Date of last revision: February 9, 2021
Churn Buster, LLC provides online application services for managing passive churn, which is the loss of a customer due to failed credit card charges. All of our customers are business entities or other organizations that use our service to better manage the timing of their charges to their customers’ credit cards and their communications with their customers around credit card payments.
Churn Buster’s main office is in San Diego, California. We offer our services to customers worldwide.
How to Contact Us
Mail: 237 A Street #74803, San Diego, California 92101
The types of data we collect and our purpose for collecting it depend on how you interact with us. For example, we collect different data about one-time website visitors than authorized users of our application services. We have used defined terms for the different types of relationships to help us explain our privacy practices:
- customer means our application services customer; this is the business or other organization that establishes an account with Churn Buster or our reseller for the use of our services;
- account user means an individual who interacts with us as a representative of our customer; this includes service users, billing contacts, and technical support contacts;
- payor means an individual who has authorized our customer to charge their credit card to pay for our customer’s products or services;
- visitor means an individual who visits our website, our social media pages, our offices, interacts with us at a trade show or other industry event, or communicates with us in some other way other than as an account user or payor;
- services means Churn Buster passive churn reduction services and related analytics services;
- we, our and us refer to Churn Buster;
- you and your refer to visitors, account users, or payors, or all of them, as indicated by the context.
Data Collection Purposes
We collect personal data for our business purposes:
- to operate our website;
- to improve our website and service offerings;
- to market our services;
- to manage our relationship with our customers, including account administration;
- to provide our online services to our customers;
- to provide customer support; and
- to manage our vendors.
We allow third party advertisers, such as NowSpots, Inc. (using the Perfect Audience service) to collect personal data on our site for their use in selling targeted advertisement services, both to Churn Buster and others. See Advertising Ecosystem below.
The Section below captioned, “How We Use Data” explains how we use different categories of data for each of these purposes.
Data Collection Methods
Automated data collection on our website and online services platform
When you visit our site or use the Churn Buster services, our servers capture data that may be used to identify you and your device, such as your IP address, device identifier, and information about your device such as the operating system, time zone setting, language setting, browser settings, and browser plug ins. Depending on your device settings, we may also capture location information. Our servers may also capture information about your visit to our site or services platform, such as the website you visited right before you visited our site, the time and duration of your visit on each page on the site, and your navigation path from page to page (i.e., what you click on). We use third-party service providers such as FullStory to capture other information about your site visit, such as clicks, taps, scrolling, and recordings of your mouse navigation on our site.
We and our third-party analytics providers may use an online tracker (such as a cookie we place on your browser) so that we may identify you as a return visitor if you visit our site more than once. Please see How to Opt Out of Online Data Collection below for information on how to block cookies.
Data provided by advertisers
If you arrive at our site by clicking on a link that is part of an advertisement on another site (including an advertisement on a social media platform), the advertising service will identify the link, enabling us to associate you with the advertising parameters we provided to the advertising service. For example, we may ask an advertising service to target our ad to individuals that the ad service has identified as eCommerce professionals. If you arrive at our site by means of the link in that ad, we will be able to identify you as an eCommerce professional. Advertising services are responsible for the collection, use and disclosure of the data they provide to us in accordance with their published privacy policies. See the section below captioned Advertising Ecosystem and How to Opt Out of Online Data Collection.
Data provided by you as part of your communications with us
We collect personal data that you submit to us as part of a communication with us as a visitor or account user, such as via chat on our site, email, submission of a web form, telephone, or in person (such as at a meeting, trade show or other event). For example, you may communicate with us as a visitor to obtain more information about our services, or as an account user to request technical support. The communication may include information that can be used to identify you such as your name, job title, job function, the organization you represent, email address, phone number as well as information about your interest in our company or our services. We do not solicit information from you as part of these communications other than information that is useful to us in light of the purposes described above, but if you choose to volunteer more personal information than we ask for we will collect that as part of the communication.
