PRIVACY POLICY EFFECTIVE DATE: 4/23/2023
1. INTRODUCTION
1.1. PURPOSE OF POLICY. SJM Northstate Enterprises, LLC (“us,” “we,” or “Company”) is
committed to respecting the privacy rights of its customers, visitors, and other users of the
Company mobile app, known as Accountability Buddy, and services (together, the “App”). We
created this Privacy Policy (this “Policy”) to give you information about our collection, use, and
disclosure of information about you, as well as your rights regarding that information. This
Policy is only applicable to the App and any offline location where we make this Policy available
to you, and not to any other websites or mobile apps that you may be able to access from the
App, each of which may have data collection and use practices and policies that differ materially
from this Policy.
1.2. NOTICE CONCERNING CHILDREN
PLEASE NOTE: We are a general audience mobile app, and do not direct any of our content
specifically at children under 13 years of age. We understand and are committed to respecting
the sensitive nature of children’s privacy online. If we learn or have reason to suspect that an
App user is under age 13, we will promptly delete any personal information in that user’s
account. Pursuant to our Terms of Use, which can be found by clicking here, individuals using
this App shall certify that they are at least age 18, and any user found to be under the age of 18
shall be subject to having their account and user information deleted.
2. INFORMATION COLLECTION PRACTICES
2.1. WHAT INFORMATION DOES THE COMPANY COLLECT?
(a) INFORMATION YOU PROVIDE. In operating the App, Company may include
registration, online surveys, and other forms that ask users to provide their names, e-mail
addresses, and other contact information, as well as the following categories of information: age,
sexual orientation, gender identification, nationality, race, or other identifying information.
Depending on your use of the App, we may also request financial data (such as your account or
credit card number for purchases) and demographic data (such as your zip code, age, and
income). If you communicate with us by e-mail, post messages to any of our chat groups,
bulletin boards, or forums, or otherwise complete forms, surveys, or contest entries, any
information provided in those communications will be collected from you.
(b) AUTOMATIC COLLECTION. When you visit the App, our servers automatically
recognize (1) visitors’ domain names; (2) IP addresses (the number assigned to mobile phone on
the Internet); (3) device information; and (4) location data. This “traffic data” may be used for
marketing purposes or for improving the services we offer, as explained in more detail below.
(c) TRACKING TECHNOLOGIES. We use “cookies” and other tracking technologies that
allow us to store a small piece of data on your device about your visit to the Site. Cookies help us
learn which areas of the App are useful and which areas need improvement. You can choose
whether to accept cookies by changing the settings on your account. However, if you choose to
disable this function, your experience at the App may be diminished and some features may not
work as they were intended.
3. USE AND SHARING OF INFORMATION
3.1. WHAT DOES COMPANY DO WITH COLLECTED INFORMATION?
(a) OPERATING OUR APP AND PERFORMING SERVICES. We use your personal
information to verify your identity, to check your qualifications, or to follow up with transactions
initiated on the App. We may also use your contact information to inform you of any changes to
the App, or to send you additional information about Company. We use financial information to
verify your qualifications for certain products or services and to process payments. We use
demographic data to customize and tailor your experience on the App, to provide identifying
information about you to other users you engage with in using the App (other “Buddies”), and
for in-house analytics and marketing research for Company.
(b) TRAFFIC DATA. We use traffic data to analyze our App traffic, but we do not examine
this information for individually identifying information. In addition, we may use IP addresses to
help diagnose problems with our server, to administer the App, or to display the content
according to your preferences. Traffic and transaction information may also be shared with
business partners and advertisers on an aggregate basis.
(c) USE OF COOKIES. We may use cookies and other tracking technologies to deliver
content specific to your interests, to save your password so you don’t have to re-enter it each
time you visit our App, or for other purposes.
(d) DISCLOSURE OF PERSONAL INFORMATION. We may disclose personal information
that you provide via the App to the following third parties:
• Other Buddies on the App, whether you have chosen to engage with them or not
• Our subsidiaries and affiliates;
• Joint venture or marketing partners; and
• Contractors, vendors, and service providers we use to support our business and the App.
