Private Policy
Last Updated: April 26, 2020
At Little Bill, Inc. ("Little Bill", "we", "us", or "our" which include our group and affiliated companies), our most important asset is our relationship with our user community. We are committed to maintaining the confidentiality, integrity and security of information about our users and their organizations. This privacy policy ("Privacy Policy") describes how we collect, use, disclose, share and secure the personal and company information you provide when you use our expense management software, invoicing, bill processing, retail information, coupons management, loyalty management, applications and other related financial tools and services, through our mobile application (the "Application") or visit the Little Bill Website https://www.LittleBill.io/ (the "Site" and, together with any related software, tools and services provided in connection with the Application or the Site, the "Little Bill Service"). It also describes your choices regarding the use, access and correction of your Personal Data (as defined in section 3 of this Privacy Policy) and how to contact us if you have any further queries or complaints about our management of your personal information.
In this Privacy Policy, "you" and "your" refers to individual users of the Little Bill Service, as well as to Members and Corporate Members. "Members," "Corporate Members," and other capitalized terms not defined in this privacy policy are defined in the Little Bill Terms of Service currently located at https://www.littlebill.io/terms .
If you do not agree to the terms of this Privacy Policy you must immediately leave the Website and discontinue your use our products and services.
Little Bill Data Policy will be aligned with the standards of the General Data Protection Regulation (EU) 2016/679.
Information available at https://gdpr.eu/
1. MEMBER CONSENT
By submitting or making available Personal Data (as defined below) through our Site, the Little Bill Software or the Little Bill Service, you confirm that you have read and accepted the terms of this Privacy Policy and you expressly consent to the collection, storage, use and disclosure of your Personal Data in accordance with this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must not use our products and services or our Site.
2. A NOTE ABOUT CHILDREN
We do not intentionally gather Personal Data about individuals who are under the age of 18. If you become aware that we inadvertently hold or have access to Personal Data about anyone under 18, please let us know so we can delete it.
3. TYPES OF PERSONAL DATA WE COLLECT
So that we can provide you with our products and services, we may need to collect Personal Data (as that term is defined below) about you or others. If you do not provide us with the Personal Data we request, we may not be able to supply you with some or all of our products and services.
Little Bill collects Personal Data from you when you visit our Site, when you send us information or communications in connection with your use of the Little Bill Service, and/or when you download and use the Little Bill Software. "Personal Data" means data that allows someone to identify or contact you or your employees, consultants, and independent contractors, including, for example, name, address, geographic location of your computer or mobile device, telephone number, receipts description (including but not limited to total, store names, items bought, quantities, amounts...), credit card number, email address, social security number (of controlling officers (requesting users) and beneficial owners of your Account, which shall be required for KYC checks) and bank account information. If you are accessing the Little Bill Service from Australia, "Personal Data" also includes any information or opinion, whether true or not and whether recorded in material form or not, by which you may be reasonably identifiable. Little Bill will not use your Personal Data except as agreed to in this Privacy Policy and in the Terms of Service.
Personal Data You Provide To Us
We collect Personal Data from you, such as first and last name, email and mailing addresses, telephone number, professional title, company name, date of birth, zip code, and password, when you register for the Little Bill Service or sign up for our Premium Program. In addition, we (or our third-party credit card or payment processor on our behalf) will collect Personal Data including your credit card number or account information when you upgrade to a paid account. We will also collect receipts description (including but not limited to total, store names, items bought, quantities, amounts...). We also retain information on your behalf, such as the Personal Data described above and any correspondence. If you provide us feedback or contact us via email, we will collect your name and email address, IP address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us, such as a resume. If we conduct a survey in which you participate, we may collect additional profile information. We may also collect Personal Data at other instances in the Site or Application user experience where we state that Personal Data is being collected.
If you choose to use our referral service to tell a friend about our site, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Little Bill stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. If your friend is a resident of the European Union or Australia, please make sure they are happy to be contacted by us.
When you provide us with Personal Data about your contacts we will only use this information for the specific reason for which it is provided.
If you believe that one of your contacts has provided us with your Personal Data and you would like to request that it be removed from our database, please contact us at help@LittleBill. io.
Your friend may also contact us at help@ littlebill.io to request that we remove this information from our database.