Data provided by you or your organization to establish and maintain the Churn Buster account and authorize your use of our services
Our customers are required to name billing, administrative, technical and other types of service and account users who have authority to use our services and manage the customer’s account. We collect the name and business contact information of these account representatives. Our customers also authorize individuals as service users. We require each individual account representative and service user to establish their own set of account credentials (user name and password). If you use a personal payment card or other financial account to make payment arrangements, then we may collect information relevant to the processing of the payment transaction.
Data provided by you or your organization to enable Churn Buster access to your third party accounts
To provide our services we require access to our customers’ accounts with their payment providers, email service providers, and occasionally other third party services such as Zapier. Therefore the customer is required to provide account credentials used by their representatives on those platforms, or to grant Churn Buster dedicated (and revocable) access.
Marketing Partners and Resellers
We have relationships with other companies that help us market, sell and deliver our services. They may collect personal data of the type described above using the methods described above and provide that data to us. For example, we have relationships with companies who refer customers to us. We will treat personal information we receive from our marketing partners and resellers the same as the personal information we collect directly.
Combinations of data collected using different methods
We use service providers such as Google Analytics, Heap, FullStory, Segment, and Intercom to help us associate the personal data we capture about you as part of visitor interactions with personal data we collect about you as an account user.
How We Use Data
This section describes more specifically how our use of the data relates to the purposes for which we collected the data.
Visitors: We use data collected about visitors:
- to operate our website – web servers, by their nature, must capture your IP address and information about your browser and device to display our site to you;
- to develop our website and product offerings – we use the information about visitor navigation on our site to help us understand what part of our website and products offerings is of interest to different kinds of visitors so that we can modify and improve our site content and other marketing materials to be more appealing to prospective customers; we may also use the information about your site visits and other visitor interactions to help us measure interest in our services or various features of our services;
- to show you personalized content when you visit our site – we use information about your prior visit to our site to customize your subsequent visits; for example, we may make more visible to you information or offers about products or services that appear to be of interest to you based on your navigation of our site on a prior visit; if you arrive at our site via an advertisement we may use that fact to make inferences about your interests and target content to you on that basis;
- to measure the success of our advertising efforts – we use visitor information to verify whether the ad services we purchase from third parties are actually resulting in visits to our site or other visitor interactions;
- to register you for webinars, office visits, or other online or off-line events we may host – we may use your name, contact email, contact address, and phone number to register you as an attendee and communicate with you about the event; we might target special content to event registrants when they visit our website based on the type of event.
- to communicate with you as part of our marketing efforts – if you provide us with contact information we may use it to send you communications about our company, our products or services, or related topics that we think you may find of interest;
Account Users: we use data collected about accounts users (alone or as combined with data collected as part of an account user’s visitor activity (such as pre-login activity on the Site):
- to provide our online services – we use login credentials to authenticate individuals as authorized administrative users of our services; we use IP addresses to provide our services
- we use contact information such as your email or physical address to send invoices and other account communications, authenticate individuals who request information or support on the customer’s behalf, and administer the customer’s account, such as processing billing information to complete customer purchases;
- to review compliance with usage terms in our services agreements and enforce the terms and conditions that govern our services; for example if the customer’s use of our services is limited to a certain number of individuals we may use personal data to help us monitor compliance with the usage restrictions;
- to help us develop our service offerings – we use information about your use of our services to measure interest in various features, to plan enhancements and new features, and to improve user experience;
- to communicate with you as part of our marketing efforts – we use contact information and information about your use of our services to send you communications about our products or services, or related topics that we think you may find of interest; and
- to market our services - if you provide a customer testimonial or other content for marketing purposes we will publish the content with your name or other identifying information that you authorize us to use; if you agree that we may use you as a reference, we may provide your name and contact information to prospective customers for our services so that they may contact you to discuss your experience with our services.
Choices and Means to Limit Use and Disclosure or Your Data
You may limit our use and disclosure of your personal data. Please send us a request at firstname.lastname@example.org if you would like to know what personal data we have about you and how we use and disclose that data. You may also submit requests to email@example.com if you want to correct, delete or restrict the use of your personal data, or if you object to our processing of your data on the grounds that we do not have a lawful basis for that processing.