These support partners have all agreed to uphold the same standards of security and
confidentiality that we provide to you under this Policy, and they have agreed to only use
your information to carry out their specific business obligations to Company.
We may also disclose personal information that you provide via the App in the event of a
merger, acquisition, or any form of sale of some or all of our assets, in which case personal
information we collect via the App will be among the assets transferred to the buyer. Further, we
may disclose your personal information to third parties to
• Comply with any court order or other legal obligation;
• Enforce or apply our Terms of Use and other agreements; and
• Protect the rights, property, or safety of our business, our clients, customers, employees,
or others. This includes exchanging information with other companies and organizations
for the purposes of fraud protection, information security, and other related matters.
4. USER CHOICES REGARDING COLLECTION, USE, AND DISTRIBUTION OF
INFORMATION.
4.1 ACCOUNT SETTINGS. We maintain a procedure to help you confirm that your Personal
Information remains correct and up-to-date. At any time, you may visit your personal profile on
the App by clicking the Profile button at the top of the screen. Through your personal profile you
may: (a) review and update your Personal Information that we have already collected; (b) choose
whether you wish us to send you information about our Company; and (c) choose whether you
wish for us to share your Personal Information with third parties.
4.2. LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card,
user name, or password is lost, stolen, or used without permission. In such an event, we will
remove that credit card number, user name, or password from your account and update our
records accordingly.
4.3 COMMUNICATIONS.
• If you do not wish to receive information and promotional material from us, you may
select the appropriate “opt-out” option each time we ask you for information.
• You can opt-out of e-mails from us by clicking on the unsubscribe link in each message,
or e-mailing us with UNSUBSCRIBE in the subject field of the e-mail.
5. FOR RESIDENTS OF CALIFORNIA
5.1 SHINE THE LIGHT.
Under California’s “Shine the Light” law, California residents who provide personal
information in obtaining products or services for personal, family, or household use are entitled
to request and obtain from us, once each calendar year, information about the customer
information we shared, if any, with other businesses for their own direct marketing uses. If
applicable, this information would include the categories of customer information and the names
and addresses of those businesses with which we shared customer information for the
immediately preceding calendar year.
To obtain this information, please send an e-mail message to
admin@accountabilitybuddyapp.com with “Request for California Privacy Information” in the
subject line and in the body of your message. We will provide in response the requested
information to you at your e-mail address.
Please be aware that not all information sharing is covered by the “Shine the Light”
requirements and only required information will be included in our response.
5.2 CALIFORNIA CONSUMER PRIVACY ACT.
Company will not sell or share your personal information with any third party without first
providing you with the right to opt out or limit the use and disclosure of the information. Any
personal information collected will be strictly used by Company for analytics and for
identification purposes on your profile that you create. You have the right to know what
information has been collected, and upon request, pursuant to California law, Company will
provide you with the categories of personal information collected, specific pieces of personal
information collected, the categories of sources from which Company collected personal
information, the purposes for which Company uses the personal information, the categories of
third parties with whom Company shares the personal information, and the categories of
information that Company sells or discloses to third parties. Company must provide you this
information for the 12-month period preceding your request free of charge pursuant to the
California Consumer Privacy Act.
5.3 ERASER BUTTON
Under California’s “Eraser Button” law, California residents under age 18 who have registered
to use the App may request removal of content they have posted. To make a request, please send
us an e-mail message to admin@accountabilitybuddyapp.com with “Eraser Button” in the
subject line. Pursuant to the Terms of Use, which can be found by clicking here, individuals
using this App shall certify that they are at least age 18, and any user found to be under the age
of 18 shall be subject to having their account and user information deleted.
The California Consumer Privacy Act (“CCPA”) provides additional rights to residents of
California regarding our information collection and use practices.
