Bodega

Privacy Policy

Effective date: August 1, 2022

At Bodega, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing the Bodega Platform in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. 

Remember that your use of the Bodega Platform is at all times subject to our Terms of Use which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

Privacy Policy Table of Contents

What this Privacy Policy Covers

Personal Data

How We Share Your Personal Data

Tracking Tools, Advertising and Opt-Out

Data Security and Retention

Personal Data of Children

California Resident Rights

Other State Law Privacy Rights

European Union and United Kingdom Data Subject Rights

Changes to this Privacy Policy

Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use the Bodega Platform. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and may have collected over the past 12 months:

Category of Personal Data

Examples of Personal Data We Collect

Categories of Third Parties With Whom We Share this Personal Data: 

Profile or Contact Data

  • Email
  • First and last name
  • Crypto Wallet Addresses
  • Personal Data contained in Digital Assets
  • Phone Number
  • Mailing Addresses

  • Service Providers
  • Parties You Authorize, Access or Authenticate
  • Analytics Partners
  • Business Partners

Online Identifiers

  • Cultural or social identifiers related to a Digital Asset
  • Service Providers
  • Parties You Authorize, Access or Authenticate
  • Analytics Partners
  • Business Partners

Payment Data

  • Payment card type
  • Credit or debit card number
  • Billing address, phone number, and email
  • Crypto Wallet addresses
  • Service Providers (specifically our payment processing partners, currently Stripe Inc. and Apple, Inc.

Commercial Data

  • Purchase history
  • Records of Digital Assets

  • Service Providers
  • Parties You Authorize, Access or Authenticate
  • Analytics Partners
  • Business Partners

Device/IP Data

  • IP address
  • Type of device/operating system/browser used to access the services
  • Device ID
  • Service Providers
  • Parties You Authorize, Access or Authenticate
  • Analytics Partners
  • Business Partners

Web Analytics

  • Web page interactions
  • Referring webpage/source through which you accessed the Bodega Platform
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Bodega Platform

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

•Business Partners

Social Network Data

  • Email
  • User name on social media network
  • IP address
  • Social media profile information
  • Device ID
  • Public content posted to social media sites

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

  • Business Partners

Geolocation Data

  • IP address-based location information
  • Specific location data

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

•Business Partners

Demographic Data

  • Age and date of birth
  • Zip code

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

•Business Partners

Sensory Data

  • Photos, videos or recordings of a user’s environment

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

•Business Partners

Inferences Drawn From Other Personal Data Collected

  • Profiles reflecting user attributes
  • Profiles reflecting user behavior and preferences

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

•Business Partners

Other Identifying Information that You Voluntarily Choose to Provide

  • Identifying information in emails or letters you send us

•Service Providers

•Parties You Authorize, Access or Authenticate

•Analytics Partners

•Business Partners

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

Our Commercial or Business Purposes for Collecting Personal Data

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Bodega Platform and promote our business, provided that we will not share such data in a manner that could identify you.  

Tracking Tools, Advertising and Opt-Out

The Bodega Platform uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our services, analyze trends, learn about our user base and operate and improve our services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Bodega Platform does not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Bodega Platform. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Bodega Platform and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Bodega Platform. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Bodega Platform. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly collect or solicit personally identifiable information from anyone under 18. In accordance with the Terms of Use, you must be at least 18 years of age or older to use the Bodega Platform.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at compliance@bodega.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Bodega Platform or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) contains your Bodega User ID and password and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We do not sell your Personal Data as sale is defined in the CCPA. If this practice ever changes, you will have the right to opt out of the sale of your Personal Data.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you. 

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at compliance@bodega.com. However, we do not currently disclose your Personal Data to third parties for such purposes.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at compliance@bodega.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.  

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Bodega will be the controller of your Personal Data processed in connection with the Bodega Platform.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at compliance@bodega.com.  

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Examples of these legitimate interests include (as described in more detail above):

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at compliance@bodega.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

Transfers of Personal Data

The services are hosted and operated in the United States (“U.S.”) through Bodega and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Bodega Platform, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Bodega in the U.S. and will be hosted on U.S. servers, and you authorize Bodega to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.

Changes to this Privacy Policy

We’re constantly trying to improve our services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Bodega website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Bodega Platform, and you are still responsible for reading and understanding them. If you use the Bodega Platform after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: