Bundle, LLC (“Bundle,” “we,” “us” or “our”) recognizes that you care how information about you is collected and used. We have created this privacy policy (the “Privacy Policy” or “Policy”) to inform you of our information collection, use, and sharing practices. Please read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your Personal Information (defined below) collected by our websites, including bundlebenefits.com (and any website or hyperlink that redirects to the foregoing) and any smartphone, device or other electronic applications or tools or through any social media platform (together, the “Electronic Platforms”), emails, text messages, direct messages, or other communications whether electronic or written.

It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use, and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation (“GDPR”) which applies across the European Union (including the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

1. INFORMATION WE COLLECT ABOUT YOU.

1. Personal information that directly or indirectly identifies, relates to, describes, or is reasonably capable of being associated with you or your household (“Personal Information”). For purposes of this Policy, “household” has the meaning as set out by the California Consumer Privacy Act of 2018 (the “CCPA”).
   1. Name (including any account name, screen name, alias, or online identifier)
   2. Telephone number
   3. Email address
   4. Internet Protocol address
   5. Professional or employment-related information (this may be supplied by your employer on your behalf)\
   6. Social security number, driver’s license number, passport number, or other similar identifier
   7. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement)
   8. Other information that is: (a) not Personal Information; and (b) does not individually identify you (“Other Information”). Examples of Other Information includes browser type, operating system, technical data, and usage data. We may link together different types of Other Information or link Other Information to Personal Information.
   9. Browser type and version
   10. Statistical usage data that is anonymized and aggregated with other users

The Personal Information set out in (A), above, is required to provide our services to you. If you do not provide Personal Information we may ask for, it may delay or prevent us from providing services to you.

2. HOW YOUR PERSONAL INFORMATION IS COLLECTED.

Your Personal Information may be collected:

1. directly from you via our website or any other Electronic Platforms, or when you contact us by telephone, text message, or email; or
2. if your employer supplies information to Bundle on your behalf.

We may also collect information:

• Directly from a third party (e.g., consumer protection non-profits, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., PayPal); and
• From cookies on our website; and
• Via our IT systems, including automated monitoring of our Electronic Platforms and other technical systems, e.g., computer networks and connections, communications systems, email and instant messaging systems.

3. HOW AND WHY WE USE YOUR PERSONAL INFORMATION.

We use the information that we collect about you to provide, maintain, protect and improve the services that we provide to you. We do not sell your information to any third parties and only use it for legitimate business purposes.

The list below explains what we use (process) your personal information for and our reasons for doing so:

• To provide Bundle products and services to you. For the performance of our contract with you or to take steps at your request before entering into a contract
• To prevent and detect fraud against you or Bundle. For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
• Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies. To comply with our legal and regulatory obligations
• Other processing necessary to comply with professional, legal, and/or regulatory obligations that apply to our business. To comply with our legal and regulatory obligations
• Ensuring business policies are adhered to, e.g., policies covering security and internet use. For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
• Operational reasons, such as improving efficiency, training and quality control. For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
• Ensuring the confidentiality of commercially sensitive information. For our legitimate interests of those of a third party, i.e., to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations
• Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures. For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
• Preventing unauthorized access and modifications to systems. For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
• Updating and enhancing customer records. For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests of those off a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
• Statutory returns. To comply with our legal and regulatory obligations
• Ensuring safe working practices, staff administration and assessments. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
• Marketing our services to (a) existing and former customer; (b) third parties who have previously expressed an interest in our services; (c) third parties whom we have had no previous dealings. For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
• Credit reference checks via external credit reference agencies. For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
• Other customer due diligence including communications with industry groups or non-profit consumer groups, e.g., the Better Business Bureau. For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
• External audits and quality checks, e.g. for ISO accreditation and the audit of our accounts. For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations

4. COMMUNICATIONS

We may use your Personal Information to:

communicate with you in order to deliver our products and our services (e.g., to set up appointments and/or resolve scheduling conflicts, see also Section 9 (“SMS Service”)); or

send you updates about our products and services including exclusive offers or new product notifications.

