Privacy Policy

Summary

This summary is for convenience. The full policy below controls.

• Who this covers: Customers, BLUPals and BLUPal+ delivery partners (“Delivery Partners”), and visitors to our website and apps.
• What we collect: Account details, order and delivery information, precise location (for Delivery Partners, only while online and during an active delivery), payment and payout information, in-app messages, delivery photos and PINs, device and usage data.
• How we use it: To run the BLUSVN marketplace, match orders with Delivery Partners, process payments and payouts, keep the service safe, provide support, and send marketing consistent with your preferences.
• Who we share it with: Other users as needed to complete a delivery (for example, a Delivery Partner sees your delivery address), service providers, advertising and analytics partners, and authorities when the law requires.
• Selling and targeted advertising: We do not sell your personal information for money. We do use advertising cookies and SDKs that some state laws treat as a “sale,” “sharing,” or “targeted advertising.” You can opt out here.
• How long we keep it: Generally up to three years after your order or account activity, or longer where the law requires.
• Your choices: Access, correct, delete, or download your data; opt out of marketing and targeted advertising; control location permissions in your device settings.
• Contact: privacy@blusvn.com, Privacy Policy, or the mailing address in Section 13.

1. Who We Are and What This Policy Covers

This Privacy Policy describes how BLUSVN LLC, operating under the brand name BLUSVN (“BLUSVN,” “we,” “us,” or “our”), collects, uses, shares, and protects personal information. BLUSVN LLC operates the Site and apps described below and is a wholly owned subsidiary of its parent company, BLU Seven Limited. References to “BLUSVN” in this policy mean BLUSVN LLC unless otherwise stated.

It applies to:

• the BLUSVN Bottled Water Delivery customer app (iOS and Android);
• the BLUSVN Gig app used by Delivery Partners (iOS and Android);
• our website at blusvn.com (the “Site”);
• our customer support channels, SMS and email communications, and marketing and events;
• collectively, the “Services.”

This policy covers three groups of people:

• Customers – people who order bottled water delivery through BLUSVN.
• Delivery Partners – independent contractors who shop for, transport, and deliver orders using the BLUSVN Gig app. BLUPals complete BLU doorstep deliveries. BLUPal+ Delivery Partners complete ULTRA indoor deliveries and are subject to additional screening described in this policy.
• Visitors – anyone who browses the Site or interacts with us without an account.

This policy does not apply to the practices of third parties we do not control, including the retailers from which products are purchased (for example, Costco, Sam’s Club, Walmart, and Kroger), app stores, or payment networks. Their privacy policies govern their handling of your information.

2. Information We Collect

We collect information in three ways: information you give us, information collected automatically when you use the Services, and information from other sources.

2.1 Information You Provide

All users

• Account and contact details: name, email address, phone number, password, and profile photo (optional).
• Communications: messages you send through in-app chat, support requests, survey responses, reviews, and ratings.
• Marketing preferences: your choices about promotional email and SMS.

Customers

• Delivery information: delivery address, unit or gate codes, delivery instructions, and, for ULTRA indoor deliveries, the delivery PIN used to confirm handoff.
• Order information: items ordered, retailer selected, order history, tips, and promotional codes used.
• Payment information: payment card details are collected directly by our third-party payment processor. BLUSVN receives a payment token, card type, last four digits, and billing ZIP code, but does not receive or store full card numbers.
• Business account information: if you order for an office or business, the business name, address, and contact person.

