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General

Privacy Notice for Bestie customers and website users

Effective Date: October 1, 2024

This Privacy Notice describes how your Bestie entity as indicated below (“Bestie,” “we” and “us”) collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you (whether you are a person acting as a sole proprietor or on behalf of another business entity) visit our website (www.bestie.biz) or apply or sign up for a Bestie account (collectively, “Services”).

INFORMATION WE COLLECT ABOUT YOU

We collect information about you in three ways: (i) when you provide it to us directly; (ii) when we gather information while you are using the Services; and (iii) when we collect information from other sources. We explain below what types of data are involved in each case, how and why we process (use) it and the lawful basis that applies to our use of the relevant information.

Information You Provide (“Bestie Account Data”)

Below is a description of the types of information that we may receive directly from you which we refer to as “Bestie Account Data”:

Types of Information ("Bestie Account Data")	Examples
Financial Information	Bank account information and payment card numbers
Identity Information	Name, email address, postal address, signature, and phone number; Passport number, driver's license number, Social Security number, Taxpayer Identification number, or other government-issued identification number; Where additional verification is required and where you choose to share such information, photo identification, such as your passport or driver’s license in combination with a photograph facial scan and biometrics extracted from such image or other documents proving your identity or place of residence, including financial account statements, phone or utility bills.
Contacts Information	When you use any of our Services to send or receive payments, we may ask you to provide the contact details, such as the address, email address, or phone number of the intended recipient. You can do this by manually entering this information into the Services.
Any other data you give us	Information that you voluntarily provide to us, including your survey responses; participation in contests, promotions, or other prospective seller marketing forms or devices; suggestions for improvements; information disclosed to the chatbots that operate on our Services; referrals; or any other actions you perform on the Services.

Here is an explanation of what we do with the Bestie Account Data described above, i.e. how we use it and for what purposes, along with an explanation of the lawful basis that supports this use.

How we use Bestie Account Data	Why we process Bestie Account Data	Legal Justification
When you make a request to receive information about Bestie or our products we collect Identity Information that you provide to us.	To respond to your request, including determining whether the Services are available in your country.	Pre-contract performance
We may use your Identification Information and your Financial Information to go through our identity or account verification process and to enable you to authenticate into your account once it is created. We may share your Identification Information with identity verification vendors, including credit reporting agencies, wireless carriers, and others, to verify information that we collect. Our vendors cross-check the identity and financial data you give us. Your information is also screened against relevant sanctions watchlists.	To determine whether the Services are available in your country and to create your account with us and to meet our AML, "know your customer", background checking (see further below) and other compliance requirements.	Legal obligation. For example, "Know your Customer" and AML compliance requirements are governed by, among other laws, the Bank Secrecy Act (1970) (USA), the USA Patriot Act (2001) (USA), the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations (S.C. 2000, Canada), EU Directive 2015/849 (AMLD IV) on anti-money laundering and terrorist financing, EU Directive 2018/843 (AMLD V) on anti-money laundering and terrorist financing and EU Member State implementing legislation such as the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended) (Ireland).
We use your Identification Information to deliver the information and support you request, including to deliver technical notices, security alerts, and support and administrative messages to you. We also use it to resolve disputes, collect payments or fees, and provide assistance for problems with our Services or your Bestie account.	To communicate with you to fulfill our obligations under the Terms of Service.	Contractual performance
When you apply or sign up for a Bestie account or other Services, we collect all of the Bestie Account Data necessary to create your account and enable you to start fulfilling transactions.	To create and support your account with us, including displaying your transaction history including monthly account statements.	Contractual performance
When you use the Services to send or receive payments, we may require Contacts Information, such as the sender or recipient’s email address or phone number to fulfill the transaction.	To process the payments that you send or receive and to prevent the risk that payments may be misdirected.	Contractual performance
If you choose to let us access and upload Contacts Information directly from your mobile phone, we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.	To improve your customer experience, to protect the integrity of our Services, to prevent misdirected payments, and to help personalize the Services to you.	Consent
We use your Identification Information to send you surveys and get your feedback about our Services.	To understand if the Services are helpful to you and to evaluate the effectiveness of any updates we provide.	Legitimate interest
We use your Identification Information to promote our products and Services to you.	To promote our products and services.	Legitimate interest or consent (where legally required for direct marketing contact).
When you provide feedback to us or answer our surveys.	To improve our services and to develop new products and services.	Legitimate interest
We use your Identification Information to personalize your use of our Services, for example, when you sign up for a Bestie account, we can associate certain information with your new account, such as information about other Bestie accounts you have had or currently have, and prior transactions you have made using our Services.	To improve your customer experience.	Legitimate interest and/or contractual performance.