We may communicate with you through any number of methods, including, without limitation, via Electronic Platforms or by email, text message, telephone, or post.

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH.

We routinely share your Personal Information with:

Our affiliates (if any);

Service providers we use to help deliver our products and services to you, such as payment service providers and communication platform providers, e.g., Amazon Chime, Amazon Simple Email Service;

Other third parties we use to help us run our business, including, without limitation, marketing agencies, website hosts, data analytics companies, and providers of business process software, e.g., Craft CMS, HubSpot, Google Analytics;

Bundle's use and transfer of information from Google APIs to any other App will adhere to Google API Services User Data Policy, including the Limited Use requirements. 

Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

Credit reporting agencies;

Our insurers and brokers; and

Our bank(s).

We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers to ensure they can only use your Personal Information for legitimate purposes.

We may also share Personal Information with external auditors, e.g., for ISO accreditation and/or the audit of our accounts. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

If Bundle or any of our affiliates is involved in a merger, acquisition, asset sale, joint venture, or other, similar transaction, you acknowledge and agree that your Personal Information may be transferred to, or accessed by, a successor or other entity and may be subject to that entity’s privacy policies, which may vary from this Privacy Policy.

6. PERSONAL INFORMATION WE DISCLOSED FOR A BUSINESS PURPOSE.

In the preceding 12 months, we may have disclosed, for a business purpose, to one or more third parties the following categories of Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, screen name, alias, or other similar identifiers);

Information that identifies, relates to, describes, or is capable of being associated with you, including, but not limited to, your name, signature, address, telephone number, insurance policy number or other insurance information, education, and/or bank account number, credit card number, debit card number, or other financial information (where applicable);

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement);

Professional or employment-related information (which maybe have been supplied by your employer on your behalf); and

Inferences drawn from any of the information identified above to create a profile about you reflecting your consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

7. WHERE YOUR PERSONAL INFORMATION IS HELD.

Information may be held at our offices and those of our affiliates, third party agencies, service providers, representatives, and agents as described above (see Section 5 (“Who We Share Your Personal Information With”), above).

In order to comply with applicable law and/or regulation, Bundle does not forward, sell, migrate, or otherwise transfer information (including Personal Information) outside the country and/or region in which such information originated. For example, Bundle will ensure that information obtained inside the European Economic Area (“EEA”) will not be sold, migrated, or otherwise transferred outside the EEA.

8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT.

We will retain your Personal Information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your Personal Information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;

To show that we treated you fairly; or

To keep records required by law.

We will not retain your Personal Information for longer than necessary for the purposes set out in this Policy. Different retention periods may apply for different types of Personal Information.

9. SMS SERVICE.

In connection with your use of the Electronic Platforms, you consent to communication through text messages (including those messages originating from short codes). The following terms may apply to text messages you receive from us:

You may cancel text message service at any time by replying “STOP,” “CANCEL,” “END,” “UNSUBSCRIBE,” “QUIT,” or some other similar term. After you send a cancellation message to us, we may send a reply message asking to confirm that you have been unsubscribed. If you confirm, you will no longer receive text messages from us.

If you are experiencing issues with the messaging service you may reply with the keyword “HELP” or some other similar term. You may also contact us to get help directly. See Section 16 (“How to Contact Us”), below.

Bundle is not liable for any delayed or undelivered messages. BUNDLE IS NOT RESPONSIBLE FOR THE TIMELINESS, ACCURACY OR COMPLETENESS OF ANY INFORMATION DELIVERED TO YOU THROUGH THE SMS SERVICE.

Message and data rates may apply for any messages sent to you from Bundle and to Bundle from you. The number and frequency of messages you receive from Bundle may vary. If you have any questions about your text plan or data plan, contact your wireless provider.

10. YOUR RIGHTS UNDER THE GDPR

You may have the following additional rights under the GDPR and certain other privacy and data protection laws, as applicable:

Right to Access. The right to be provided with a copy of your personal information (the right of access)

Right to Rectification. The right to require us to correct any mistakes in your Personal Information

Right to be Forgotten. The right to request, in certain situations, deletion of your Personal Information

Right to Restriction of Processing. The right to require us to restrict processing of your Personal Information in certain

Right to Data Portability. The right to receive, in certain situations, the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party

Right to Object. The right to object:

at any time to your personal information being processed for direct marketing (including profiling), where applicable;

in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

11. YOUR RIGHTS UNDER THE CCPA.

You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You. You have the right to know:

The categories of Personal Information we have collected about you;

The categories of sources from which Personal Information is collected;

Our business or commercial purpose for collecting Personal Information;

The categories of third parties with whom we share Personal Information if any; and

The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that Information about you is retained;

Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or

Provide the Personal Information to you more than twice in a 12-month period

Personal Information Sold or Used for a Business Purpose. we may disclose to a third party for a business purpose, you have the right to know the categories of personal information that we disclosed about you for a business purpose. Bundle does not sell, resell, or rent your Personal Information.

Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you (as described in Section 16 (“How to Contact Us”), below), we will:

Delete your Personal Information from our records; and

Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete you Personal Information if it is necessary to:

Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with state or federal law, provide a good service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performed a contract between you and us;

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

Debug, identify, and repair errors that impair existing intended functionality;

Exercise free speech, ensure the right of another individual too exercise his/her/their right of free speech or exercise another right provided for by law;

Comply with an existing legal obligation; or

Otherwise use your Personal Information, internally, in a lawful manner that is compatible with context in which you provided the Information

Protection Against Discrimination. You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things

Deny goods or services to you;

Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

Provide a different level or quality of goods or services to you; or

Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services, if that difference is reasonably related to the value provided to you by your data.

12. KEEPING YOUR PERSONAL INFORMATION SECURE.

We may disclose your Personal Information to our employees, contractors, agents, and/or affiliated organizations that need to know that information in order to process it on Bundle’s behalf or to provide products and services to you. Some of those employees, contractors, agents and affiliated organizations may be located outside of your state, province or country. Subject to Section 8 (“How Long Your Personal Information Will Be Kept”), by providing your information to Bundle, you consent to the transfer of your information to them.

We take commercially reasonable efforts to guard against unauthorized access, use, alteration, or destruction of Personal Information, which efforts you agree are sufficient, adequate and complete. We limit access to your Personal Information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, we may not immediately delete residual copies of Personal Information that is on our active servers and may not remove information from our backup systems.

If you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in Section 16 (“How to Contact Us”), below.

Bundle does not sell or rent your Personal Information to other organizations for advertising or marketing purposes.

13. HOW TO EXERCISE YOUR RIGHTS

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available on our website at

[https://forms.office.com/Forms...];

Email us at wecare@bundleskills.com; or

Write to us at Bundle LLC, 418 Broadway, STE N, Albany, NY 11207 (USA).

If you choose to contact directly by any of the methods above, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number);

A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

14. HOW TO FILE A GDPR COMPLAINT.

If the GDPR applies to you, you may have the right to lodge a complaint with a supervisory authority in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws has occurred. You can find a list of supervisory authorities here.

15. CHANGES TO THIS PRIVACY NOTICE.

This Privacy Policy was published on [2/1/2020] and last updated on [11/27/2023].

We may change this Policy from time to time–when we do, we will inform you via conspicuous notice displayed on our Electronic Platforms.

16. HOW TO CONTACT US.

If you need additional assistance, please contact us by post or email. Our contact details are shown below:

Our Address: Bundle, LLC, 418 Broadway, STE N, Albany, NY 11207 (USA)

Email: wecare@bundleskills.com