Delivery Partners

• Identity and eligibility information: name, date of birth, mailing address, and government-issued identification used to verify your identity. Social Security or taxpayer identification numbers are not required to begin delivering; we collect tax identification information only when required for tax reporting on your earnings.
• Delivery method and vehicle information: whether you deliver by car, bike, scooter, or on foot. For vehicle deliveries, we collect your vehicle’s year, type, and color. This information is obtained through a third-party vehicle-data service based on information you provide during sign-up.
• Background screening information (BLUPal+ only): because BLUPal+ Delivery Partners enter Customers’ homes, offices, and other indoor spaces, we require a background check before you can complete ULTRA deliveries. The check is performed by a third-party consumer reporting agency, which collects the information needed to run it (such as your name, date of birth, address history, and identification numbers) and provides the results to us. Background checks are consumer reports under the Fair Credit Reporting Act and are obtained only with your separate written authorization, which we provide at the time you apply for BLUPal+ status. BLUPals who complete only BLU doorstep deliveries are not subject to background checks.
• Payout information: bank account or debit card details used to pay your earnings, collected directly by our third-party payout provider, and tax information (for example, Form W-9 details) needed for tax reporting.
• Delivery documentation: proof-of-delivery photos you take for BLU doorstep deliveries, delivery PINs you enter for ULTRA deliveries, purchase receipts, and delivery notes.
• Earnings and performance information: deliveries completed, acceptance and completion rates, ratings, tips, and earnings and withdrawal history.

2.2 Information Collected Automatically

Precise location information

• Customers: with your permission, we collect your device’s precise location to confirm you are in a serviceable area, suggest delivery addresses, and show your Delivery Partner’s progress. You can order without granting location access by entering an address manually.
• Delivery Partners: with your permission, we collect your device’s precise location only while you are online in the BLUSVN Gig app and during an active delivery. Collection continues in the background during an active delivery so that navigation, Customer tracking, and delivery verification work even when the app is not on screen. We do not collect your location when you are offline or when no delivery is active. We use this information to offer you nearby orders, provide navigation, share your progress with the Customer, verify deliveries, detect fraud, and resolve disputes.

You are asked to allow or deny location access when you first install the BLUSVN Gig app, and you can change that choice at any time through your device settings when no delivery is active. Location access is required to accept and complete deliveries; if you disable it, you will not be able to go online or receive order offers.

• Device and app information: device model, operating system and version, unique device identifiers, mobile advertising identifiers (IDFA/GAID), app version, language, time zone, mobile carrier, and crash and performance logs.
• Usage information: pages and screens viewed, features used, search terms, order and delivery timestamps, referring URLs, and interactions with our emails and notifications.
• Log information: IP address, browser type, access times, and the pages you visited before and after the Site.
• Cookies and similar technologies: described in Section 6.

2.3 Information From Other Sources

• Other users: a Customer’s rating or feedback about a Delivery Partner, or a Delivery Partner’s delivery notes about a Customer’s order.
• Service providers: payment and payout confirmations, fraud-risk signals, background-check results (BLUPal+ only), address verification, and analytics.
• Third-party sign-in: if you sign in with Apple or Google, we receive the name and email address associated with that account (or, if you use Apple’s Hide My Email feature, a relay address).
• Publicly available sources and marketing partners, in accordance with applicable law.

We do not receive personal information about Customers from retailers.

3. How We Use Information

We use personal information for the following purposes:

To provide the Services

• Create and manage your account and verify your identity.
• Match Customer orders with available Delivery Partners.
• Process orders, payments, tips, refunds, and Delivery Partner payouts.
• Provide navigation, real-time delivery tracking, and delivery confirmation.
• Enable communication between Customers, Delivery Partners, and BLUSVN support, including in-app chat.
• Provide customer and Delivery Partner support.

To maintain safety, security, and integrity

• Verify Delivery Partner eligibility and, for BLUPal+, conduct background checks.
• Detect, investigate, and prevent fraud, abuse, account sharing, and other harmful or illegal activity.
• Investigate delivery disputes, safety incidents, and complaints.
• Enforce our Terms of Service and other policies.

To improve and develop the Services

• Understand how people use the Services, test features, and fix bugs.
• Conduct research and analytics, including on delivery times and service areas.
• Improve our order-matching, routing, and fraud-detection systems.