On receipt of your notice that the data we have about you is inaccurate or incomplete, we will promptly correct any inaccurate data and ensure it is complete in light of the purposes for which we process the data.
If you wish to revoke any consent you have previously given, we will honor the revocation and will no longer rely on that consent to process your personal data. For example, if you no longer consent to our use of your data for marketing purposes, we will stop using the data for that purpose and notify any third party with whom we have shared that data that they must also stop using it for that purpose.
On your request, we will promptly restrict processing of your personal data or delete your personal data except to the extent the restriction or deletion will prevent us from complying with our legal obligations to our customer or interfere with our reasonable record keeping as necessary to demonstrate compliance with our contracts and applicable law.
Additional Information for California Visitors, Account Users for Limiting Use and Disclosure of Your Data
In addition to our commitments stated above, if our collection of personal information about you for our own general business purposes is covered by the California Consumer Privacy Act you have certain rights under that law.
You may request disclosure of the following specific information:
- the categories of personal information as well as the specific pieces of personal information that we have collected about you for our business purposes over the prior 12 months,
- the categories of sources from which we have collected that personal information,
- our purpose(s) for collecting that personal information,
- the categories of third parties with whom we have shared the personal information, such as our service providers, and
- whether we have sold the personal information to third parties or disclosed the information to third parties for a business purpose, and if so the categories of personal information and third parties.
In addition, you have the right to ask Churn Buster to delete your personal information. We will comply with your deletion request and require our service providers to do the same, unless we plan to retain the personal information on a legally permitted basis and we give you notice of this fact and the legal basis on which we rely.
You may make a request by sending an email or physical mail request to the addresses above.
Before responding to your request we may ask you to provide information needed to verify that you are the consumer (or have authorization from the consumer) whose personal information is covered by the request.
We may not discriminate against you because you make a request described in this Section by denying you our services or providing a different quality or price for our services, unless the different service or price is reasonably related to the value provided to you by your data.
If you are under 16 years of age, you are not authorized to use our website or our services and we don’t want your personal data.
Our customers provide us with access to personal data about their customers who pay them with payment cards (their “payors”) to enable us to provide our services. This includes access to our customer’s payment processor accounts, and customer information stored within those accounts such as card expiration dates, masked card numbers, email addresses, phone numbers, approximate locations, and customer metadata. We use this personal data about our customers’ payors only as permitted by our customer in our agreement with them. Please contact us at the address above if you have questions or concerns regarding our processing of the data described in this Section. We ask, however, that you first contact our customer if you have a request to access, block, erase or take other action with respect to data that we have solely as a data processor for our customer.
Some of our customers are subject to special data privacy laws, such as the General Data Protection Regulation adopted by the European Union in May 2018 (the “GDPR”) and the California Consumer Privacy Act of 2018 (the “CCPA”). We make appropriate contractual commitments to our customers in support of their obligations under the GDPR, CCPA or other data privacy and protection laws applicable to them.
Our Article 27 representative under the GDPR is: Matt Goldman (CEO)
We have not sold or leased personal data, and will not sell or lease your personal data. The California Consumer Privacy Act includes a definition of “sale” that may include permitting third party advertisers to collect data about our Site visitor for use as part of their advertising services generally. During the prior 12 months we have permitted NowSpots, Inc. dba Perfect Audience to collect data on our site by means of advertising cookies. See the section below captioned Advertising Ecosystem for information on how you block these cookies.
We will not disclose your personal data to third parties except as follows:
This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.
Protecting Network and Information Security
As necessary to protect our information and systems from unauthorized actions that compromise their security or availability, such as disclosures as part of industry initiatives to identify and block malicious actors.
Sale of Business
As part of a sale of a sales of business assets where the purchaser needs the personal data to use the assets.