Personal Data Collected by Third Parties
We will collect your Personal Data from you unless it is unreasonable or impracticable to do so. However, we may collect and receive Personal Data about you from companies that distribute the Little Bill Service by way of a co-branded or private-labeled website, companies that offer their products and/or services via the Little Bill Service, or companies that provide services (such as payment processing services) in connection with the Little Bill Service, including without limitation Issuers and Card Networks (as such terms are defined in the Terms of Service) (collectively, "Partner Companies"). Our Partner Companies may supply us with Personal Data, such as your name and email and mailing address information or your login credentials for such Partner Company's website or service, in order to help us establish the account or fulfill orders. We may also collect your Personal Data from public sources. We may add this information to the information we have already collected from you via our Site or Application in order to perform and improve the Little Bill Service. If you provide us Personal Data about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
This Privacy Policy applies only to the use and disclosure of Personal Data that we collect while you use the Little Bill Service. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave the Little Bill Service and go to another site. During this process, a third party may collect Personal Data from you. We have no control over, do not review, do not endorse, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on a link to a third party. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
Personal Data Collected via Technology
The Little Bill Service (which may be hosted by a third-party service provider) collects Personal Data from you, such as browser type, your approximate geographic location of your mobile device or computer (from your Internet Protocol (IP) address), operating system and version, Internet Protocol (IP) address, domain name, information about your application, operating environment and hardware profiles and/or a date/time stamp for your visit. We may also use Identifiers (as defined below) and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and/or access to the Little Bill Service and your activity on the Site and the Application. Like most internet services, we automatically gather this Personal Data and store it in log files each time you visit the Site, use the Application or access your account on our network.
When you interact with the Site or the Application, we try to make that experience simple and useful. We and our partners use industry standard identifiers, such as cookies or other similar technologies. We also use mobile device identifiers which perform a similar role, like the IDFA used by Apple devices and the UDID used by Android devices. Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application and which store and sometimes track information about your use of the Site or Application (as the case may be). A number of cookies we use last only for the duration of your web or Application session and expire when you close your browser or exit the Application. Other cookies are used to remember you when you return to the Site or Application and will last for longer. We refer to cookies and the mobile device equivalents as "Identifiers".
We use Identifiers to:
Usage information may be linked to your account in order to assist Little Bill to provide services to your account, for example analysing data for the purposes of trouble shooting. Little Bill will not sell or disclose usage data to any third party unless such usage data has been aggregated or de-identified and is no longer capable of identifying you as an individual.
Our Site includes Social Media Features, such as the Facebook "Like" button and Widgets, such as the "Share this" button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our Site, and may set an Identifier to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
Some of the Identifiers used by the Site are set or accessed (as appropriate) by us, and some by third parties who are delivering services on our behalf.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site or Application, you may not be able to take full advantage of the Little Bill Service.
In addition to cookies, web beacons may be set by us or third parties in respect of your use of the Site or Application. Web beacons are small image files within the content of the Site or Application for analytics purposes so we or third parties can understand which parts of the Site or Application are visited and which functions of the Site or Application are used and whether particular content is of interest.
When you download and use the Little Bill Service, we automatically collect information about the type of device you use and operating system version.
We may send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We collect your location based information for the purpose of mileage tracking and providing location specific features. We may share your geo-location data with third parties for the sole purpose of providing these services. If you do not wish to allow us to share your information in this manner please opt out by contacting us at help@LittleBill.io.
You may opt-out of location based services at any time by editing the setting at the device level or by emailing us at help@littlebill.io.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the Application, the events that occur within the Application, aggregated usage, performance data, and where the Application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile Application.
3rd Party Tracking Technologies
We and our affiliates (including but not limited to Google Analytics and New Relic) may use Identifiers and similar tracking technologies to monitor performance and usage on the site for internal analytics and performance monitoring. These Identifiers and similar tracking technologies are used to help the Site collect and store information regarding your visit, such as session state and authentication tokens. Users can control the use of cookies at the individual browser level but if you choose to disable cookies, it may limit your use of certain features or functions provided through the Little Bill Service. To manage Flash cookies, please click here .
The use of Identifiers by our affiliates is not covered by our privacy policy. We do not have access or control over these cookies.
Behavioral Advertising
We may partner with a third party to either display advertising on our Site or Application or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to opt -out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads
4. USE OF YOUR PERSONAL DATA
Little Bill and our Partner Companies may use your Personal Data in the following ways:
From time to time, we may also use your Personal Data to send important notices to you, such as communications about purchases you have made, or changes to our terms and conditions or other policies. This information is important to your interactions with us and you acknowledge that you may not opt out of receiving these communications.
If you provide feedback on the Little Bill Service, we may use such feedback for any purpose, provided we will not associate such feedback with your Personal Data. Little Bill will collect and store any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.
Any information, including Personal Data, which you elect to make publicly available on the Little Bill Service will be available to other Members or the public. If you remove information that you have made public on the Little Bill Service, copies may remain viewable in cached and archived pages of the Little Bill Service, or if other Members have copied or saved that information.
