Privacy Policy

 
Last updated August 26, 2021
 

Thank you for choosing to be part of our community at Bhapi Inc (“Company,” “we,”
“us,” or “our”). We are committed to protecting your personal information and your
right to privacy. If you have any questions or concerns about this privacy notice or                                                           our practices with regard to your personal information, please contact us at
cs@bhapi.io.

Settings
This privacy notice describes how we might use your information if you:
▪ Visit our website at https://bhapi.io
▪ Download and use our mobile application — bhapi
▪ Engage with us in other related ways ― including any sales, marketing, or
events

In this privacy notice, if we refer to:
▪ “Website,” we are referring to any website of ours that references or links to
this policy
▪ “App,” we are referring to any application of ours that references or links to
this policy, including any listed above
▪ “Services,” we are referring to our Website, App, and other related services,
including any sales, marketing, or events

The purpose of this privacy notice is to explain to you in the clearest way possible
what information we collect, how we use it, and what rights you have in relation to it.
If there are any terms in this privacy notice that you do not agree with, please
discontinue use of our Services immediately.
Please read this privacy notice carefully, as it will help you understand what
we do with the information that we collect.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT
FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register
on the Services, express an interest in obtaining information about us or our
products and Services, when you participate in activities on the Services (such as by
posting messages in our online forums or entering competitions, contests or
giveaways) or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions
with us and the Services, the choices you make and the products and features you
use. The personal information we collect may include the following:
Personal Information Provided by You. We collect names; phone numbers; email
addresses; usernames; passwords; contact preferences; contact or authentication
data; billing addresses; debit/credit card numbers; and other similar information.

Payment Data.
We may collect data necessary to process your payment if you

make purchases, such as your payment instrument number (such as a credit card
number), and the security code associated with your payment instrument. All
payment data is stored by Apple Pay, Google Pay and Stripe. You may find their
privacy notice link(s) here: https://support.apple.com/en-us/HT210665,
https://payments.google.com/

payments/, https://stripe.com/en-au/privacy.

 
Social Media Login Data.
We may provide you with the option to register with us

using your existing social media account details, like your Facebook, Twitter or other
social media account. If you choose to register in this way, we will collect the
information described in the section called “HOW DO WE HANDLE YOUR SOCIAL                                                      LOGINS?” below.

 

All personal information that you provide to us must be true, complete and accurate,

and you must notify us of any changes to such personal information.
 

Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our                                                       services.

 

We automatically collect certain information when you visit, use or navigate the
Services. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about how
and when you use our Services and other technical information. This information is
primarily needed to maintain the security and operation of our Services, and for our                                                 internal analytics and reporting purposes.

 

Like many businesses, we also collect information through cookies and similar
technologies. You can find out more about this in our Cookie Notice: https://bhapi.io
/cookie-policy
.

Information collected through our App
In Short: We collect information regarding your mobile device, push notifications,
when you use our App.

If you use our App, we also collect the following information:
▪ Mobile Device Access. We may request access or permission to certain
features from your mobile device, including your mobile device’s contacts,
social media accounts, calendar, storage, and other features. If you wish to
change our access or permissions, you may do so in your device’s settings.
▪ Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model and manufacturer), operating system, version
information and system configuration information, device and application
identification numbers, browser type and version, hardware model Internet
service provider and/or mobile carrier, and Internet Protocol (IP) address (or
proxy server). If you are using our App, we may also collect information about
the phone network associated with your mobile device, your mobile device’s
operating system or platform, the type of mobile device you use, your mobile
device’s unique device ID and information about the features of our App you
accessed.
▪ Push Notifications. We may request to send you push notifications regarding
your account or certain features of the App. If you wish to opt-out from
receiving these types of communications, you may turn them off in your
device’s settings.

This information is primarily needed to maintain the security and operation of our
App, for troubleshooting and for our internal analytics and reporting purposes.

