Last Updated: 19 December 2017
Boku, Inc. (for itself, and on behalf of its subsidiaries and affiliated entities, “Boku”) is committed to respecting and protecting your privacy. We value your trust and want you to understand how we protect, collect, use and disclose the personal information you share with us.
This privacy statement applies to personal information we obtain anytime you interact with Boku such as when you visit our website (boku.com), interact with a participating merchant (“Merchant”) or contact Boku support. We want to ensure you are aware of our practices for collecting and processing personal information, which is information about a person that can be used to identify that person. This privacy statement does not apply to Merchants accessing and using the Merchant portions of our website. The collection, use and disclosure of Merchant data and information is governed by the legal agreement between Boku and the Merchant.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Boku, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, and according to the applicable Principles of each Framework. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
Boku, Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and any subsequent transfers to third parties acting as agents on its behalf. Boku, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer of liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Boku, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
What we collect
We collect personal information to process transactions and to administer our business (“the Boku Service”). The type of personal information we collect in connection with providing the Boku Service may include contact information such as mobile number, wireless network, computer or network connection identifiers, country, billing amount and Merchant or such other information we may collect with your consent or as permitted or required by law.
How we use it
We use personal information in a number of ways such as to complete your transaction, administer any problems that may arise in carrying out the transaction, to better understand and manage our ongoing relationship with you, to assure good service, to prevent fraud and abuse, for the purposes of verification and risk management and otherwise with consent or as permitted or required by law. Boku may store personal information on databases for the purposes of the administration of our business, including our ongoing relationship with you, for market research and, only with your consent, for direct marketing purposes. As permitted by applicable law, we may merge personal information with public information or other information received from reputable vendors to update contact information or to enhance demographic profiles. We will retain your information for a minimum of 5 years or as necessary to comply with our legal obligations or resolve disputes. If you wish to request that we remove your information from our systems and no longer provide you with services you may contact us.
Who we share it with
Boku will not sell, rent, or lease your personal information. We may share all of the information, as described above, with Merchants, our affiliates and our agents in connection with goods and services these parties perform for, or with, Boku for the uses described in “How we use it” and for other purposes as permitted or required by law. In particular, use of your personal information for marketing purposes by Boku and/or our agents will always be made with your consent and in compliance with the applicable law regarding customer consent. Disclosures permitted or required by law may include cooperation with criminal or government investigations, fraud prevention and detection, and responses to a court order or subpoena. Boku agents are bound by appropriate data safeguarding obligations. Our Merchants, agents and affiliates may be located outside the European Economic Area.
Boku may disclose some or all of the personal information to Merchants and service providers for the purposes of processing the requested transactions, improving the user experience or to perform business support functions on our behalf. Our agreements with service providers will contain confidentiality provisions and restrictions on using this information for any other purpose. If Boku becomes involved in a merger, acquisition or any form of sale of some or all its assets, we may disclose personal information to third parties in connection with the evaluation of the transaction. The surviving company, or the acquiring company in the case of a sale of assets, would have access to personal information that would continue to be subject to this privacy statement.
Boku will not use or share your personal information in ways incompatible with the ones described above without providing you a choice. You must opt-out of any sharing of personal information you have authorized or consented to as described above. However, to the extent that applicable law requires express consent or “opt-in” for the collection and use of personal information, Boku will maintain processes and procedures to ensure such information is collected with express consent. Your mobile number will not be used to directly market Boku services unless that possible use has been disclosed and a choice provided.
Accuracy & Access
Boku is committed to ensuring that the information we obtain and use about you is accurate for its intended purpose. Upon request Boku will provide you with information about whether we hold any of your personal information. You can contact us at any time to review, update, request deletion or correct (for future use) your personally identifiable information maintained by Boku. We will reply to your request within thirty (30) days of submission. You can help us maintain accurate records by informing us of changes or modifications to your personal information.
Boku utilizes physical, electronic and procedural security measures to protect against loss, misuse, and alteration of information under our control. Boku offers industry–standard practices and security measures to safeguard and secure the personal information we collect.
Access to personal information is restricted to Merchants, employees and service providers who need to have access to that information as described in this privacy statement. Boku requires its service providers to observe standards with respect to the security, collection, use and sharing of personal information, and to comply with applicable law. We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. When you enter sensitive information such as your mobile number, we encrypt that information using secure socket layer technology (SSL).
If Boku learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Boku Service, you agree that Boku may communicate with you electronically or via short messaging service (SMS). Boku may post a notice on the Boku website if a security breach occurs. Boku may also send you an email to you at the email address, if any, you have provided to us or send you an SMS to the mobile number you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us.
Preventing Identity Theft
Boku is dedicated to protecting your personal information. We will never initiate a request for personal information from you by fax or email, except in response to communications initiated by you. Please do not send confidential personal information such as social security numbers, government identification numbers, or account numbers to Boku via an unsecured email message. You may send confidential information to Boku via posted mail, phone or contact us. Do not be misled by emails that appear to be from us and ask for personal information. If you receive a suspicious email requesting your personal information, please forward the email immediately to [email protected]. To report fraud to the Internet Fraud Complaint Center, visit www.ic3.gov. This is a partnership between The FBI and the National White Collar Crime Center.
When you browse our websites or request pages, we automatically collect certain technical information about your visit. Examples of this standard type of information include the type of Internet browser you use, your IP address, browser headers, the files you request and the domain name and country from which you request information. We use this type of technical information to make our website function correctly, to better understand how visitors use our website and to improve the website, its contents and functionality to meet your needs. As part of our efforts to protect customers from fraud, this information is also used to assist in authenticating who you are when you access the website.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
Privacy practices of third parties
Boku is not responsible for the content or information practices employed by other websites that are linked to or from our website or which use the Boku Service. In most cases where links are provided, they are provided as pointers to information on services that may be useful to users. These sites and the Merchant sites providing mobile payment services using the Boku Service are governed by their own privacy statements. You are encouraged to review the privacy statement of these other websites before providing them with personal information.
Third Party Cookies
Use by Children
Boku will not knowingly collect personal information from children under the age of 13, without the consent of a parent or guardian.
Change in Privacy Statement
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify you here, by email, or by means of a notice on our home page.
For more information or if you have questions
Should you have further questions regarding our privacy statement or about how your personal information is used, you can contact us.
735 Battery St.
San Francisco, CA, 94111 USA