Bamboo Privacy Notice

Welcome to Bamboo, where you create unique feeds for anything you care about. This Privacy Notice explains how the Bamboo application (“Bamboo”) provided by Nowbase, LLC (“Nowbase,” “us” or “we”), treats your information and your options to exercise your privacy rights. If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@nowbase.com. 

This Privacy Notice is governed by and part of our Terms of Use. Note that this Privacy Notice does not apply to any third-party platforms or services, or any third-party services linked or accessible from our Services. 

1. Personal Data. In this Privacy Notice, “Personal Data,” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:
   
   a) Identifiers (e.g., name, email, telephone number, address, username);
   
   b) Sensitive Personal Data (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
   
   c) Legally protected information (e.g., race, citizenship, marital status, sex);
   
   d) Employment-related information (e.g., current or past employment);
   
   e) Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
   
   f) Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
   
   g) Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); 
   
   h) Internet or other similar activity (e.g., browsing history; content interactions); and
   
   i) Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes. 
   
   Not all information about you qualifies as Personal Data. Depending on where you live, publicly available information, aggregated information (meaning data summaries or reports with Personal Data removed), employment-related information, or anonymized information (that cannot be linked back to you as an individual) may not legally qualify as Personal Data.

2. Bamboo is for users 16 and older. Bamboo is designed for users 16 years and older. Children under age 16 should not download, register, or use Bamboo in any manner, or provide any Personal Data to us. If we learn we have collected or received Personal Data from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@nowbase.com.
   ‍
3. Personal Data on Bamboo.  Bamboo only collects Personal Data with your consent, for our legitimate interest of ensuring Bamboo functions as intended, or as required or permitted by law. We process Personal Data as adequate and relevant to the specific, express purposes stated for collection or as reasonably necessary and proportionate to provide you with the Services. To be more specific, Bamboo collects Personal Data:a) Directly from you when you register or provide it with your consent. When you download Bamboo and register as a user, you will be prompted to provide identifiers including your email, phone number, a handle or username, and password. We collect this information with your consent, and we use it to provide you with access to the application and to facilitate your use of your Bamboo account. 
   
   b) When you opt-in to tracking. Bamboo may offer certain features that serve you with content or opportunities based on your profile, stated interests, or how you use the application. These features function by tracking your activities on Bamboo with your consent. If you wish to enjoy these features, simply opt-in when prompted. If you prefer to not be tracked, remain opted out. Bamboo does not engage in cross-platform user tracking, and we never sell or rent tracking data to third parties. c) In the form of technical data through cookies on our website. The Bamboo website may use cookies and related technologies to understand visitor interactions with the website and application, provide certain features, or improve functionality. Most of the data collected in this manner is technical only and does not qualify as Personal Data. Read more about this data in the Cookie Disclaimer posted to our website. 
   
   We will not collect additional categories of Personal Data or use already collected Personal Data for purposes that are materially different, unrelated, or not reasonably necessary or compatible with the original purpose without notice and consent to you as required by law.
   
   In addition to the purposes described above, we may process your Personal Data to: (i) fulfill any purpose to which you consent; (ii) monitor your compliance with our agreements and policies; (iii) help maintain the safety, security, and integrity of our technology assets; (iv) conduct internal testing, research, analysis, and product development, including to develop and improve our content and offerings; (v) respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; (vi) identify, contact or bring legal action against persons or entities who may be causing injury to you, to us, or to others as we determine necessary; or (vii) evaluate or conduct a business transition involving some or all of our company assets where Personal Data held by us is among the assets transferred. 