We may in the future sell all or part of our assets or be involved in a merger. We may provide the company that is seeking to acquire our business with access to personal data as part of their evaluation of our business, but will require them to maintain the personal data in confidence and use it only to evaluate our business. If we complete a transaction, it is customary to transfer personal data that is related to the purchased business assets to the purchaser.
We use the services of companies like the ones listed below to collect data on our behalf or to help us analyze, store, manage and otherwise process your personal data. Each of these companies commits in its contract with us to use the personal data only according to our contract with them or our other instructions as necessary to support our business. They are not authorized to use your personal data for any other purpose. They are not authorized to disclose your personal data to others except with our permission, and only if they require the others to comply with the same restrictions that apply to them.
- Heap, Inc. - analytics
- Google, Inc. – analytics
- Segment.io, Inc. – analytics
- FullStory, Inc. - analytics, session recordings
- Intercom, Inc. – chat and other communications with visitors and account users
- Amazon Web Services, Inc. - infrastructure
- Salesforce, Inc. dba Heroku, - infrastructure
- Accedian dba Skylight – infrastructure monitoring
- New Relic, Inc. – infrastructure monitoring
- Logentries.com, Inc. – infrastructure monitoring
- Cloudflare, Inc. – content delivery and network risk management
- Postmark - messaging
We use online advertising services that enable a practice referred to as “online behavioral advertising.” These services aggregate data about an individual’s behavior on many different sites and online services, and use that data to sell targeted advertising services. For example, we permit NowSpot, Inc.’s advertising service called Perfect Audience to collect data about your behavior on the Churn Buster Site, as do many other website operators who use their services. Advertising service providers combine the data about an individual that they collect from different sources, and use this aggregate data to sell advertising services that target the display of ads to web users who meet certain behavioral criteria. The advertising service providers do not disclose this aggregate data to Churn Buster, but we are able to infer that users who interact with our ad meet the advertising criteria we provided. Advertising providers collect this data using cookies, web server logs (its own and its advertising customers), clear gifs and other online data collection techniques. See Online Data Collection Techniques and How to Opt Out of Online Data Collection.
Online Data Collection Techniques
All Web servers capture certain personal information, such as IP address, in order to serve the Web page visited. Web site operators may also capture personal information using tracking devices such as cookies. A cookie is a unique alphanumeric identifier that is placed by a web server on the browser used to view the content or use the service at the site. Cookies are used to analyze visitors’ use of the website. For example, a website operator can use the cookie to identify the number of unique visitors to the site, whether or not those visitors are repeat visitors, and information about the visitor’s activity on the site, device and device settings. A tracking pixel, also known as a web bug or web beacon, is a small graphic (usually 1 pixel x 1 pixel) invisible to the eye, that is embedded in web content or email. When content that has an embedded web beacon is viewed, the browser will request content from a web server, which in turn will set a cookie.
How To Opt Out Of Online Data Collection
You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.
Our servers do not recognize or respond to any “do not track” setting you may have in your browser.
Some third parties who we permit to collect data on our site have features that allow you to block their data collection via cookies. See their privacy policies and cookie policies. Google’s information is here: https://tools.google.com/dlpage/gaoptout/.
If you do not wish to receive our email or other communications, please send your request to firstname.lastname@example.org. Please note that it may take up to ten days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request.
Children are not permitted to use our site or services. We do not knowingly collect personal information from anyone under 16. If you are under 16, do not use or provide any information on our Sites unless you have involved your parent or guardian. If we discover that we have information about a child we will delete that information. If you are the parent or guardian of a child and you believe we have personal data about the child without your consent, please contact us at the address appearing at the top of this page and we will delete that information.
Churn Buster protects personal data from unauthorized use, disclosure, corruption and destruction using appropriate technical and organizational measures.
We will retain your personal data only for as long as reasonably necessary to fulfill the purpose for which it was collected, and to comply with our legal obligations, and will use secure means to destroy the data after that time. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We will comply with laws applicable to the transfer of personal data across international borders. We provide appropriate contractual commitments to our customers in the European Union that require protections around transfer of personal data to the United States.