PRIVACY POLICY
Effective as of February 18, 2026
This Privacy Policy explains how we collect and use information about you when you use the Friendbuy website located at www.friendbuy.com (“Site”) and other Friendbuy services (“Services”).
In this Privacy Policy, “you” refers to any user of our Site or Services, including retailers, publishers, merchants and others who have an account with Friendbuy (“Merchants”) and customers and other end users of Merchants, including individuals who are referred to the Merchant (collectively, “End Users”). Friendbuy’s Site is intended for use by our Merchants. Friendbuy’s Services include online tools (“widgets”) and other features for Merchants to facilitate and analyze their referral marketing and loyalty programs. Referral marketing programs allow an End User to share information about Merchant products and services with friends, who are also treated as End Users under this policy. Loyalty programs allow Merchants to reward End Users for their purchases and interactions with the brand. Below, we describe how we treat the information we receive from Merchants and the information we receive about End Users on behalf of Merchants.
In this Privacy Policy, “you” refers to any user of our Site or Services, including retailers, publishers, merchants and others who have an account with Friendbuy (“Merchants”) and customers and other end users of Merchants, including individuals who are referred to the Merchant (collectively, “End Users”). Friendbuy’s Site is intended for use by our Merchants. Friendbuy’s Services include online tools (“widgets”) and other features for Merchants to facilitate and analyze their referral marketing and loyalty programs. Referral marketing programs allow an End User to share information about Merchant products and services with friends, who are also treated as End Users under this policy. Loyalty programs allow Merchants to reward End Users for their purchases and interactions with the brand. Below, we describe how we treat the information we receive from Merchants and the information we receive about End Users on behalf of Merchants.
INFORMATION WE COLLECT
Merchant Information
If you register to create a Friendbuy account, we will collect your email address, full name and any other information you submit to us (“Merchant Information”). When you purchase our Services, Friendbuy utilizes a third party payment processor that collects your credit card information, mailing address, and other billing information to process payments on Friendbuy’s behalf.
End User Information
If you use any Friendbuy Services as an End User, we will collect the following information on behalf of our Merchants: (i) your e-mail address, (ii) any other personal information you submit on a Friendbuy widget (such as your date of birth or friend’s name and e-mail address), (iii) any information that we receive from social media platforms (e.g., Facebook, Twitter) when you choose to use them, and (iv) any other information or content you post on, or using, our Services (collectively, “End User Information”).
We will also collect End User Information when Merchants provide it to us. The End User Information provided by Merchants can include, for example, your account information to allow Friendbuy to deliver payments or other incentives that Merchants offer to you.
Friendbuy does not currently respond to web browser “Do Not Track” signals in connection with our collection of End User Information or Automated Information (defined below).
We will also collect End User Information when Merchants provide it to us. The End User Information provided by Merchants can include, for example, your account information to allow Friendbuy to deliver payments or other incentives that Merchants offer to you.
Friendbuy does not currently respond to web browser “Do Not Track” signals in connection with our collection of End User Information or Automated Information (defined below).
Automated Information
This section applies to everyone who uses the Site or Services: Merchants, End Users and anyone else who navigates to the Site or our Services. When you visit the Site or use our Services (including using Friendbuy Services on a Merchant website), we automatically collect certain information from your browser or device (“Automated Information”).
Like most other online businesses, we use cookies, pixels, web beacons, and other automated mechanisms to collect this information. Through these mechanisms we collect information such as your mobile device’s advertising identifier or other device identifiers, a cookie identifier, your computer’s IP address, information about your browser or device, and information about how you use our Site and the Services. By browsing our Site or using our Services, you agree to the collection and use of this information as described in this Privacy Policy.
Like most other online businesses, we use cookies, pixels, web beacons, and other automated mechanisms to collect this information. Through these mechanisms we collect information such as your mobile device’s advertising identifier or other device identifiers, a cookie identifier, your computer’s IP address, information about your browser or device, and information about how you use our Site and the Services. By browsing our Site or using our Services, you agree to the collection and use of this information as described in this Privacy Policy.
HOW WE USE AND SHARE YOUR INFORMATION
Merchant Information
We use and share Merchant Information for our lawful business purposes, including to provide and improve our Site and Services, to facilitate billing and payment, to authenticate a Merchant’s identity, to contact Merchants about their accounts and for internal reporting and planning. We also use and share this information to provide Merchants with useful advertising and offers. Merchants can opt out of receiving commercial emails from us by clicking on the opt-out link in the emails that are sent by Friendbuy. See below for more information on how we may share Merchant Information, and for information on how we handle Merchant Information from the European Economic Area and Switzerland.