Information We Collect From Your Use of the Services

We also get data from the devices you use when you interact with our systems, like your location or information about the device you’re using. We refer to this as Usage Data.

Types of Informaton ("Usage Data")	Examples
Commercial Information	Information about the products and services you sell e.g., inventory, pricing and other data. Information about your payment transactions e.g., when and where the transactions occur, a description of the transactions, the payment or transfer amounts, billing and shipping information, and payment methods used to complete the transactions.
Location data, which includes the location of your device, and may in some circumstances include precise geolocation data	For more information and to learn how to disable collection of location information from your mobile device, please see below.
Internet or other electronic network activity information	Web browser and device characteristics. Information about how you use and interact with our Services. This includes your access time, "log-in" and "log-out" information, browser type and language, the domain name of your internet service provider, other attributes about your browser, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Services, your search terms, and the website you visited before you visited or used the Services.
Online identifiers	Information you use to log in to your account. Internet Protocol ("IP") address, and unique personal identifiers (including device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; unique alias, and other identifiers).
Professional or employment-related information	Information you provide about your business (e.g., appointments, staffing availability, and contact data) and your employees (e.g., job titles, payroll information, and hours worked and other timecard data).
Profile information - Inferences drawn from any of the information above to create a profile about you	These may reflect your preferences, characteristics, and behavior. For example, if you use a product or service after receiving a marketing communication about it.

We need this Usage Data to do things like provide services to you that you have requested, fulfill our legal obligations (such as checking if payments are being made or received by you and that they are legally compliant), and help protect your account from hackers and prevent fraud. We also need this Usage Data to make our products and services better for you and others, as well as to develop new products and services. For example, if more transactions are occurring on a specific hardware device we will build out more product and service availability on that device.

How we use Usage Data	Why we process Usage Data	Legal Justification
We collect your Commercial Information from the devices you use when you interact with our systems and from the information that is associated with the transaction as captured on our databases.	This enables us to provide services to you that you have requested including inventory, eCommerce and payments processing. This also enables us to protect the integrity of our Services and systems, and your, our, our customers', or your customers' rights or property. This also enables us to do internal research, measure, track, and analyze trends and usage, to improve our products and services, and, in the United States, to provide our products and services when instructed by your customers.	Contract performance Legitimate Interests Legitimate Interests
We use your Commercial Information when you interact with our systems and when it is associated with a transaction. We combine this information with Identification Information as well as with risk signals.	This enables us to debug, fix service errors, investigate, detect, prevent, report or recover from fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities; or to otherwise help protect your account, including to dispute chargebacks on your behalf.	Contract performance (support and maintenance) Legal obligation (fraud or incident reporting) Legitimate interest (protect your account)
We use your Commercial Information in connection with artificial intelligence technologies to generate personalized features for your business.	This enables us to provide the Services that you have requested that utilize these technologies.	Contract Performance
We collect your Internet or other electronic network activity information while you are using the Services using our website, web apps, and hardware and we combine this with your Profile Information.	This enables us to provide Services to you in compliance with regulatory obligations. This enables us to provide Services to identify any unusual activity on your account so as to detect and prevent fraud, and to debug and fix errors that impair how our Services function.	Legal obligation (fraud or incident reporting) Contract performance Legitimate interest
We store your Professional or employment-related information in our databases.	This enables us to deliver aspects of the Services (e.g., Crew App and Payroll) that require this level of information to function.	Contract performance
We generate your Profile Information using our databases. We use your Profile Information to verify your identity, and to enhance our Services.	This enables us to engage in profiling and automated processing to verify your identity both directly and through the use of third party identification verification services (so we can confirm you appear to be who you say you are), improve our products and Services and develop new products and Services.	Our legitimate interests in verifying your identity and reducing the risk of fraud, as well as, where permissible, offering new and improved services to our customers that are likely to be relevant to their business in light of their Seller activity and the systems and processes they use.
We use your Geolocation data to determine whether we can provide you with Services and to customize our Services to your location.	This enables us to determine whether we can provide Services to you, and in what language, enables us to comply with applicable payment processor requirements, and other regulatory requirements, and to combat fraud.	Contract performance (for Services in territories where we are authorized to conduct our business) Legal obligation (to comply with territorial restrictions)

Information We Collect from Other Sources

We also need to check that you are eligible for the services you want to use, are using our services legally, and to protect your data and our services from potential fraudulent activity which may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, do a credit check, prevent fraud or assess risk.

