Privacy Policy

Last Updated on 04/12/2024


This notice describes the privacy policy (“Privacy Policy” or “Policy”) of an App, titled ‘Shufflebuy’ and (hereinafter referred to as the “App” or “Website”) which is operated by Shufflebuy, LLC, having its principal office at 390 North Orange Avenue, Suite 2300, Orlando, FL - 32801 (hereinafter referred to the “Company” or “Shufflebuy” or “us” or “our” or “we”). In this Policy, you shall be referred as “you” or “your” or “user” or “users”.


This Privacy Policy explains what information of yours will be collected by us when you download, register on or access the App or Site or when you post a listing or text others, how the information will be used, and how you can control the collection, correction, and/or deletion of the information. We will not knowingly use or share your information with anyone, except as described in this Privacy Policy. The use of information collected through our App shall be limited to the purposes described under this Privacy Policy and our Terms & Conditions.

By registering on or using our App or providing your personal information to us or by using other features and functionalities of the App, you are accepting and consenting to the practices described in this policy. Please note that this includes consenting to the processing of any personal information that you provide, as described below.



1. What information about the users do we collect?

2. Lawful basis for processing personal information

3. How do we use this information?

4. Deleting your information

5. Sharing of information

6. Storage and Security of Information

7. Links to third party Apps

8. California Resident Rights

9. How do we respond to legal requests?

10. Children Privacy

11. How do I withdraw my consent?

12. Governing law and Dispute Resolution

13. Do you have any questions or concerns about this privacy policy?

14. Welcoming of suggestions

What information about the users do we collect?

Information that you provide us: We collect the information you provide when you use our App/Site and our services, including without limitation, when you sign up for an account, add information to your profile, browse our App, post a listing, interact with a listing, text other members, post images or videos, purchase our paid services, use our services, engage with us through any social media platform, share your feedback, submit a complaint, communicate or interact with us in any manner. This can include Personally Identifiable Information (PII) and non-PII information. The examples include your full name, profile details, location, email, contact number, messages that you share with other members, listings and other content that you upload or share, your queries etc. We also collect information about how you use our services, such as the content you engage with or the frequency and duration of your activities.

Information that we collect when you use the App: We also collect information while you access, browse, view or otherwise use the App. In other words, when you access the App or Website, we are aware of your usage of the App or Website, and gather, collect and record the information relating to such usage, including geo-location information, device data and connection information, browser information and web-log information.

Information that we collect from third party sources: You can engage with us through social media platforms or mobile applications. When you engage with us through social media platforms, such as Facebook or Instagram, you allow us to have access to certain information from your social media profile based upon your privacy preference settings on such platform.

Payment Information: Shufflebuy does not save your payment information. We us Stripe for payments, please refer to their privacy policy for more info.

Camera Access: We collect your camera access to enable you to capture photos and videos to upload and share on our platform.

Good Judgment: We suggest that you exercise good judgment and caution while providing your personal information.

What is the lawful basis for which we use your personal information?

You hereby acknowledge that all processing of your personal information will be justified by a "lawful ground" for processing. In the majority of cases, processing will be justified on the basis that:

Consent: You have given your consent for processing personal data for one or more specific purposes.

Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.

Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.

Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

How do we use this information?

We use all of the information we have to help us provide, support and improve our services. We use the information collected from you for one or more of the following purposes:-

To create and update your account and profile;

To post your listings;

To enable you to message other members;

To post your comments;

To assess queries, requirements, and process requests for various services;

To enhance your user experience, including as a way to recognize you and welcome you to the App and Website;

To improve our App, Site and services;

To be able to deliver our services, personalize content, and make suggestions for you by using this information to understand how you use and interact with our services and the people or things you’re connected to and interested in on and off our services.

We use your information to send you marketing communications, newsletter, communicate with you about our services and let you know about our policies and terms. We also use your information to respond to you when you contact us.

We use the information we have to help verify accounts and activity, and to promote safety and security on of our services, such as by investigating suspicious activity or violations of our terms or policies.

We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues that you report to us. And we use your information to make improvements to our services.

We use information to help improve the safety and reliability of our services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Shufflebuy, our community, or the public.

To respond to summons, court orders, directions or other judicial processes.

To provide information to law enforcement agencies or in connection with an investigation on matters related to public safety.

Deleting your information

Your information, account and the content that you share on our platform is yours. You can at any time delete the same. However, you acknowledge that we will not be able to remove the content that other community members have saved and copied, and we may also retain some of the information so deleted for a reasonable period of time in order to comply with legal requests. You can request us to delete your information by writing to us at

Sharing of Information

Your profile, listing and the content that you share or upload on the App is public, and is viewable to the other users and viewers of the App and Site.

When you message other users, you text is viewable by these other users.

We share your personal as well as non-personal information with our third-party hosting service provider namely, Wix.

We keep your information safe and do not share your information with any other third party. However, if we merge with or are acquired by another company or we sell our App or Site or business unit, or if all or a substantial portion of our assets are acquired by another company, in those cases, your information will likely be one of the assets that would be transferred.

We may also share your information in response to legal request. Please refer to Section 10.

Storage and Security of Information

Storage: Your data is stored through Wix data storage, databases and servers. The user data is run through global google cloud compute platform: 1600 Amphitheatre Parkway, Mountain View, California. We also store some of the information collected by us on our servers and do not share it with any third party, except for the limited purposes as mentioned in the Section 5. The servers and databases in which information may be stored may be located outside the country from which you accessed this App and in a country where the data protection and other laws may differ (and be less stringent) from your country of residence. You hereby consent to any such cross-border transfer of your personal information.

Retention: Personal information that we collect, access or process will be retained only so long as necessary for the fulfillment of the purposes for which it was collected, as necessary for our legitimate business purposes, or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made de-identified or anonymous.

Steps taken by us to protect your data: We regularly take the following steps to protect the integrity of your information:

We protect the security of your information while it is being transmitted by using secure connection;

We use computer safeguards such as firewalls to keep this data safe;

We only authorize access to employees and trusted partners who need it to carry out their responsibilities;

We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security; and

We will ask for proof of identity before we share your personal data with you.

Security: We as well as Wix seemingly employs reasonable security practices to ensure that the information is safe and secure with it. However, no information on the internet is 100% safe, and you accept and acknowledge such risk. Also, we will disclose the information so collected for limited purposes as mentioned in this Privacy Policy.

Links to other Apps

The App may contain links to third-party websites and online services that are not owned or controlled by us. We have no control over, and assume no responsibility for such websites and online services. Be aware when you leave the App/Site; we suggest you read the terms and privacy policy of each third-party website, and online service that you visit.

California Resident Rights

This section of the Policy applies to you, if you are a California resident, as per California Consumer Policy Act, 2018 (simply called “CCPA”) and California Online Privacy Protection Act (simply called “COPPA”). This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: Yes.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

We use the personal information that we collect or receive for the business purposes as described above. We may disclose the above listed categories of personal information to third parties for business purposes as described above. As previously mentioned in this Policy, we do not “sell” (as such term is defined in the CCPA) personal information.

You are entitled to the following specific rights under the CCPA in relation to personal information related to you:

You have a right to request that we will disclose certain information to you about our collection and use of personal information related to you over the past 12 months, including: (i) The categories of personal information that we collect about you; (ii)The categories of sources from which the personal information is collected; (iii) The purposes for collecting, using, or selling that personal information. (iv) The categories of personal information that we disclosed for a business purpose or sold, and the categories of third parties to whom we disclosed or sold that particular category of personal information. (v) The specific pieces of personal information that we have collected about you.

You have a right to request that we delete personal information related to you that we collected from you under certain circumstances and exceptions.

You also have a right not to be discriminated against for exercising your rights under the CCPA.

You also have a right to submit your request via an authorized agent. If you use an authorized agent to submit a request to access or delete your personal information on your behalf, the authorized agent must: (1) be a person or business entity registered with the California Secretary of State to conduct business in California; (2) provide proof of such registration; and (3) provide documentation or other proof indicating that they are authorized to act on your behalf. We may also require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.

To make such requests, please contact us at

We will verify your request using the information associated with your account, including email address. Government identification may also be required.

A request for access can be made by you only twice within a 12-months period. Any disclosures that we provide will only cover the 12-months period preceding receipt of your request. We do not charge a fee to process or respond to your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

How do we respond to legal requests?

We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from law enforcement agencies, courts, tribunals and government authorities. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; or to prevent death or imminent bodily harm. We also may retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other violations of our terms.

Children Privacy

Protecting children's privacy is important to us, and therefore our App is not intended for children. We do not direct the App to, nor do we knowingly collect any personal information from, such children. If you are not of majority as per the law of jurisdiction that applies to you, you are not authorized to use our App without your parents/legal guardian’s prior express consent. If we learn that a child has provided personally identifiable information to us, we will use reasonable efforts to remove such information from its database. Please contact us at if you believe we knowingly or unknowingly collected information described in this Section.

How can I withdraw my consent? (OPT-OUT)

If you signup, you will automatically start receiving promotional emails and direct mail from us. If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at

Governing law and Dispute Resolution

Unless provided by the relevant statute, rules or directives applicable to the jurisdiction in which you reside, in case of any disputes, issues, claims or controversies arising out of or in relation to your use of the App, or our services, the governing law and dispute resolution mechanism as provided in the Terms & Conditions shall apply to this Privacy Policy as well.

Do you have questions or concerns about this Privacy Policy?

In the event you have any grievance regarding anything related to this Privacy Policy, Terms & Conditions, Disclaimer, Community Guidelines, or with any content or service of App, in that case you may freely write your concerns through your registered email to Grievance Officer/Designated Representative to below:

Name: Joseph Petro


Welcoming of suggestions

We welcome your comments regarding this Privacy Policy. Please write to us at

Last updated on 3/20/2022.