In some cases we collect information provided by our Corporate Members, and in such cases, we have no direct relationship with the individuals whose Personal Data we process. If you believe your Personal Data has been collected by us in such circumstances, and would no longer like to be contacted as an employee or customer of one of our Corporate Members, please contact that Corporate Member directly in order to request your removal.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your Personal Data with Partner Companies to provide technical support or to provide specific services, such as hosting of your applications, maintenance services, database management or payment processing for purchases, reimbursements or other payments (including but not limited to PayPal and the Bancorp). Partner Companies will have access to your Personal Data only to perform these services on our behalf and are obligated not to disclose or use it for any other purpose. They may be located, or their data processing activities may take place, in the United States of America or elsewhere outside the European Economic Area (EEA). The US and other non-EEA countries do not have similar data protection laws to the European Union, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe.
Any subsidiaries, joint ventures, or other companies under common control with us (collectively, "Related Entities"), may share some or all of your Personal Data, in which case we will require our Related Entities to honor this Privacy Policy and your Personal Data will only be used for the purposes set out in this Privacy Policy.
Little Bill may sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Personal Data may be among the items sold or otherwise transferred in these types of transactions, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.
In certain situations, Little Bill may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Regardless of any choices you make regarding your Personal Data (if applicable), Little Bill may disclose Personal Data if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants or lawful requests from government authorities served on Little Bill; or (b) protect or defend the rights, reputation or property of Little Bill or users of the Little Bill Service.
Except as otherwise stated in this policy and our Terms of Service, we do not sell, trade, share, or rent the Personal Data collected from the Little Bill Service to third parties. You expressly consent to the sharing of your Personal Data as described in this policy.
We may aggregate, de-identify and/or anonymize any information collected through the Little Bill Service so that such information is no longer linked to your Personal Data. We may use and share such aggregated and anonymized information solely for marketing purposes or distribution to third party research firms.
Service Provider, Sub-Processors/Onward Transfer
Little Bill may transfer Personal Data to companies that help us provide the Little Bill Service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
6. CHOICE/OPT-OUT
Little Bill offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also access and manage your preferences from your account.
7. MARKETING
Little Bill would like to send you information about products and services of ours that we think you might like, as well as those of our partners.
List of our partners companies can be found here: https://www.littlebill.io/partners
If you agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Little Bill form contacting you for marketing purposes or giving your data to other members of Little Bill SAS.
If you no longer wish to be contacted for marketing purposes, please send an email to help@littlebill.io.
You may understand that marketing can be part of Little Bill Services through the smartphone Application. In that case, you may stop receiving all marketing by cancelling your Little Bill account.
8. HOW DO WE STORE DATA?
Little Bill securely store your data at IBM Cloud Mongo DB, IBM Cloud Cloud Object Storage, Amazon S3.
Little Bill will keep all your data for 24 months after your last log-in. Once this time period has expired, we will delete all your data automatically.
9. WHAT ARE YOUR DATA PROTECTION RIGHTS?
Little Bill would like to make sure you are fully aware of all of your data protection rights.
Every user is entitled to the following:
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@littlebill.io
10. PERSONAL DATA CHANGES
If you believe that the Personal Data we hold about you may not be complete, accurate and up-to-date, you may change aspects of any of your Personal Data in your account by editing your profile within the registration portion of the Site or by sending an email to us at help@littlebill.io.You may request deletion of your account information by us, but please note that we may be permitted or required (by law or otherwise) to keep this information and not delete or change it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements
Access to Data Controlled by our Corporate Members
Upon request we will provide you with information about whether we hold any of your Personal Data. We also acknowledge that you have the right to access your Personal Data subject to any exceptions which may apply in the jurisdiction in which you reside. Where a Member accesses the Application or the Little Bill Service because their employer is a Corporate Member, Little Bill has no direct relationship with that Member. In that situation, a Member who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Little Bill's Corporate Member (the data controller). If the Corporate Member requests Little Bill to remove the data, subject to our rights to retain the Personal Data as set out in this Privacy Policy, we will respond to their request within 30 business days.
Data Retention
Little Bill will retain data we process on behalf of our Corporate Members for as long as needed to provide services to our Corporate Member. Little Bill will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We ensure that Personal Data we dispose of is de-identified or destroyed in a secure fashion.
Blog / Forum
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Data from our blog or community forum, contact us at help@littlebill.io. In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so and why.
11. CALIFORNIA PRIVACY RIGHTS
Members who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to help@littlebill.io.
12. SECURITY OF YOUR APPLICATION AND PERSONAL DATA
Little Bill is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. Despite these measures, you should know that Little Bill cannot fully eliminate security risks associated with Personal Data. If you have any questions about the security of your Personal Data, you can contact us at help@ littlebill.io.
13. CONTACT INFORMATION
If you have any comments, questions or complaints about this Privacy Policy or if you feel that we have breached our obligations in the handling, use or disclosure of your personal information, feel free to email comments or questions to us at help@littlebill.io or 34 Avenue des Belges, 69230, Saint Genis Laval, France.