4. Users are responsible for their own privacy practices. On Bamboo you can leverage a variety of features like feed curation, collaborating with other users, or monetization of your content. You can also control the audience for your content by user age, location, interests, invite-only, or other criteria. No matter your choices or how you use Bamboo, you are solely responsible for any Personal Data you collect related to your use of Bamboo. It is your responsibility, not ours, to ensure that your use of Bamboo complies with applicable laws.  
   ‍
5. Your Personal Data is retained while your account is active. Your Personal Data on Bamboo will be retained while your account remains active. If you cancel your account, all Personal Data associated with your account will be deleted within 30 days of the cancellation date. Technical data and any data collected through cookies or related technologies may be retained for as little as a few minutes or as long as 24 months. We regularly identify and purge data that is no longer needed. We reserve the right to retain data for longer periods as required by law or court order or if doing so is critical to our business.
   ‍
6. We only disclose your Personal Data as needed to provide you with Bamboo.  We will only disclose Personal Data to third parties as described in this section, with your permission, or as required by law. We never share or sell your Personal Data to any third parties. We may disclose Personal Data for business purposes to the following third parties: a) Our Service Providers. We rely on certain service providers to offer features like SMS, photos, and videos, and for data hosting, content management, development, and other purposes. Our service providers may need access to Personal Data as needed to fulfil their contractual obligations to us. We prohibit our service providers from selling or disclosing the Personal Data we provide, and we require all service providers to maintain confidentiality standards and appropriate technical and organizational measures to ensure the security of your Personal Data.b) Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.c) Law enforcement, and other governmental agencies, as permitted or required by law.d) Aggregated and Deidentified Information. We reserve the right to share aggregated, anonymized, or de-identified data with nonaffiliated entities without restriction. Your Personal Data is never included in these datasets in an identifiable format.‍
   ‍
7. By signing up or logging in via Google Single Sign-On, you authorize us to receive your name and email address from Google. This information is exclusively used for the purposes of creating your user account on our platform. If the email provided matches an existing account, we generate a new data entity, referred to as ConnectedAccount, within our system's backend. This entity serves to link your existing account with the Google login method you've chosen. The collected information is solely utilized to facilitate the creation or linking of user accounts and is not used for any other purposes.
   ‍
8. ‍By signing up or logging in via Facebook / Meta Single Sign-On, you authorize us to receive your name and email address from Facebook / Meta. This information is exclusively used for the purposes of creating your user account on our platform. If the email provided matches an existing account, we generate a new data entity, referred to as ConnectedAccount, within our system's backend. This entity serves to link your existing account with the Facebook / Meta login method you've chosen. The collected information is solely utilized to facilitate the creation or linking of user accounts and is not used for any other purposes.

4. You can control your Personal Data on the Services. You can control how we collect and use your Personal Data through your Bamboo account or your device:a) Your Bamboo account. You have the option to access, correct or update, or delete certain Personal Data through your Bamboo account settings. b) Emails. We may send you informational or support emails related to your account. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive emails from us, you can change your account settings, unsubscribe via the links provided in the emails, or send us a request to privacy@nowbase.com.Note that if you opt out of marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.c) Device Settings. You can control the data collected from your device through cookies and related technologies by adjusting your device settings.d) SMS. If you provide your wireless phone number, you consent to receiving non-marketing SMS messages related to your use of Bamboo. However, we will only send you marketing text messages if you opt-in to receive these notifications from us. For all text messages, the number of texts you receive will depend on the Services you use and the information you request from us. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.e) Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.‍
   ‍
5. You may have rights under consumer privacy laws. This section provides informational notices pursuant to consumer privacy laws that require companies to inform consumers about their privacy rights, such as U.S. consumer privacy laws, the European Union’s General Data Protection Regulations and its counterpart in the United Kingdom, and Canada’s Personal Data Protection and Electronic Documents Act. Some of these laws may not apply to you or your use of Bamboo, in which case these notices are offered as a courtesy. Our obligations under these laws are limited to the extent we collect or process your Personal Data and are subject to statutory exceptions and limitations. Please contact privacy@nowbase.com if you have any questions. Depending on where you live, your rights over your Personal Data may include some or all of the following:a) Right to know. You may have the right to know how we collect and process your Personal Data. We have set the required information in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via Bamboo, email, or other communication.b) Right to reasonable expectations. You expect us to collect, use or disclose Personal Data responsibly and not for any other purpose other than as stated at the time of collection. We set your expectations in this Privacy Notice, and we collect legally required consent at various stages of our interactions with you. If we collect or use your Personal Data based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time with reasonable notice by contacting privacy@nowbase.com.c) Right to accuracy, and the right to correct your Personal Data. You can correct or update your Personal Data through your Bamboo account. If you require assistance, please contact us at privacy@nowbase.com and we will update our records to reflect your accurate information.d) No selling or sharing Personal Data. Some jurisdictions entitle consumers to opt out of the sale or sharing of their Personal Data or targeted advertising practices. We do not sell your Personal Data or share your Personal Data with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt out. e) Limited use and disclosure of sensitive Personal Data. We do not seek to collect sensitive Personal Data about anyone, and in no case will we use or disclose sensitive Personal Data for the purpose of inferring characteristics about a consumer. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of sensitive Personal Data. f) Right to not be subject to Automated Decision-Making (“ADM”) or the right to opt out of profiling. We do not use automated decision-making or any form of automated processing of Personal Data to evaluate, analyze, or predict your performance, preferences, choices, or behavior. If this changes in the future, we will update this Privacy Notice and provide you with an option to exercise your privacy rights related to Personal Data processed using ADM or profiling.g) Right to access your Personal Data. You can access your Personal Data through your Bamboo account. Additionally, we will provide you with a copy of your Personal Data upon request, along with details about the types of Personal Data we process, why we process it, and any third parties we work with to collect Personal Data on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example, to protect the rights of other individuals. Certain laws may limit the scope or frequency of requests we must fulfill.   h) Right to deletion or erasure (a.k.a. the “right to be forgotten”). When you cancel your account, the Personal Data associated with your account is automatically scheduled for deletion within 30 days. Additionally, upon your request and when required by law, we will delete your Personal Data from our systems. This right is not absolute, and we may be entitled to retain and process your Personal Data despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Data.i) Right to data portability. In some cases, we are required to provide your Personal Data to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.j) Right to restrict processing of your Personal Data. You may have the right to request that we restrict the processing of your Personal Data if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Data, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Data that is sensitive in nature, or that is sold or shared for certain purposes.k) Right to object to certain processing of your Personal Data. You may have the right to request, under certain circumstances and where we are required to do so by law, that we limit our processing of your Personal Data as you request. l) Right to non-discrimination. If you reside in a jurisdiction that extends a right to non-discrimination related to the exercise of privacy rights, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.m) Right to disclosure of certain information. You may have a right to request information about our collection and use of your Personal Data over the past 12 months, such as (i) the categories of Personal Data we have collected about you; (ii) the categories of sources for the Personal Data we have collected about you; (iii) our business purpose for collecting, using, disclosing, or selling that Personal Data, as applicable; and (iv) the categories of third parties with whom we disclose that Personal Data. Vernier does not sell or share your Personal Data, but if we did you could request two separate lists stating: (a) sales, identifying the Personal Data categories that each category of recipient purchased; and (b) sharing for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.    n) Health Data Rights. Bamboo does not collect any health data. Some laws entitle consumers to certain details about health data collected about them, including (i) confirmation of whether the entity collects, shares, or sells the consumer’s health data and access that data, including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties, (ii) a method to withdraw consent related to use of health data, and (iii) the right to have their health data be deleted. o) Right to disclosure of marketing information. If you are a resident of the State of California, California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California consumers to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.
   