Types of Information ("External Data)"	Examples
Background Check Information	Credit report information. Identity verification information. Information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
Credit, Compliance and Fraud Information	Account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, wireless carriers, and personal reporting agencies.

How we use External Data	Why we process External Data	Legal Justification
We collect Background Check Information about you from background check vendors and we process this information using our anti-fraud and risk management systems.	This helps us verify your identity, do a credit check, prevent fraud and assess risk.	Legal obligation Legitimate interest
We receive and exchange Credit, Compliance and Fraud Information using our credit management systems and processes.	As required under applicable laws, as part of any credit investigation, credit eligibility, identity or account verification process, fraud or risk detection process, or collection procedure.	Legal obligation Legitimate interest

INFORMATION WE COLLECT ABOUT YOUR CUSTOMERS

We also obtain information about your customers on your behalf as your service provider when they transact with you or otherwise when you request that we do so. We call this information Your Customers’ Data. We collect Your Customers’ Data when they interact with you through your use of Bestie’s products, for instance when they make a payment at your establishment, or schedule an appointment, or receive an invoice from you. The particular Customer Data we collect will vary depending on your location, which products and services you use and how you use them. Your Customers’ Data may include:

Types of Information ("Your Customers' Data")	Examples
Customer Device Information	Information about your customer's device, including hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device's interaction with our Services.
Customer Financial Information	Bank account and payment card numbers.
Customer Identification Information	Your customers' name; email address; mailing address; phone number; government-issued identification; or other historical, contact, and demographic information, and signature.
Customer Location Information	The location of your customer's device if they pay with Apple or Android Pay, or give their consent.
Customer Transaction Information	When your customers use Bestie to make or record payments to you, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions which may include item-level data, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
Customer Use Information	Information about how your customers interact with you using our Services, including access time, "log-in" and "log-out" information, browser type, history and language, country and language setting on your device, IP address, the domain name of your customer's Internet service provider, other attributes about your customer's browser, mobile device and operating system, features your customer uses, and the date and time of use of the Services.
Other Information You or Your Customers Provide	Information that your customers voluntarily provide you, or that you input into Bestie's systems about your customers For example, survey responses; participation in contests, promotions, or other prospective seller marketing forms or devices; suggestions for improvements; notes you take about your customers, or any other actions performed when they interact with you using Bestie

We use Your Customers’ Data as part of our contractual obligation to provide the Services you request to you.

It is your responsibility to obtain any necessary permission for us to use Your Customers’ Data in the manner envisaged in this Privacy Notice so that we can provide you with the Services requested by you.

WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We may share the personal information described in the “Information We Collect About You” section class="text-left" with the following categories of service providers and third parties:

Category of third parties with whom we share your personal information in order for you to receive the Services	Description of the services in question
Service support partners	We may work with the following types of third party service providers who help us provide, maintain and improve the Services: Technology providers or potential partners to store information, provide software, or programs to help us provide the Services; Marketing or event providers that help us run our advertising campaigns, contests, special offers, or other events or activities; Identity verification providers to help us with fraud prevention and to assist us in meeting our AML, "know your customer", background checking and other compliance requirements; Fee collection service providers to help us enforce our legal rights; Financial partners, like financial institutions, payment networks, payment card associations, and credit bureaus that help us provide the Services.
Third-Party Analytics Services	Our analytics partners help us with our online services, such as Google Analytics and error tracking platforms. The analytics providers that administer these services use technologies such as cookies, web beacons, and web server logs to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services. To learn more about Google Analytics and how to opt out, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181881?hl=e
Online Tracking and Interest-Based Advertising	Consistent with local law, we and our advertising partners may collect information about your activities on our website. We use this information to advertise to you and to tailor our products and services to your interests. You may see certain ads on other websites because we use third-party services to advertise our services to you. We use these services to target our ads to you and others based on your demographics, interests, and context. These third-party ad services track your online activities over time and across multiple websites by collecting your information through automated technologies, including third-party cookies, web server logs, and web beacons. The ad services use this information to show you Bestie ads that may be tailored to your individual interests. The information our ad services may collect on our behalf includes data about your visits to websites that serve Bestie ads, such as the pages or ads you view and the actions you take on those websites. This data collection takes place both on our online services, and on third-party websites that serve our ads to you. This process also helps us figure out if our ads to you are effective. To learn about how to opt out of interest-based advertising (sometimes referred to as "targeted advertising") in the U.S., see "Cookies And Other Similar Technologies" and the "United States" section class="text-left"s below. Certain web browsers allow you to instruct your browser to respond to Do Not Track ("DNT") signals to website you visit, informing those sites that you do not want your online activities to be tracked. At this time, our websites are not designed to respond to DNT signals or similar mechanisms from browsers.
Partners	We may share minimal personal information (such as your business name) with potential partners who may be able to provide a complementary or related service for your business. We may also share personal information with partners if we believe the disclosure is reasonably necessary to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities. We work with partners who may receive compensation for helping us to identify prospective caregivers interested in Bestie. If you were referred to Bestie by one of our referral partners, we may share limited commercial information related to your use of Bestie, such as the date you activated your account and the volume of transactions you process through Bestie, to provide reporting on the referral fees earned by the partner that referred you.
Our Affiliates and Group Companies	With other business units and between wholly owned subsidiaries of Boop LLC. For example, we may share your information internally to understand how you engage with our company products to help make our Services better for you and for everyone, to help us build Services tailored to your preferences, and to help protect our services and maintain a trusted environment.

Other third parties who will receive your personal information	Why we share data with these parties
Other users of our Services with whom you interact through your own use of our Services.	To enable you to make or accept a payment, appointment, or money transfer using our Services.
Law enforcement and other public and private agencies	If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our Terms of Service or other applicable agreements or policies; (iv) to protect our or our customers' rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.
To a subsequent owner, co-owner, or operator of one or more of the Services	To enable them to continue to run the Services after the change of owner or operator.
If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.	To enable the completion of the relevant merger, restructuring, financing, acquisition, divestiture, dissolution or other corporate change.
To others, at your direction	To carry out certain requests you make for us to share data.

SECURITY

We do a lot to keep your data safe. While we think we have strong defenses in place, no one can ever guarantee that hackers won’t be able to break into our sites or steal your data while it is stored or flowing from you to us or vice versa.

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers. Your personal information will be accessible by our employees, contractors and service providers who require access for the purposes described in this Privacy Notice.

COOKIES, OTHER SIMILAR TECHNOLOGIES, AND ADVERTISING

The following additional information applies across all of our websites and apps.

Digital cookies and similar technologies help us make our services better to use by doing things like recognizing when you’ve signed in, analyzing how you use our services so we can make them more useful to you, giving you a more personalized experience.

When you interact with our online services, or open emails we send you, we obtain certain information using automated technologies, such as cookies, web server logs, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails.

We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to:

Remember your information so you do not have to re-enter it.
Track and understand how you use and interact with our online services and emails.
Tailor our online services to your preferences.
Measure how useful and effective our services and communications are to you.
Otherwise manage and enhance our products and services.

We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. For example, we may use other companies’ web analytics services (described in the “Third-Party Analytics Services” section class="text-left" above), which use automated technologies to help us evaluate how customers use our websites. Some of these technologies may also be set by third parties that help us advertise our products and services to you as informed by your interests, based on information collected from your activity on the web, including but not limited to, browsing or purchasing products on or through our websites or on third party websites or your activity on mobile sites and applications. This advertising approach is called interest-based advertising or “targeted advertising.”

Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. More information on how to manage these settings on common browsers and devices are below.

Manage cookie settings in Chrome and Chrome Android and Chrome iOS
Manage cookie settings in Firefox
Manage cookie settings in Internet Explorer
Manage cookie settings in Microsoft Edge
Manage cookie settings in Safari and Safari iOS

Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device.

Within mobile applications, you may also go to your device settings and select “Limit Ad Tracking” (for iOS devices), or “Opt out of Interest-Based Ads” (for Android devices), which will allow you to limit our use of information collected from or about your mobile device (such as precise location data) for the purposes of serving online behavioral advertising to you.