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. However, if you require information which is specific to your circumstances then it may not be possible for you to deal with us anonymously or by pseudonym. You acknowledge and agree that when contacting Little Bill, whether by email, chat, or otherwise, you will not include any personally identifiable information in your communications, and that if such information is included in your communications with Little Bill, Little Bill will have no legal obligation or liability with regard to such information.
14. CHANGES TO THIS PRIVACY POLICY
If Little Bill makes changes to this Privacy Policy, these changes will be posted on the Site and Application in a timely manner. Little Bill reserves the right to modify this Privacy Policy at any time, so please review it frequently. You acknowledge that the updated policy will apply to the collection, storage, use or disclosure of Personal Data from the date of publication and it is your responsibility to check the Site and Application regularly for updates. You can determine when this Privacy Policy was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to this Privacy Policy will become effective upon our posting of the revised Privacy Policy on the Site and Application. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Use of the Little Bill Service following such changes constitutes your acceptance of the revised Privacy Policy then in effect. We encourage you to periodically review this page for the latest information on our privacy practices.
15. AUSTRALIAN PRIVACY RIGHTS
If you are in Australia, our collection, storage, use and disclosure of your Personal Data will be subject to this Privacy Policy and the Privacy Act 1988 (Cth) (Privacy Act). Any part of this Privacy Policy that is illegal, unenforceable or inconsistent with the Privacy Act may be severed from this Privacy Policy and the remaining terms or parts of the term of this Privacy Policy will continue in force.
In addition, the following information applies to you.
Refer-a-Friend
If you choose to use our referral service to tell a friend about Little Bill, you must seek your friend's consent to our use of your friend's name and email address to contact them about the Little Bill Service. By providing us with your friend's name and email address, you warrant that your friend consents to such contact.
Anonymity and Pseudonymity
If you are making a general enquiry only, you may deal with us on an anonymous basis or through the use of a pseudonym. However, we will not be able to provide you with any specific information about your account if you fail to identify yourself to us.
Data Transfer Disclosure
Personal Data provided to us by Members or Corporate Members located in Australia may be disclosed to service providers located outside Australia, including in the US, including providers of cloud or other types of networked or electronic storage.
Although these third parties are subject to privacy and confidentiality obligations imposed by contract or the regulatory frameworks of the jurisdiction in which those third parties are located, you acknowledge that:
ï they may not always comply with those obligations, or those obligations may differ from the obligations imposed by privacy and data protection legislation in your jurisdiction; and
ï the third party may be subject to foreign laws which might compel further disclosures of personal information (e.g. to government authorities).
Secondary Purpose
You acknowledge that we may use or disclose your Personal Data for a reason other than the reasons set forth in Section 4 (secondary purpose) where the secondary purpose is connected to or associated with a purpose for collection set out in this Privacy Policy, or directly connected to or associated with a purpose for collection if the information is 'sensitive information' as that term is defined under the Privacy Act.
16. OVERSEAS DISCLOSURE
Little Bill is based France and data are saved in the United States, and, unless we expressly agree otherwise, we may host, transfer, and process data, including Personal Information, in the United States and in other countries through Little Bill and third parties that we use to operate and manage the Service. These countries may have data protection laws that are different from those of your country of residence. When you access or use the Service, or otherwise provide information to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of information in and to the United States and other countries which may have different privacy laws from your or their country of residence. Little Bill takes appropriate measures to ensure such transfers are in compliance with applicable laws
17. DATA RETENTION
Other than in aggregated, anonymized form as permitted under the Little Bill Terms of Service, and except as required by applicable law, we will delete or otherwise destroy your Personal Data as soon as practicably possible following your termination or cancellation of your use of the Little Bill Service.
18. LOSS OF PERSONAL DATA
If it comes for any reasons that your Personal Data have been deleted due to technical issues, run out of business or any other circumstances, Little Bill cannot be held liable for the loss of your Personal Data. Little Bill will always have the integrity to keep your Personal Data secure.
19. QUERIES, CONCERNS, AND COMPLAINTS
If you have any queries, concerns or complaints about the manner in which we have collected, stored, used or disclosed your personal information, please contact the Data Protection Officer at privacy@expensify.com. We will treat your complaint confidentially and, after investigating your complaint, discuss the ways in which we can remedy the situation. We will ensure that we respond to your complaint within a reasonable time (and in any event within the time required by applicable law).
If your inquiries or complaints regarding our Privacy Policy or use of data that have not been resolved to your satisfaction within 30 days via the means set forth herein, please contact:
- The Office of Australian Information Commissioner at https://www.oaic.gov.au/ (if you are an Australia individual)
- The International Trade Administration by following the instructions at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint (if you are a European Union individual); or
- The Federal Trade Commission at https://www.ftccomplaintassistant.gov/#crnt&panel1-1 (if you are a United States individual).