PRIVACY POLICY

Last Updated: July 1, 2023

California Notice at Collection/State Privacy Rights: See the State Privacy Rights section below for important information about your rights under applicable state privacy laws.

This Privacy Policy ("Policy") describes how Pubmark Inc. d/b/a BookBub ("Company") collects, uses, and shares personal information of consumer users of our websites located at www.bookbub.com and www.chirpbooks.com, our mobile applications ("Applications") (collectively, the "Sites"), and our online services through BookBub and Chirp ("Services"). This Policy also applies to any of our other websites that post this Policy.


PARTICULARLY IMPORTANT INFORMATION

Who We Are. For the purpose of applicable data protection legislation, the data controller of your personal information is Pubmark Inc., One Broadway, Cambridge, MA 02142. Our Data Protection Officer can be reached at [email protected].

Must-Read Sections. We draw your attention in particular to the sections entitled International Data Transfer and Your Choices.

Changes to This Policy. We will post any modifications or changes to our Privacy Policy on our Sites and Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The "Last Updated" legend above indicates when this Policy was last changed. If we make any material changes to the Policy, we will notify you by updating the date of this Privacy Policy and posting a notice on our Sites or other appropriate means prior to those changes taking effect. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Services and our business.


WHAT WE COLLECT

There's a range of information we may collect about you so that we can operate our Sites, Services, or otherwise. This information may include:

  • Information You Give Us. Personal information you may provide to us includes:

    • Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
    • Demographic data, such as your city, state, country of residence, and postal code.
    • Profile data, such as the username and password that you may set to establish an online account on the Services, interests, preferences, and any other information that you add to your account profile.
    • Communications data based on our exchanges with you, including when you contact us through the Services, social media, or otherwise.
    • Transactional data, such as information relating to or needed to complete your orders on or through the Services, including order numbers and transaction history.
    • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
    • Payment data needed to complete transactions, including your payment card information or bank account number.
    • Promotion data, including information you share when you enter a sweepstakes, contest, or giveaway, or when you complete a survey.
    • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
  • Information We Get From Others. We may get information about you from other sources, including:

    • Public sources, such as social media platforms and other publicly available sources.
    • Private sources, such as data providers and data licensors.
    • Marketing partners, such as joint marketing partners and event co-sponsors.
    • Third-party services that you use to sign into, or otherwise link to, your account. This data may include profile information that is made available to us based on your account settings on the third-party service.
  • Information Automatically Collected. We, our service providers, and our business partners may automatically log information about you, your device, and your interactions with the Services, our communications, and other online services, including:

    • Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g. phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g. Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
    • Online activity data, such as pages or screens you view; how long you spend on a page or screen; the website you visited before browsing to the Service; navigation paths between pages or screens; information about your activity on a page or screen; access times and duration of access, authors you follow; books and advertisements you click; audiobooks you purchase or listen to; and your reactions, ratings, and reviews on books.
    • Communication interaction data, such as your interactions with our emails or other communications (e.g. whether you open emails or click links within them). We may do this through the use of pixel tags or clear GIFs, which may be embedded invisibly in our emails.
  • Cookies and Similar Technologies. Some of the automatic collection described above is facilitated by the following technologies:

    • Cookies, which are small data files stored on your device by a website and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and signin status as they navigate a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on our sites.
    • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser, in connection with specific applications.
    • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a page or email was accessed or opened, or that certain content was viewed or clicked.
  • Data About Others. We may offer features that help users invite their friends or contacts to use the Services, and we may collect contact details about these invitees so we can deliver their invitations.


WHAT WE DO WITH THIS INFORMATION

We use the information we collect in the following ways:

  • Service Delivery. To operate, maintain, and improve our Sites and Services; to create and maintain your account, identify you as a user, and customize our Sites for your account; to send you administrative communications, which may include administrative emails, confirmations, technical notices, updates, and security alerts; to respond to your comments and questions; to process payments you make via our Sites, to communicate with you about events or contests in which you participate; to understand your needs and interests, and personalize your experience with the Services; and to provide support for the Services and respond to your requests, questions, and feedback.

  • Research & Development. To improve our Services and our business, and develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services or promote our business, and will not attempt to reidentify any such data.