2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business
interests, the fulfillment of our contract with you, compliance with our legal
obligations, and/or your consent.
We use personal information collected via our Services for a variety of business
purposes described below. We process your personal information for these
purposes in reliance on our legitimate business interests, in order to enter into or
perform a contract with you, with your consent, and/or for compliance with our legal
obligations. We indicate the specific processing grounds we rely on next to each
purpose listed below.

We use the information we collect or receive:
▪ To facilitate account creation and logon process. If you choose to link your
account with us to a third-party account (such as your Google or Facebook
account), we use the information you allowed us to collect from those third parties                                                               to facilitate account creation and logon process for the performance of
the contract. See the section below headed “HOW DO WE HANDLE YOUR
SOCIAL LOGINS?” for further information.
▪ To post testimonials. We post testimonials on our Services that may contain
personal information. Prior to posting a testimonial, we will obtain your
consent to use your name and the content of the testimonial. If you wish to
update, or delete your testimonial, please contact us at cs@bhapi.io and be
sure to include your name, testimonial location, and contact information.
▪ Request feedback. We may use your information to request feedback and to
contact you about your use of our Services.
▪ To enable user-to-user communications. We may use your information in
order to enable user-to-user communications with each user’s consent.
▪ To manage user accounts. We may use your information for the purposes of
managing our account and keeping it in working order.
▪ To send administrative information to you. We may use your personal
information to send you product, service and new feature information and/or
information about changes to our terms, conditions, and policies.
▪ To protect our Services. We may use your information as part of our efforts
to keep our Services safe and secure (for example, for fraud monitoring and
prevention).
▪ To enforce our terms, conditions and policies for business purposes, to
comply with legal and regulatory requirements or in connection with our
contract.
▪ To respond to legal requests and prevent harm. If we receive a subpoena
or other legal request, we may need to inspect the data we hold to determine
how to respond.
▪ Fulfill and manage your orders. We may use your information to fulfill and
manage your orders, payments, returns, and exchanges made through the
Services.
▪ Administer prize draws and competitions. We may use your information to
administer prize draws and competitions when you elect to participate in our
competitions.
▪ To deliver and facilitate delivery of services to the user. We may use your
information to provide you with the requested service.
▪ To respond to user inquiries/offer support to users. We may use your
information to respond to your inquiries and solve any potential issues you
might have with the use of our Services.
▪ To send you marketing and promotional communications. We and/or our
third-party marketing partners may use the personal information you send to
us for our marketing purposes, if this is in accordance with your marketing
preferences. For example, when expressing an interest in obtaining
information about us or our Services, subscribing to marketing or otherwise
contacting us, we will collect personal information from you. You can opt-out
of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY
RIGHTS?” below).
▪ Deliver targeted advertising to you. We may use your information to
develop and display personalized content and advertising (and work with third
parties who do so) tailored to your interests and/or location and to measure its
effectiveness. For more information see our Cookie Notice: https://bhapi.io
/cookie-policy.