5.3.1 CATEGORIES OF PERSONAL INFORMATION COLLECTED
We identify below the categories of personal information that we have collected about our
users in the last 12 months, using the categories provided in the CCPA.
• Identifiers
• Customer Records Information
• Characteristics of protected classifications under California or federal law
• Commercial Information
• Biometric Information
• Internet or Other Electronic Network Activity Information
• Geolocation Data
• Audio, Visual, Electronic, Thermal, Olfactory, or Similar Information
• Professional or Employment-related Information
• Educational Information
• Inferences
For more detail on the information we collect, including the sources we receive information
from, please refer to our Information Collection Practices above. We collect and use these
categories of personal information for the business purposes described in the Information
Collection Practices section above.
5.3.2 CATEGORIES OF PERSONAL INFORMATION SOLD. Company does not sell
personal information as defined under the CCPA.
5.3.3 RIGHTS OF CALIFORNIA RESIDENTS
A. Right to Know
You have the right to know certain details about our data practices in the past 12 months. In
particular, you may request the following from us:
• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or
• sold;
• The categories of third parties to whom the personal information was disclosed for a
• business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information;
• and
• The specific pieces of personal information we have collected about you.
To exercise the Right to Know, please send us an e-mail message to
admin@accountabilitybuddyapp.com with “Right to Know” in the subject line. In the request,
please specify which right you are seeking to exercise and the scope of the request. We will
confirm receipt of your request within 10 days. We may require specific information from you to
help us verify your identity and process your request. If we are unable to verify your identity, we
may deny your requests to know.
B. Right to Delete
You have the right to request that we delete the personal information we have collected from
you in the last 12 months. To exercise the Right to Delete, please submit a request, please send
us an e-mail message to admin@accountabilitybuddyapp.com with “Right to Delete” in the
subject line. We will confirm receipt of your request within 10 days. We may require specific
information from you to help us verify your identity and process your request. If we are unable to
verify your identity, we may deny your request to delete. If we deny your request, we will
explain the reason why in our response.
C. Right to Non-discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your
rights.
D. Authorized Agent
You can designate an authorized agent to submit requests on your behalf. However, we will
require written proof of the agent’s permission to do so and verify your identity directly.
6. SECURITY
The App has security measures in place to prevent the loss, misuse, and alteration of the
information that we obtain from you, but we make no assurances about our ability to prevent any
such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.
7. PUBLIC APP AREAS AND ACCESS TO OTHER WEBSITES OR MOBILE APPS
7.1. PUBLIC FORUMS
The App includes interactive forums such as direct messaging, chat rooms, and live video
chats. Please remember that any information that is disclosed in these areas becomes public
information and you should exercise caution when deciding to disclose your personal
information.
7.2. OTHER WEBSITES OR MOBILE APPS
The App may contain links to other websites or mobile apps. If you choose to visit other
websites or mobile apps, we are not responsible for the privacy practices or content of those
other websites or mobile apps, and it is your responsibility to review the privacy policies at those
websites to confirm that you understand and agree with their policies.
8. CONTACT INFORMATION AND POLICY UPDATES
8.1. CONTACTING US
If you have any questions about this Policy, our practices related to this App, or if you would
like to have us remove your information from our database, please feel contact us at the
following email address:
admin@accountabilitybuddyapp.com
8.2. UPDATES AND CHANGES
We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by
posting such change, update, or modification on the App and without any other notice to you.
Any such change, update, or modification will be effective immediately upon posting on the
App. It is your responsibility to review this Policy from time to time to ensure that you continue
to agree with all of its terms. By continuing to use the App, you are acknowledging that you
agree to the terms of this Policy and any additions, changes, updates, or modifications that have
been made to it.
8.3. ACKNOWLEDGEMENT.
BY USING THE SERVICE OR ACCESSING THE APP, YOU ACKNOWLEDGE THAT
YOU HAVE READ THESE PRIVACY POLICIES AND AGREE TO BE BOUND BY THEM.