  • Marketing and Advertising. We, our service providers, and our advertising partners may collect and use your personal information for marketing and advertising purposes:

    • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of these communications as described in the Your Choices section below.
    • Interest-based advertising. Our advertising partners may use cookies and similar technologies to collect information about your interactions with the Services (including the data described in the Information Automatically Collected section above), our communications, and other online services over time, and use this information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
  • Compliance & Operations. We may use your personal information to:

    • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
    • protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims);
    • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
    • enforce the terms and conditions that govern the Services; and
    • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
  • Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

    • Technical operation. To allow the technical operation of the Services, such as by remembering your preferences as you navigate the site, and whether you are signed in to the Services.
    • Functionality. To enhance the performance and functionality of our Services.
    • Advertising. To help our advertising partners collect information about how you use the Services and other online services over time, which they may use to show you ads on other online services that they believe will interest you, and measure the performance of those ads.
  • Analytics. To help us understand user activity on the Services, including which pages are most and least visited and how visitors interact with the Services. For example, we use Google Analytics for this purpose. You can learn more about the information collected by Google Analytics by visiting its privacy policy. You can also learn about how to prevent the use of Google Analytics relating to your user activity here: https://tools.google.com/dlpage/gaoptout?hl=en.


HOW WE SHARE THIS INFORMATION

We may share your personal information as follows:

  • Third Parties Designated by You. We may share your personal information with third parties where you have provided your consent to do so.

  • Our Third-Party Service Providers. We may share your personal information with our third-party service providers who provide services such as data analysis, information technology and related infrastructure, email delivery, and other similar services. We require that our third-party service providers use your personal information only to provide the services we've requested.

  • Payment Processors. Any payment card information you use to make a purchase on the Services is collected and processed directly by our payment processors, such as Braintree. Braintree may use your payment data in accordance with its privacy policy.

  • Our Advertising Partners. We may share your personal information with our third-party advertising partners who enable us to place ads on our Sites, or on third-party websites. For additional information, including options for opting out of our (and our advertising partners') use of cookies and similar technologies, refer to the section below entitled Advertising Choices.

  • Our Other Services. We may share your personal information between our services, BookBub and Chirp. For example, if you create an account on Chirp, we may access the genres of books you like to read from your account on BookBub.

  • Corporate Restructurings. We may share personal information in the context of an actual or proposed business deal involving the sale or transfer of all, or a part of, our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

  • Other Disclosures. We may share personal information as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Privacy Policy; and (d) to protect our rights, privacy, safety, or property, and/or that of you or others.


INFORMATION THAT MAY BE PUBLICLY VISIBLE

If you have a social profile on BookBub, then certain information may be publicly visible, including your name and username; other users you're following; and your reactions, ratings, and reviews that you share with other BookBub users. If you haven't created a social profile, then we may have created one for you using the information you have previously provided, including parts of your email address, to facilitate interacting with features on the site. You can control the information that is publicly visible on your profile by adjusting your privacy settings.

We urge you to be very careful when deciding to disclose your personal information, or any other information, on our Sites.


COOKIES

We use several types of cookies on our sites:

  • Essential Cookies. These cookies are essential to provide you with services available through our Sites. For example, when you sign in to our Sites, we may send cookies to your device so that we can identify you as a user.

  • Functionality Cookies. These cookies are used to remember choices you make when you use our Sites, such as your country. The purpose of these cookies is to provide you with a more personal experience.

  • Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Sites and how users use the Sites. The information is aggregated and anonymous and does not identify any individual visitor. It includes the number of visitors to our Sites, the pages they visited, and other similar information. We use this information to help operate, maintain, and improve our Sites.

  • Social Media Cookies. These cookies are used when you share information using a social media sharing button on our Sites or engage with our content on or through a social network such as Facebook or Twitter. The social network will record that you have done this.


YOUR CHOICES

Opt-out. You can contact us any time to opt-out of (a) promotional communications, (b) any new processing of your personal information that we may carry out beyond the original purpose, or (c) the transfer of your personal information outside the EEA. Please note that your use of some of the Sites or Services may be ineffective upon opt-out.

Access. You can access the information we hold about you at any time by viewing your account on our Sites or by contacting us directly.

Amend. You can also contact us to update or correct any inaccuracies in your personal information.

Move. Your personal information is portable โ€” i.e. you have the flexibility to move your data to other service providers as you wish.

Erase and Forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

You may have an account on BookBub, Chirp, or both Sites.