End User Information
We use End User Information to operate the Services we provide to Merchants. When you use these Services as an End User, this may include sharing some information about you with the other End User(s) you refer to a Merchant.We share End User Information with the Merchant on whose website, applications, and systems the End User Information was collected or who otherwise facilitated the End User’s use of our Services, and not with other Merchants. Friendbuy does not share or sell End User Information to any other non-affiliated organizations for those third parties’ marketing purposes.If an End User provides any information to the Merchant either directly or by submitting the information through Friendbuy’s Services, the information will be subject to the Merchant’s privacy policy; Friendbuy does not control what a Merchant does with such information. Merchants can use and share End User Information for Merchants’ own purposes, including to market to End Users.
Automated Information
We use Automated Information from Merchants to provide and improve our Site and Services and, from time to time, to make Merchants aware of new products and offers from Friendbuy.We use Automated Information from End Users to provide and improve our Services.See below for more information on how we may share Automated Information from Merchants and End Users.
End User Information
We use End User Information to operate the Services we provide to Merchants. When you use these Services as an End User, this may include sharing some information about you with the other End User(s) you refer to a Merchant.We share End User Information with the Merchant on whose website, applications, and systems the End User Information was collected or who otherwise facilitated the End User’s use of our Services, and not with other Merchants. Friendbuy does not share or sell End User Information to any other non-affiliated organizations for those third parties’ marketing purposes.If an End User provides any information to the Merchant either directly or by submitting the information through Friendbuy’s Services, the information will be subject to the Merchant’s privacy policy; Friendbuy does not control what a Merchant does with such information. Merchants can use and share End User Information for Merchants’ own purposes, including to market to End Users.
Automated Information
We use Automated Information from Merchants to provide and improve our Site and Services and, from time to time, to make Merchants aware of new products and offers from Friendbuy.We use Automated Information from End Users to provide and improve our Services.See below for more information on how we may share Automated Information from Merchants and End Users.
ADDITIONAL SHARING WITH THIRD PARTIES
In addition to the reasons we share Merchant Information, End User Information and Automated Information to operate our Site and Services as stated above, we will share your information in the following circumstances:
We will share your information with your consent.
We will share your information with affiliated companies if Friendbuy becomes affiliated with another company in the future.
We will share your information to investigate, prevent, or take action regarding actual or suspected illegal activities, fraud, situations involving potential threats to the physical safety of any person, violations of our contracts or Terms of Service, or as otherwise required by law. For example, we may disclose your information in response to a subpoena or compulsory process, if requested by a law enforcement or regulatory agency, or to prevent imminent harm or financial loss to Friendbuy or others. We also reserve the right to provide your information to a third party if we believe such disclosure may prevent harm or liability to us or others.
We will transfer your information as part of due diligence or an actual or potential sale or merger of part or all of our business, including in bankruptcy.
We will share your information with any third party who is helping us provide the Site or Services (e.g., data hosting, email services, credit card and other payment processors).
We will share any information that does not identify a specific person or device, such as information that has been de-identified or aggregated, in our discretion.
DIGITAL ADVERTISING AND ANALYTICS
On our Site, we partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads are personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other websites or apps over time. This type of advertising is known as interest-based advertising.
You can visit www.aboutads.info to learn more about interest-based advertising and how to opt -out of this advertising on websites by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program.
We also use third parties for non-advertising purposes, including analytics, on our Site and Services. These providers use automated means such as cookies (which are text files placed on your computer) to collect information across non-affiliated websites and online services over time that will be transmitted to and stored on their servers. These services also may transfer information to third parties as permitted by their own privacy policies, such as if they are legally required to do so or where such third parties process information on their behalf. Among other such services, we use Google Analytics. For more information about how Google collects and uses data, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
You can refuse the use of cookies by selecting the appropriate settings on your browser but if you do so, you may not be able to use the full functionality of the Site and Services, and these third parties could still collect data by other means. By using the Site or Services, you consent to our third-party providers’ processing of your data as described above.
EUROPEAN, UNITED KINGDOM, AND SWISS MERCHANT INFORMATION
As described in this Privacy Policy, we may obtain End User Information from, or on behalf of, Merchants who use our Services. We act as a processor for those Merchants, which have their own privacy policies that describe how they use information. When Friendbuy is processing End User Information on behalf of a Merchant as a processor, the End User must reach out to that Merchant directly to exercise any rights under local data protection laws.
Friendbuy is a data controller with regard to Merchant Information from the European Economic Area (EEA), United Kingdom (UK), or Switzerland. This section applies to our processing of such Merchant Information from the EEA, UK, and Switzerland.
Lawful Basis for Processing. Friendbuy processes Merchant Information with your consent (e.g., when Friendbuy processes Merchant Information submitted to the Site for specified purposes).
On other occasions, Friendbuy may process Merchant Information when it needs to do this to fulfil a contract (for example, for billing purposes) or where required to do this by law.