To communicate with you

• Send transactional messages about your account, orders, deliveries, payouts, and policy changes by push notification, SMS, email, or in-app message.
• Send marketing and promotional communications where permitted by law and consistent with your preferences (Section 7).

For advertising and personalization

• Personalize content, recommendations, and offers within the Services.
• Measure the effectiveness of our advertising and show you BLUSVN ads on other websites and apps (see Section 4.4).

For legal and business purposes

• Comply with legal obligations, including tax reporting for Delivery Partners.
• Respond to lawful requests from public authorities.
• Establish, exercise, or defend legal claims.
• Evaluate or complete a merger, acquisition, financing, or sale of assets.

We may aggregate or de-identify personal information so it can no longer be linked to you, and use or share that information for any purpose. We commit to maintaining de-identified information in de-identified form and not attempting to re-identify it, except to test our de-identification methods.

4. How We Share Information

We do not sell personal information for money. We share personal information in the following circumstances.

4.1 With Other Users

Completing a delivery requires sharing some information between Customers and Delivery Partners:

• Delivery Partners receive the Customer’s first name and last initial, delivery address, delivery instructions, gate or unit codes, the items ordered, the Customer’s order-related chat messages, and, for ULTRA deliveries, confirmation that the PIN entered matches. Delivery Partners never receive the Customer’s phone number, email address, or payment information. All communication between Customers and Delivery Partners takes place through in-app chat, which is available only while a delivery is in progress.
• Customers receive the Delivery Partner’s first name, profile photo, delivery method (including vehicle year, type, and color for vehicle deliveries), real-time location during the delivery, and chat messages.

Delivery Partners are required by our Terms to use Customer information only to complete the delivery and to delete it afterward. BLU doorstep deliveries are verified by a proof-of-delivery photo of the items at the drop-off location. ULTRA deliveries are verified by the Customer’s PIN only; Delivery Partners do not take photos on ULTRA deliveries, including inside the Customer’s home or business.

4.2 With Service Providers

We share information with companies that perform services for us, under contracts that restrict their use of the information to providing those services. Categories include:

• Payment processing and Delivery Partner payouts
• Cloud hosting and data storage
• Mapping, navigation, and geocoding
• SMS, email, and push-notification delivery
• Customer support and chat tools
• Identity verification, vehicle-data lookup, and, for BLUPal+, background screening
• Analytics and crash reporting
• Fraud prevention
• Marketing and advertising platforms (see Section 4.4)

4.3 With Retailers

BLUSVN sources products from third-party retailers (for example, Costco, Sam’s Club, Walmart, and Kroger). Retailers are independent businesses, not BLUSVN partners or affiliates. We do not share Customer personal information with retailers.

Delivery Partners purchase items in-store using their own payment method (such as a personal card, gift card, or cash) and, where applicable, their own store membership. As a result, the retailer records that purchase under the Delivery Partner’s name, membership, or payment method, and the retailer’s own privacy policy governs any information it collects at checkout.

4.4 For Advertising and Analytics

We allow advertising and analytics partners to collect device identifiers, IP address, and usage information through cookies, pixels, and software development kits (SDKs) on our Site and apps. These partners use the information to measure our advertising campaigns and to show you BLUSVN ads on other websites and apps. Under some state privacy laws, this is considered a “sale” or “sharing” of personal information, or “targeted advertising.” You can opt out as described in Sections 6 and 8. We do not share precise location, delivery addresses, payment information, chat content, or delivery photos with advertising partners.

4.5 With Affiliates

We may share information with our parent company, BLU Seven Limited, and other corporate affiliates for the purposes described in this policy. Our affiliates are bound by this policy when handling your personal information.

4.6 For Legal Reasons and to Protect Rights

We may disclose information when we believe in good faith that doing so is necessary to:

• Comply with a law, regulation, subpoena, court order, or other legal process, or a request from a government authority.
• Enforce our Terms of Service and investigate potential violations.
• Detect, prevent, or address fraud, security, or safety issues.
• Protect the rights, property, or safety of BLUSVN, our users, or the public, including sharing with law enforcement or emergency services in urgent situations.
• Respond to insurance claims or legal disputes arising from a delivery, including sharing delivery and location records with insurers or the other party’s representatives.