If you wish to exercise any of these rights, please contact us (BookBub, Chirp). In your request, please make clear (a) what personal information is concerned, and (b) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Some of these rights may be offered based on the jurisdiction in which you live, and may not be available to everyone.

When you receive promotional emails from us, you can also unsubscribe or opt-out by clicking the link at the bottom of any of the emails. You can't opt-out of receiving administrative communications.

In order to use our Sites, you need to provide us with your email address. If you cannot provide us with your email address, you cannot use our Sites.

Advertising Choices. Like many companies online, we may use services provided by Google and other companies that rely on technologies โ€” such as cookies and web beacons โ€” to collect information directly from your device about your browsing activities, your interactions with websites, and the device you're using to connect to the Internet. There are a number of ways to opt-out of having your online activity and device data collected through these services, which we have summarized below:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly.

  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising. Please check the instructions for your operating system: iOS or Android.

  • Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based advertising by using a browser with privacy features, like Brave, or by installing browser plug-ins that block third-party cookies and trackers.

  • Platform opt-outs. The following advertising partners offer features that let you opt-out of the use of your information for interest-based advertising:

  • Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies. Because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://www.allaboutcookies.org.

Blocking images/clear GIFs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Managing settings on third-party services. If you choose to connect to our Services through a third-party service, then you may be able to use your account settings on that third-party service to limit the information we receive from it. If you revoke our ability to access information from a third-party service, that choice will not apply to information that we have already received.

Deleting your content or closing your account. You can choose to delete certain content through your account. If you wish to close your account, please contact us (BookBub, Chirp).


GOOGLE RECAPTCHA

We use Google reCAPTCHA, which identifies bots by collecting hardware and software information and sending that data to Google for analysis. To learn more about Google reCAPTCHA, please visit https://www.google.com/recaptcha/about/ and https://policies.google.com/privacy.


DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes for which we collected it. These purposes may include satisfying any legal, accounting, or reporting requirements; establishing or defending legal claims; or fraud prevention.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.


INTERNATIONAL DATA TRANSFER

Your information, including personal information that we collect from you, may be transferred to, stored at, and processed by us and other third parties outside the country in which you reside, including but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Sites, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We will only process your personal information in accordance with applicable data protection and privacy laws. We need certain personal information in order to provide you with access to our Sites. If you are an EU resident and you registered with us, you will have been asked to check a box indicating your agreement to provide this information in order to access our Services. This consent provides us with the legal basis we require under applicable law to process your information. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal information in line with this Privacy Policy, please do not use our Sites.

You can only use Chirp if you reside in the United States or Canada.


SENSITIVE PERSONAL INFORMATION

Subject to the next two paragraphs, we ask that you not send us, and you do not disclose, any sensitive personal information (e.g. social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our Sites or otherwise to us.

If you send or disclose any sensitive personal information to us when you submit user-generated content to our Sites, you consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such user-generated content to our Sites.

In certain cases, we may collect race and ethnicity information, LGBTQ identity, disability status, or other information from authors who choose to share it with us. This information is collected on a voluntary basis from authors with their explicit consent, and is used to audit and track promotions. If you're an author who provided this information, you can withdraw your consent at any time by contacting us (BookBub, Chirp).


OTHER SITES AND SERVICES

The Sites and Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.


OUR POLICY ON CHILDREN

Our Sites are not directed at children under 16. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact us (BookBub, Chirp), and we will delete such information as soon as reasonably practicable.


USER TESTIMONIALS AND FEEDBACK

We often receive testimonials and comments from users who have had positive experiences with our Services, and we occasionally publish them. We obtain the user's consent prior to posting any feedback on a public area of our Sites.


STATE PRIVACY RIGHTS

This section applies to California, Virginia, Colorado, and Connecticut residents and provides additional information pursuant to applicable state privacy laws, including the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), and the Connecticut Data Privacy Act ("CTDPA") (collectively, the "State Privacy Laws"). In this section, the term "Personal Information" means information defined as "personal information," "personal data," or other similar terms under the State Privacy Laws. The State Privacy Laws may provide residents with some or all of the rights listed below. Please note that not all rights listed below may be afforded to all users, and if you are not a resident of one of the states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. We may decline your request in certain cases as permitted by law.

Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

  • Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting Personal Information.
    • The categories of third parties with which we share Personal Information.
    • The categories of Personal Information that we disclosed for a business purpose.
    • The categories of third parties to whom the Personal Information was disclosed for a business purpose.
  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

  • Appeal. You can appeal our denial of any request validly submitted.

  • Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

  • Deletion. You can ask us, subject to certain exceptions, to delete the Personal Information that we have collected from you.

  • Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of Personal Information for targeted advertising purposes.

  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

How to exercise your rights to information, access, appeal, correction, or deletion. You can submit requests to exercise your rights to information, access, appeal, correction, or deletion by contacting us (BookBub, Chirp) or by emailing us (BookBub, Chirp).

Exercising your right to opt-out of processing for targeted advertising purposes. Like many companies, we use services that help deliver interest-based ads to you as described above. The State Privacy Laws may classify our use of some of these services as "sharing" your personal information with our advertising partners. You can opt-out of this tracking by visiting our Your Privacy Choices page (BookBub, Chirp). Your request to opt-out will apply only to the browser and the device from which you submit the request. You can also opt-out by enabling Global Privacy Control (GPC) for each supported browser that you use. Learn more about Global Privacy Control.

We share the following categories of Personal Information with advertising partners: Device data and Online activity data.

Verification of identity; authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under the State Privacy Laws, you may be permitted to authorize an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your privacy rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Additional information for California residents

  • Sensitive personal information. We do not use or disclose Sensitive Personal Information for purposes that California residents have a right to limit under the California Consumer Privacy Act.

  • Sources and purposes. We collect all categories of Personal Information from the sources listed in the What We Collect section above and use them for the purposes described in the What We Do With This Information section above.

  • Collection and disclosure. The list below describes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code ยง1798.140), and the categories of third parties to whom we disclose it. The terms in the list refer to the categories of information and third parties detailed above in the What We Collect and the How We Share This Information sections. Information you voluntarily provide to us, such as in forms, may contain other categories of Personal Information not described below. We may also disclose Personal Information to professional advisors, law enforcement and government authorities, and business transferees as described above.

    • Identifiers. Identifiers may include Contact data, Demographic data, Profile data, Communications data, Transactional data, Marketing data, Promotion data, Data about others, Device data, Online activity data, and Communication interaction data. We may disclose this information with the following categories of third parties: Third Parties Designated by You, Our Third-Party Service Providers, Payment Processors, Our Advertising Partners, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • California customer records. California customer records may include Contact data, Demographic data, Profile data, Communications data, Transactional data, Marketing data, Promotion data, Data about others, Device data, Online activity data, and Communication interaction data. We may disclose this information with the following categories of third parties: Third Parties Designated by You, Our Third-Party Service Providers, Payment Processors, Our Advertising Partners, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • Commercial information. Commercial information may include Contact data, Demographic data, Profile data, Communications data, Transactional data, Marketing data, Promotion data, Data about others, Device data, Online activity data, and Communication interaction data. We may disclose this information with the following categories of third parties: Third Parties Designated by You, Our Third-Party Service Providers, Payment Processors, Our Advertising Partners, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • Financial information. Financial information may include Transactional data and Payment data. We may disclose this information with the following categories of third parties: Our Third-Party Service Providers, Payment Processors, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • Online identifiers. Online identifiers may include Contact data, Demographic data, Profile data, Communications data, Marketing data, Promotion data, Data about others, and Communication interaction data. We may disclose this information with the following categories of third parties: Third Parties Designated by You, Our Third-Party Service Providers, Payment Processors, Our Advertising Partners, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • Internet or network information. Internet or network information may include Communications data, Device data, Online activity data, and Communication interaction data. We may disclose this information with the following categories of third parties: Third Parties Designated by You, Our Third-Party Service Providers, Payment Processors, Our Advertising Partners, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • Inferences. Inferences may be derived from any of the above categories. We may disclose this information with the following categories of third parties: Third Parties Designated by You, Our Third-Party Service Providers, Payment Processors, Our Advertising Partners, Our Other Services, Corporate Restructurings, or Other Disclosures.
    • Protected classification characteristics. We do not intentionally collect this information, but it may be revealed in information we collect.


CONTACT INFORMATION

Thanks for using our sites, and for reviewing our Privacy Policy. We welcome your comments or questions about this Privacy Policy. If you have any feedback, we encourage you to contact us (BookBub, Chirp).