If necessary, Friendbuy may also process Merchant Information when it is in Friendbuy’s legitimate interests to do this (e.g., for customer service or fraud detection) and when these interests are not overridden by your data protection rights.
Transfers of Personal Information. Please be aware that the personal information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, including in the United States. Friendbuy enters into Standard Contractual Clauses for the transfer of personal information outside of the EEA, UK, and Switzerland or we will otherwise transfer personal information subject to appropriate safeguards.
Your Rights. You have the following rights with respect to Merchant Information that we hold about you:
- To request access to your Merchant Information;
- To request that we rectify or erase your Merchant Information;
- To request that we restrict or block the processing of your Merchant Information;
- Under certain circumstances, to receive your Merchant Information that we store and transmit to another, including requesting that we provide your personal data directly to another, i.e., a right to data portability; and
- Where we previously obtained your consent, to withdraw consent to our processing of your Merchant Information.
To exercise these rights, see the “Contact Us” section below. Please be aware that exceptions may apply or Friendbuy may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Additionally, you have the right to lodge a complaint against us. To do so, contact the data protection supervisory authority in your country of residence.
U.S. STATE PRIVACY INFORMATION
As described in this Privacy Policy, we may obtain End User Information from, or on behalf of, Merchants who use our Services. In this respect, we act as a “service provider” or “processor” for those Merchants, which have their own privacy policies that describe how they use information.
When Friendbuy is processing End User Information on behalf of a Merchant as a service provider or a processor, the End User must reach out to that Merchant directly to exercise any rights the End User may have under applicable state privacy laws. Friendbuy is not currently subject to the California Consumer Privacy Act (“CCPA”) in connection with personal information about Merchants.[V2]
THIRD-PARTY LINKS
The Site and Services include links to third-party websites or apps including social media platforms. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy notices of other websites or apps to learn about their data practices.
SECURITY
We ask that you take responsibility for protecting your password and safeguarding your account against unauthorized access. While we take steps to protect the personal information we collect or receive, we cannot guarantee its security because no method of transmission over the Internet or method of electronic storage is entirely secure.
UPDATING YOUR INFORMATION
Merchants can review or update Merchant Information by logging into your Friendbuy account and navigating to the Accounts menu or contacting us at support@friendbuy.com.
If you, as an End User, would like to review or update the End User Information that Friendbuy maintains about you, please contact the Merchant to which you submitted the information.
RETENTION OF YOUR INFORMATION
We keep Merchant Information as long as a Merchant has an account with us or as needed to provide the Services to the Merchant. We also retain and use Merchant Information after an account is closed if we believe it is necessary or beneficial for legal compliance or to resolve disputes, operate our business or enforce our agreements. We may retain End User Information and Automated Information according to our internal data retention policy, including after the associated Merchant account is closed. We will retain End User Information in accordance with our Merchant contracts and applicable laws, including state privacy laws.
CHANGES TO THIS POLICY
We may modify this Privacy Policy at any time. We will let you know of any changes by posting the revised policy on the Site and updating the effective date.
LOCATION OF YOUR INFORMATION
Your information may be transferred to and maintained on servers outside your country. We may process and store information in the United States and other countries, and your use of our Services constitutes your consent to and understanding of this transfer and processing.
CONTACT US
To contact Friendbuy about anything in our Privacy Policy, including any questions or suggestions, please send an email to legal@friendbuy.com.
In addition to the reasons we share Merchant Information, End User Information and Automated Information to operate our Site and Services as stated above, we will share your information in the following circumstances:
We will share your information with your consent.
We will share your information with affiliated companies if Friendbuy becomes affiliated with another company in the future.
We will share your information to investigate, prevent, or take action regarding actual or suspected illegal activities, fraud, situations involving potential threats to the physical safety of any person, violations of our contracts or Terms of Service, or as otherwise required by law. For example, we may disclose your information in response to a subpoena or compulsory process, if requested by a law enforcement or regulatory agency, or to prevent imminent harm or financial loss to Friendbuy or others. We also reserve the right to provide your information to a third party if we believe such disclosure may prevent harm or liability to us or others.
We will transfer your information as part of due diligence or an actual or potential sale or merger of part or all of our business, including in bankruptcy.
We will share your information with any third party who is helping us provide the Site or Services (e.g., data hosting, email services, credit card and other payment processors).
We will share any information that does not identify a specific person or device, such as information that has been de-identified or aggregated, in our discretion.
DIGITAL ADVERTISING AND ANALYTICS
On our Site, we partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads are personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other websites or apps over time. This type of advertising is known as interest-based advertising.
You can visit www.aboutads.info to learn more about interest-based advertising and how to opt -out of this advertising on websites by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program.