4.7 In Business Transfers

If BLUSVN is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, your information may be transferred as part of that transaction. We will notify you of any resulting change in ownership or use of your personal information.

4.8 With Your Consent

We share information for other purposes when you direct us to or give consent.

5. How Long We Keep Information

We keep personal information for as long as needed to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements.

As a general rule, we retain order, delivery, location, chat, delivery-photo, and support records for up to three years after the related order or account activity, after which they are deleted or de-identified. Specific exceptions:

• Account information is kept for the life of your account and up to three years after closure.
• Financial, tax, and payout records for Delivery Partners are kept for the period required by tax and financial record-keeping laws, which may exceed three years.
• Background-check records (BLUPal+) are kept for the period required by applicable consumer-reporting and employment-screening laws.
• Records subject to a legal hold, open dispute, or safety investigation are kept until the matter is resolved.
• Marketing data is kept until you unsubscribe or your account has been inactive for three years.
• Information in backups may persist for a limited time until those backups are overwritten.

6. Cookies, Pixels, and Similar Technologies

We and our partners use cookies, pixels, SDKs, and similar technologies on the Site and in our apps to:

• Operate the Services (strictly necessary): keep you signed in, remember your cart and preferences, and protect against fraud.
• Measure performance (analytics): understand how the Services are used and fix problems.
• Personalize and advertise: show relevant content and measure marketing campaigns (see Section 4.4).

Your controls

• Opt-out link: opt out here of advertising cookies and SDKs.
• Browser settings: most browsers let you block or delete cookies. If you block strictly necessary cookies, parts of the Site may not work.
• Mobile settings: you can limit ad tracking or reset your advertising identifier in your iOS or Android settings. On iOS, we request permission through App Tracking Transparency before tracking you across other companies’ apps and websites.
• Global Privacy Control: we honor Global Privacy Control (GPC) browser signals as a valid opt-out of sale/sharing and targeted advertising for the browser sending the signal.
• Do Not Track: because there is no common industry standard for “Do Not Track” signals, we do not currently respond to them. We do respond to GPC signals as described above.
• Industry opt-outs: you can opt out of interest-based advertising from participating companies at optout.aboutads.info and optout.networkadvertising.org.

7. Communications and Marketing Choices

• Email marketing: unsubscribe using the link in any promotional email or in your account settings. We will still send transactional emails about your account and orders.
• SMS: by providing your phone number and opting in, you consent to receive transactional text messages (order and delivery updates) and, if you separately opt in, promotional text messages. Message and data rates may apply. Reply STOP to opt out and HELP for help. Opting out of promotional texts does not stop transactional texts needed to complete your orders.
• Push notifications: manage in your device settings. Delivery Partners who disable notifications may miss order offers.

8. Your Privacy Rights and Choices

8.1 Rights Available to All Users

Regardless of where you live, you can:

• Access and update most account information in the app or on the Site.
• Delete your account from the Settings tab of your account, in the app or on the Site, by following the on-screen prompts, or by contacting us. We may retain certain information as described in Section 5.
• Control location permissions through your device settings.
• Opt out of marketing as described in Section 7 and of advertising cookies and SDKs as described in Section 6.