HOW LONG WE RETAIN YOUR INFORMATION

We store your information for as long as is necessary for the purposes identified in this Privacy Notice, including to provide our Services, to comply with legal obligations, to enforce and prevent violations of our Terms, to protect against fraudulent activity, and to defend our legal rights, property and users.

The retention periods for your information are determined on a case-by-case basis that depends on the following factors:

The nature of the information and why it is collected and processed. The length of time we will keep your information will generally be determined by how long we need that information to provide you with our Services, including any optional features you use and to provide customer support. For example:
- As set out in this Privacy Notice, we require Bestie Account Data to deliver our Services. We need to keep it for the duration your Bestie account exists so that we can maintain your account.
- Similarly, we will also keep your Usage Data for the lifetime of your account.
Legal reasons. In certain cases, we are obliged to keep your information for legal reasons, which may include after your account has been deactivated. We will keep your information where it necessary for us:
- To respond to a legal request or to comply with applicable law. We must keep your information where we have a legal obligation to do so, for example, if we receive a valid legal request, such as a preservation order or search warrant, related to your account, we preserve your information after you delete your account.
- To deal with and resolve requests, disputes or complaints.
- For litigation or regulatory matters. For example, we preserve your information related to a legal claim or complaint, such as where we are subject to a regulatory investigation or we need to defend ourselves in legal proceedings about a claim related to your information or respond to a regulator in relation to a legal or regulatory complaint made by you or someone else.
- Issues relating to the safety, security and integrity of our Services and to protect rights, property and users. For example, we keep information where it is necessary to investigate misuse of our Services, such as fraud.

YOUR CHOICES

As described further below, you may be entitled to certain rights with respect to your personal information. You can also see, change or fix information you gave us, ask us to deactivate your account, control your location information, or opt out of receiving promotional messages from us.

Your Personal Information Rights

Depending on the jurisdiction in which you reside, you may be entitled under applicable law to request:

Access to your personal information in a portable format, including: (1) the categories of personal information described above that we have collected about you and the categories of sources from which we collected such personal information; (2) the business or commercial purposes for collecting or sharing such personal information; (3) the categories of personal information about you that we have disclosed to third parties for a business purpose; (4) the categories of third parties to whom we have disclosed such personal information; and (5) the specific pieces of personal information we have collected about you.
Deletion of the personal information we have collected from you;
Correction of the personal information we have collected about you;
To opt-out of the sharing of your personal information for purposes of targeted advertising.

You may submit an access, deletion, or correction request via email using the contact details provided below. Once we receive your request, we will verify it by requesting that you confirm certain personal information associated with your account. You may also be entitled to submit a request through an authorized agent.

Although some of the information we collect and process about you may be considered sensitive personal information, we only process such information for purposes authorized by law, such as to provide services you request from us or to verify your information.

Deactivating Your Account

If you wish to deactivate your account, you can do so by emailing us using the contact details provided below.

Location Information

In order to provide certain Services, we may request access to location information, including precise geolocation information collected from your device. If you do not consent to the collection of this information, certain Services will not function properly, and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, our mobile application may no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove the Bestie mobile application from your device.

Promotional Communications

You can opt out of receiving promotional messages from Bestie by following the instructions in those messages, by informing the caller that you would not like to receive future promotional calls, or by changing your notification settings by logging into your Bestie account. You may only opt out of text messages from Bestie by replying STOP. Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we will still send you non-promotional communications which are required for the running of your account, such as digital receipts and messages about your account or our ongoing business relations.

CHILDREN’S PERSONAL INFORMATION

Our Services are general audience services not directed at children under the age of 18. We do not knowingly collect, share, or sell any information from children under the age of 18. If we learn that any information we collect has been provided by a child under the age of 18, we will promptly delete that information.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to change this Privacy Notice from time to time, as may be required. We will provide you with reasonable prior notice of any material changes in how we use your information, including by email if you have provided one. If you disagree with these changes, you may cancel your account at any time. Any amendments will be published by posting a revised version of the Privacy Notice and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed.

CONTACT

If you have any questions or concerns regarding this Privacy Notice, please reach out to us by contacting your country specific privacy contact below:

Boop LLC (dba Bestie)
1869 154^th Rd
Garland, NE 6836

+1-402-641-2627

info@bestie.biz