We also use third parties for non-advertising purposes, including analytics, on our Site and Services. These providers use automated means such as cookies (which are text files placed on your computer) to collect information across non-affiliated websites and online services over time that will be transmitted to and stored on their servers. These services also may transfer information to third parties as permitted by their own privacy policies, such as if they are legally required to do so or where such third parties process information on their behalf. Among other such services, we use Google Analytics. For more information about how Google collects and uses data, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
You can refuse the use of cookies by selecting the appropriate settings on your browser but if you do so, you may not be able to use the full functionality of the Site and Services, and these third parties could still collect data by other means. By using the Site or Services, you consent to our third-party providers’ processing of your data as described above.
EUROPEAN, UNITED KINGDOM, AND SWISS MERCHANT INFORMATION
As described in this Privacy Policy, we may obtain End User Information from, or on behalf of, Merchants who use our Services. We act as a processor for those Merchants, which have their own privacy policies that describe how they use information. When Friendbuy is processing End User Information on behalf of a Merchant as a processor, the End User must reach out to that Merchant directly to exercise any rights under local data protection laws.
Friendbuy is a data controller with regard to Merchant Information from the European Economic Area (EEA), United Kingdom (UK), or Switzerland. This section applies to our processing of such Merchant Information from the EEA, UK, and Switzerland.
Lawful Basis for Processing. Friendbuy processes Merchant Information with your consent (e.g., when Friendbuy processes Merchant Information submitted to the Site for specified purposes).
On other occasions, Friendbuy may process Merchant Information when it needs to do this to fulfil a contract (for example, for billing purposes) or where required to do this by law.
If necessary, Friendbuy may also process Merchant Information when it is in Friendbuy’s legitimate interests to do this (e.g., for customer service or fraud detection) and when these interests are not overridden by your data protection rights.
Transfers of Personal Information. Please be aware that the personal information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, including in the United States. Friendbuy enters into Standard Contractual Clauses for the transfer of personal information outside of the EEA, UK, and Switzerland or we will otherwise transfer personal information subject to appropriate safeguards.
Your Rights. You have the following rights with respect to Merchant Information that we hold about you:
- To request access to your Merchant Information;
- To request that we rectify or erase your Merchant Information;
- To request that we restrict or block the processing of your Merchant Information;
- Under certain circumstances, to receive your Merchant Information that we store and transmit to another, including requesting that we provide your personal data directly to another, i.e., a right to data portability; and
- Where we previously obtained your consent, to withdraw consent to our processing of your Merchant Information.
To exercise these rights, see the “Contact Us” section below. Please be aware that exceptions may apply or Friendbuy may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Additionally, you have the right to lodge a complaint against us. To do so, contact the data protection supervisory authority in your country of residence.
U.S. STATE PRIVACY INFORMATION
As described in this Privacy Policy, we may obtain End User Information from, or on behalf of, Merchants who use our Services. In this respect, we act as a “service provider” or “processor” for those Merchants, which have their own privacy policies that describe how they use information.
When Friendbuy is processing End User Information on behalf of a Merchant as a service provider or a processor, the End User must reach out to that Merchant directly to exercise any rights the End User may have under applicable state privacy laws. Friendbuy is not currently subject to the California Consumer Privacy Act (“CCPA”) in connection with personal information about Merchants.[V2]
THIRD-PARTY LINKS
The Site and Services include links to third-party websites or apps including social media platforms. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy notices of other websites or apps to learn about their data practices.
SECURITY
We ask that you take responsibility for protecting your password and safeguarding your account against unauthorized access. While we take steps to protect the personal information we collect or receive, we cannot guarantee its security because no method of transmission over the Internet or method of electronic storage is entirely secure.
UPDATING YOUR INFORMATION
Merchants can review or update Merchant Information by logging into your Friendbuy account and navigating to the Accounts menu or contacting us at support@friendbuy.com.
If you, as an End User, would like to review or update the End User Information that Friendbuy maintains about you, please contact the Merchant to which you submitted the information.
RETENTION OF YOUR INFORMATION
We keep Merchant Information as long as a Merchant has an account with us or as needed to provide the Services to the Merchant. We also retain and use Merchant Information after an account is closed if we believe it is necessary or beneficial for legal compliance or to resolve disputes, operate our business or enforce our agreements. We may retain End User Information and Automated Information according to our internal data retention policy, including after the associated Merchant account is closed. We will retain End User Information in accordance with our Merchant contracts and applicable laws, including state privacy laws.
CHANGES TO THIS POLICY
We may modify this Privacy Policy at any time. We will let you know of any changes by posting the revised policy on the Site and updating the effective date.
LOCATION OF YOUR INFORMATION
Your information may be transferred to and maintained on servers outside your country. We may process and store information in the United States and other countries, and your use of our Services constitutes your consent to and understanding of this transfer and processing.
CONTACT US
To contact Friendbuy about anything in our Privacy Policy, including any questions or suggestions, please send an email to legal@friendbuy.com.
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