8.2 Rights Under U.S. State Privacy Laws

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, or another state with a comprehensive privacy law you may have the following rights, subject to legal limits:

• Know / access: confirm whether we process your personal information and obtain a copy of it.
• Correct: ask us to fix inaccurate personal information.
• Delete: ask us to delete your personal information.
• Portability: receive your personal information in a portable, usable format.
• Opt out of the sale or sharing of personal information and of targeted advertising (see Section 4.4).
• Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Limit use of sensitive personal information: we collect precise geolocation and, for Delivery Partners, government identification information, which some laws treat as sensitive. We use it only for the purposes described in Sections 2 and 3, which are necessary to provide the Services you request, and we do not use it to infer characteristics about you or share it with advertising partners.
• Non-discrimination: we will not deny you services, charge different prices, or provide a different level of service because you exercised a privacy right, except where the difference is reasonably related to the value of your data.
• Appeal: if we decline your request, you may appeal by replying to our decision or contacting us at privacy@blusvn.com with “Privacy Appeal” in the subject line. We will respond in writing within the time required by your state’s law. If your appeal is denied, you may contact your state attorney general.

How to exercise these rights

• Email: privacy@blusvn.com
• Opt-out link: opt out here

We will verify your identity before responding, typically by matching information you provide to information in your account or by sending a confirmation to the email or phone number on file. You may use an authorized agent to make a request on your behalf; we may require proof of the agent’s authority and may still verify your identity directly. We will respond within 45 days, and may extend by an additional 45 days where permitted, in which case we will notify you.

8.3 Additional California Disclosures

Categories of personal information we collect and disclose. In the past 12 months we have collected the categories of personal information listed below, as described in Section 2, and disclosed each category for a business purpose to the service providers listed in Section 4.2.

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Sources and purposes are described in Sections 2 and 3.

Financial incentives. We do not currently offer financial incentives, such as referral or loyalty programs, in exchange for personal information.

Shine the Light. We do not disclose personal information to third parties for their own direct marketing purposes.

8.4 Nevada Residents

We do not sell personal information as defined under Nevada law. Nevada residents may submit a request to opt out of future sales at privacy@blusvn.com.

8.5 Users Outside the United States

The Services are offered only in the United States. If you access them from elsewhere, your information will be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction.

9. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption of data in transit using TLS and encryption of sensitive data at rest.
• Tokenization of payment cards through a PCI DSS–compliant payment processor; BLUSVN does not store full card numbers.
• Role-based access controls and logging for systems that hold personal information.
• Multi-factor authentication for internal systems, regular security testing, and vendor security reviews.

No system is completely secure. If we learn of a breach affecting your personal information, we will notify you and the relevant authorities as required by law. You are responsible for keeping your password confidential and for activity under your account; contact us immediately if you suspect unauthorized access.

10. Children

The Services are intended for adults. You must be at least 18 years old to create a Customer account or to become a Delivery Partner. We do not knowingly collect personal information from anyone under 18, and we do not knowingly sell or share the personal information of anyone under 16. If you believe a child has provided us with personal information, contact us at privacy@blusvn.com and we will take appropriate steps. If you are 13 to 17 years old, you may create an account and place orders (BLU or ULTRA) only with the permission of a parent or legal guardian who has reviewed and agreed to these Terms on your behalf. By permitting a minor to use the Services, the parent or guardian (a) agrees to these Terms, including Section 20 of the Terms of Service, on the minor’s behalf; (b) is responsible for all orders, charges, and activity under the minor’s account; and (c) confirms that an adult will be present as required for any ULTRA delivery under Section 8.2 of the Terms of Service. The Services are not directed to, and may not be used by, anyone under 13.

11. Third-Party Links and Services

The Services may link to third-party websites, apps, and services, including retailer websites, app stores, and payment providers. This policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to read their privacy policies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top. If the changes materially affect how we use or share personal information already collected, we will provide additional notice, such as by email to the address on your account, an in-app notice, or a prominent notice on the Site, before the changes take effect. Your continued use of the Services after the effective date of an updated policy means you accept the updated policy, where permitted by law.

13. Contact Us

Questions, concerns, or requests about this policy or your personal information:

BLUSVN LLC (d/b/a BLUSVN)
Attention: Privacy
8 The Green, Suite B
Dover, Delaware 19901

Email: privacy@blusvn.com