes

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the updated Policy on the Platform with a new "Effective Date"
• Notify you via email if the changes are significant
• For major changes affecting your rights, we may require your explicit consent

Your continued use of the Platform after the updated Policy becomes effective constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Email: buzzgramco@gmail.com

14. Regulatory Contact Information

If you have a privacy complaint or wish to report a potential violation, you may also contact the relevant privacy authority:

Canada:

• Privacy Commissioner of Canada: https://www.priv.gc.ca/
• Ontario Information and Privacy Commissioner (for Ontario residents): https://www.ipc.on.ca/

United States:

• California Privacy Protection Agency (for California residents): https://cppa.ca.gov/
• Federal Trade Commission (FTC): https://www.ftc.gov/

15. Jurisdiction-Specific Supplements

15.1 Additional Disclosures for Quebec Residents

If you are a resident of Quebec, please note:

• Quebec's Law 25 (Loi Modernisant la Loi sur la Protection des Renseignements Personnels dans le secteur privé) imposes additional requirements
• You have the right to request a "Transfer Risk Assessment" if your information is transferred outside Quebec
• You may withdraw consent for non-essential processing by contacting our Privacy Officer
• For more information, visit: https://www.cnil.fr/ or contact the Commission d'accès à l'information du Québec

15.2 Additional Disclosures for Alberta Residents

If you are a resident of Alberta, please note:

• The Personal Information Protection Act (PIPA) applies in Alberta
• We provide notice of our policy regarding cross-border transfers of information
• You may contact our Privacy Officer regarding cross-border transfer practices

15.3 Additional Disclosures for British Columbia Residents

If you are a resident of British Columbia, please note:

• The Personal Information Protection Act (PIPA) applies in British Columbia
• You have the right to access and request correction of your personal information
• Contact the Office of the Privacy Commissioner of British Columbia for complaints: https://www.oipc.bc.ca/

Acknowledgment

By using the BuzzGram Platform, you acknowledge that you have read and understood this Privacy Policy and consent to our collection, use, and disclosure of your personal information as described herein.