   If you are a resident of the European Economic Area and you believe we are unlawfully processing your Personal Data, you also have the right to complain to your local data protection supervisory authority. If you are a resident of Switzerland, you have the right to complain to the Swiss data protection authorities. 

9. Submit a Privacy Request to exercise your privacy rights. If you wish to exercise your rights under your applicable privacy laws beyond the methods described above, or if you want to express concerns, revoke your consent, lodge a complaint, or request information, please submit a request through your Bamboo account or email us at privacy@nowbase.com. We can only assist with or fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction. If we do not fulfill your request within the legally required timeline, you can appeal our response by contacting us again. 
   
   
10. Bamboo is based in the United States. Bamboo is owned and operated in the United States, and we use technical infrastructure in the United States and other countries to provide you with Bamboo. You are solely responsible for determining whether your use of Bamboo complies with the laws that apply to you where you are located. If you are located outside the United States, any Personal Data processed through Bamboo may be transferred to, processed, stored, and used in the United States or elsewhere. We are committed to engaging in such transfers of Personal Data using a lawful data transfer mechanism. Please note that, when your information is transmitted to another country, the laws and rules governing your Personal Data may be different from those of your home country. By using Bamboo, you consent to the transfer and processing of your Personal Data as described in this section.
    ‍
11. Data security on Bamboo. We have implemented and maintain reasonable security measures to secure your Personal Data on Bamboo from accidental loss and unauthorized access, use, alteration, and disclosure. Bamboo uses multilayered user authentication to keep the application secure. Data is secured using strong encryption and securely stored with an industry-leading cloud provider. Our security measures are appropriate to the volume, scope, and nature of the Personal Data processed and designed to meet our duty of care with respect to your Personal Data.
    
    Please bear in mind that submitting data online is never entirely secure. We cannot guarantee the security of the information you submit via Bamboo while it is in transit, and any such submission is at your own risk. You are responsible for keeping your device access and login information confidential. You are also encouraged to use updated anti-virus and anti-malware software on your devices to avoid security risks. 

12. Links on Bamboo are for your convenience and may take you elsewhere. Bamboo may contain links to websites and platforms that are not controlled by our company. These links are provided for your convenience while you use Bamboo. We have no control over third-party websites, applications, platforms, or systems. Please exercise caution when deciding to disclose your Personal Data.
    ‍
13. We may update this Privacy Notice. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice. We will notify you about material changes to this Privacy Notice by email or by other measures that are appropriate to provide you with notice. We will collect your consent to these changes to the extent required by applicable law.

‍