3. WILL YOUR INFORMATION BE SHARED WITH
ANYONE?

In Short: We only share information with your consent, to comply with laws, to
provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
▪ Consent: We may process your data if you have given us specific consent to
use your personal information for a specific purpose.
▪ Legitimate Interests: We may process your data when it is reasonably
necessary to achieve our legitimate business interests.
▪ Performance of a Contract: Where we have entered into a contract with you,
we may process your personal information to fulfill the terms of our contract.
▪ Legal Obligations: We may disclose your information where we are legally
required to do so in order to comply with applicable law, governmental
requests, a judicial proceeding, court order, or legal process, such as in
response to a court order or a subpoena (including in response to public
authorities to meet national security or law enforcement requirements).
▪ Vital Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential violations of                                                               our policies, suspected fraud, situations involving potential threats to the
safety of any person and illegal activities, or as evidence in litigation in which
we are involved.
More specifically, we may need to process your data or share your personal
information in the following situations:
▪ Business Transfers. We may share or transfer your information in
connection with, or during negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a portion of our business to another
company.
▪ Vendors, Consultants and Other Third-Party Service Providers. We may
share your data with third-party vendors, service providers, contractors or
agents who perform services for us or on our behalf and require access to
such information to do that work. Examples include: payment processing, data
analysis, email delivery, hosting services, customer service and marketing
efforts. We may allow selected third parties to use tracking technology on the
Services, which will enable them to collect data on our behalf about how you
interact with our Services over time. This information may be used to, among
other things, analyze and track data, determine the popularity of certain
content, pages or features, and better understand online activity. Unless
described in this notice, we do not share, sell, rent or trade any of your
information with third parties for their promotional purposes. We have
contracts in place with our data processors, which are designed to help
safeguard your personal information. This means that they cannot do anything
with your personal information unless we have instructed them to do it. They
will also not share your personal information with any organization apart from
us. They also commit to protect the data they hold on our behalf and to retain
it for the period we instruct.
▪ Offer Wall. Our App may display a third-party hosted “offer wall.” Such an
offer wall allows third-party advertisers to offer virtual currency, gifts, or other
items to users in return for the acceptance and completion of an
advertisement offer. Such an offer wall may appear in our App and be
displayed to you based on certain data, such as your geographic area or
demographic information. When you click on an offer wall, you will be brought
to an external website belonging to other persons and will leave our App. A
unique identifier, such as your user ID, will be shared with the offer wall
provider in order to prevent fraud and properly credit your account with the
relevant reward. Please note that we do not control third-party websites and
have no responsibility in relation to the content of such websites. The
inclusion of a link towards a third-party website does not imply an
endorsement by us of such website. Accordingly, we do not make any
warranty regarding such third-party websites and we will not be liable for any
loss or damage caused by the use of such websites. In addition, when you
access any third-party website, please understand that your rights while
accessing and using those websites will be governed by the privacy notice
and terms of service relating to the use of those websites.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following categories of third parties.
We only share and disclose your information with the following categories of third
parties. If we have processed your data based on your consent and you wish to
revoke your consent, please contact us using the contact details provided in the
section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.
▪ Data Analytics Services
▪ User Account Registration & Authentication Services

5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store
your information.
We may use cookies and similar tracking technologies (like web beacons and pixels)
to access or store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie Notice:
https://bhapi.io/cookie-policy.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media
account, we may have access to certain information about you.
Our Services offers you the ability to register and login using your third-party social
media account details (like your Facebook or Twitter logins). Where you choose to
do this, we will receive certain profile information about you from your social media
provider. The profile information we receive may vary depending on the social media
provider concerned, but will often include your name, email address, friends list, profile                                               picture as well as other information you choose to make public on such social
media platform.We will use the information we receive only for the purposes that are described in
this privacy notice or that are otherwise made clear to you on the relevant Services.
Please note that we do not control, and are not responsible for, other uses of your
personal information by your third-party social media provider. We recommend that
you review their privacy notice to understand how they collect, use and share your
personal information, and how you can set your privacy preferences on their sites
and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements). No purpose
in this notice will require us keeping your personal information for longer than twelve
(12) months past the termination of the user’s account.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, 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.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our
security, and improperly collect, access, steal, or modify your information. Although
we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the
Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United
Kingdom (UK), you have rights that allow you greater access to and control over
your personal information. You may review, change, or terminate your account at
any time.

In some regions (like the EEA and UK), you have certain rights under applicable
data protection laws. These may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; and (iv) if applicable, to data
portability. In certain circumstances, you may also have the right to object to the
processing of your personal information. To make such a request, please use the
contact details provided below. We will consider and act upon any request in
accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the
right to withdraw your consent at any time. Please note however that this will not
affect the lawfulness of the processing before its withdrawal, nor will it affect the
processing of your personal information conducted in reliance on lawful processing
grounds other than consent.

If you are a resident in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your local data
protection supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/

index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection
authorities are available here: https://www.edoeb.admin.ch/

edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email us at
cs@bhapi.io.

Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
▪ Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account                                                   and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply with applicable legal
requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies
by default. If you prefer, you can usually choose to set your browser to remove
cookies and to reject cookies. If you choose to remove cookies or reject cookies, this
could affect certain features or services of our Services. To opt-out of interest-based
advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
For further information, please see our Cookie Notice: https://bhapi.io/cookie-policy.
Opting out of email marketing: You can unsubscribe from our marketing email list
at any time by clicking on the unsubscribe link in the emails that we send or by
contacting us using the details provided below. You will then be removed from the
marketing email list — however, we may still communicate with you, for example to
send you service-related emails that are necessary for the administration and use of
your account, to respond to service requests, or for other non-marketing purposes.

To otherwise opt-out, you may:
▪ Access your account settings and update your preferences.

10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.

If you are under 18 years of age, reside in California, and have a registered account
with a Service, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below, and include the email address
associated with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g. backups, etc.).

CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and
obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
(12) months:

We may also collect other personal information outside of these categories
instances where you interact with us in-person, online, or by phone or mail in the
context of:
▪ Receiving help through our customer support channels;
▪ Participation in customer surveys or contests; and
▪ Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Bhapi Inc collects and shares your personal information through:
▪ Social media cookies
▪ Beacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this
privacy notice and our Cookie Notice: https://bhapi.io/cookie-policy.
You may contact us by email at cs@bhapi.io, by calling toll-free at +1 85 947 51924.,
by visiting https://bhapi.io/contact-us/, or by referring to the contact details at the
bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a
request if the authorized agent does not submit proof that they have been validly
authorized to act on your behalf.

Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Each service provider is a
for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration.
This is not considered to be “selling” of your personal data.

Bhapi Inc has disclosed the following categories of personal information to third
parties for a business or commercial purpose in the preceding twelve (12) months:
▪ Category B. Personal information, as defined in the California Customer
Records law, such as your name, contact information, education,
employment, employment history and financial information.
The categories of third parties to whom we disclosed personal information for a                                                             business or commercial purpose can be found under “WHO WILL YOUR
INFORMATION BE SHARED WITH?”.

Bhapi Inc has not sold any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. Bhapi Inc will not sell
personal information in the future belonging to website visitors, users and other
consumers.

Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete
your personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited
to) the exercise by another consumer of his or her right to free speech, our
compliance requirements resulting from a legal obligation or any processing that
may be required to protect against illegal activities.
Right to be informed – Request to know

Depending on the circumstances, you have a right to know:
▪ whether we collect and use your personal information;
▪ the categories of personal information that we collect;
▪ the purposes for which the collected personal information is used;
▪ whether we sell your personal information to third parties;
▪ the categories of personal information that we sold or disclosed for a business
purpose;
▪ the categories of third parties to whom the personal information was sold or
disclosed for a business purpose; and
▪ the business or commercial purpose for collecting or selling personal
information.

In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to
re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.

Verification process
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match
it with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g. phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.

We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. If, however, we
cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purposes of verifying your
identity, and for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.

Other privacy rights
▪ you may object to the processing of your personal data
▪ you may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the data
▪ you can designate an authorized agent to make a request under the CCPA on
your behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
▪ you may request to opt-out from future selling of your personal information to
third parties. Upon receiving a request to opt-out, we will act upon the request
as soon as feasibly possible, but no later than 15 days from the date of the
request submission.

To exercise these rights, you can contact us by email at cs@bhapi.io, by calling toll-
free at +1 85 947 51924., by visiting https://bhapi.io/contact-us/, or by referring to the
contact details at the bottom of this document. If you have a complaint about how we
handle your data, we would like to hear from you.

12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with
relevant laws.

We may update this privacy notice from time to time. The updated version will be
indicated by an updated “Revised” date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
If you have questions or comments about this notice, you may email us at
cs@bhapi.io or by post to:
Bhapi Inc
2810 North Church Street, Wilmington Delaware
Wilmington, DE 19802
United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that information, or
delete it in some circumstances. To request to review, update, or delete your
personal information, please visit: https://bhapi.io/contact-us/.