Effective Date: March 31st 2020
If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) and our dedicated team that supports this office by contacting us at email@example.com.
How Do We Collect Information?
If you use our Services, we collect personal information about you. Some of the ways that Bipsync may collect personal information include:
Information You Provide
Account Information: If you create an Account, we’ll collect certain personal information such as your name, email address, username, and password.
Communications with Us: We may collect personal information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us, including via the Contact section of the Site.
Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Conferences, Trade Shows, and other Events: We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Bipsync and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Information Provided by Your Organization
If you are an Authorized User, we may receive information about you from your organization, such as your name and email address, to help with Account set-up or management of support requests.
Information Collected Using Cookies and other Web Technologies
Like many website owners, we, as well as third parties that provide content, advertising, or other functionality on the Services, use automated data collection tools such as Cookies and Web Beacons to collect certain information.
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services and to monitor how many visitors view our Services.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services.
We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Information Related to Use of the Services
Information Sent by Your Mobile Device
We may collect certain information that your mobile device sends when you use our Services, such as a device identifier, user settings, and the operating system of your device, as well as information about your use of our Services. Such information helps us to, and will be used in order to, improve, customize and enhance our Services.
In some cases we collect and store information about where you are located, such as by converting your IP address into a rough geolocation. We may use location information to improve and personalize our Services for you.
Information from Other Sources
We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
How Do We Use Information?
We may use personal information for a variety of business purposes, including to:
Fulfill our contracts and provide Services, such as:
- Managing your information and accounts;
- Responding to your questions, comments, and other requests;
- Providing access to certain areas, functionalities, and features of our Services;
- Communicating with you about your account, activities on our Services and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications and transactions;
- Answering your requests for customer or technical support; and
- Allowing you to register for events.
Analyze and improve our Services pursuant to our legitimate interest, such as:
- Measuring interest and engagement in our Services;
- Conducting research and development;
- Developing new products and Services and improving, upgrading, or enhancing our Services;
- Ensuring internal quality control;
- Verifying your identity and preventing fraud;
- Detecting and repairing bugs or other software issues;
- Detecting, preventing, and protecting against security incidents and malicious, deceptive, fraudulent or potentially prohibited or illegal activities and prosecuting those responsible for that activity;
- Enforcing our Terms; and
- To comply with our legal obligations, protect your vital interest, or as may be required for the public good.
Provide you additional content and Services, such as:
- Providing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
- Providing Services to you and our customers;
- Auditing relating to transactions or your use of the services; and
- Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
You may contact us at any time to opt out of the use of your personal information for marketing purposes, as described below.
Use De-identified and Aggregated Information. We may personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
- Operationally Necessary. This includes technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search, or similar functions;
- Performance Related. We may use technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
- Functionality Related. We may use technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
What Information Do We Share With Third Parties?
We may share any personal information that we have collected as described below:
If you are an Authorized User, under the terms of the Agreement between Bipsync and your organization, your organization and other personnel and Authorized Users from your organization are permitted to access the information in your Account, both during your use of the Services and/or when you or your organization ceases using the Services. In addition, at a minimum, the name associated with your Account may be displayed to others within your organization and in connection with your use of the Bipsync Services. Certain User roles assigned by your organization may allow personnel from your organization with specific User credentials access to Account information as required for purposes such as compliance or management of Users and User groups.
Our Services Providers
We may engage third-party service providers to work with us to administer and provide the Services. These third-party service providers have access to personal information for the purpose of performing services on our behalf. Such third parties include: customer relationship management software providers, Internet hosting and cloud service provider services, and customer support services and software.
We may provide personal information to business partners with which we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
We may share personal information with our affiliated companies.
Information Shared with Other Third Parties
We may share aggregated and de-identified information (such that information cannot be identified as the information of a particular User) with third parties for industry research and analysis, demographic profiling and other similar purposes, and for third-party programs to access the Services in a manner that extends the Bipsync user experience and helps us operate and improve the Services.
Information Disclosed in Connection with Business Transactions
Information that we collect from our Users, including personal information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your personal information, will be disclosed or transferred to a third-party acquirer in connection with the transaction, as permitted by law and/or contract.
Information Disclosed for Our Protection and the Protection of Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate: (i) to respond to claims, legal process (including subpoenas), law enforcement requests and national security requests; (ii) to protect your, our, or others’ rights and safety and the rights and safety of the public in general; (iii) to stop any activity that we consider illegal, unethical or legally actionable activity; (iv) enforce our policies or contracts; (v) collect amounts owed to us; or (vi) assist with an investigation or prosecution of suspected or actual illegal activity. In the event of such disclosure or transfer of personal information to public authorities, there is a chance that Bipsync will not be able to require such public authorities to implement and maintain reasonable security controls to protect the confidentiality, integrity and availability of personal information.
With respect to onward transfers to agents under Privacy Shield (as defined below), Privacy Shield requires that we remain liable should its agents process personal information in a manner inconsistent with the Privacy Shield Principles.
Where Do We Send Information?
As our Users operate globally, we need to send User personal information to different countries in order to provide the Services, and you might send your personal information to different countries in the course of using Bipsync Services. If you are an Authorized User, your organization may require us to store personal information in a specific region. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
When we send personal information outside of the European Economic Area (EEA), we use a variety of legal mechanisms to make sure that your personal information is sent with appropriate safeguards:
We may send personal information from the EEA, United Kingdom, and Switzerland to Bipsync Ltd. in the US. Bipsync complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the “Privacy Shield”) as adopted and set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use, transfer, and retention of personal information transferred from the European Union and the United Kingdom and Switzerland to the United States in reliance on Privacy Shield.
The U.S. Federal Trade Commission and the relevant EU data protection authorities have jurisdiction to investigate and enforce any issues relating to compliance with or certification to the Privacy Shield. Bipsync will cooperate and comply with the dispute resolution panel established by the relevant EU data protection authorities.
The Security of Your Information
We take reasonable measures to protect the information that we collect from or about you (including personal information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
Links to Other Sites
You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Your Privacy Rights
For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.
You can access the personal information associated with your Account via your Account. If you want Bipsync to delete your personal information and/or your Account, you can do so by contacting us at firstname.lastname@example.org. Please note that if you are an Authorized User and you make a request to delete your personal information and that data is necessary for the continuation of Services your organization has purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements. We’ll take steps to delete your personal information as soon as is practicable.
In accordance with applicable law, you may have the right to:
- request confirmation of whether we are processing your personal information;
- obtain access to or a copy of your personal information;
- receive an electronic copy of your personal information or ask us to send that information to another company;
- restrict our uses of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, depending on applicable law;
- seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and
- request erasure of personal information held about you, subject to certain exceptions prescribed by law.
If you would like to exercise any of these rights, please contact us at email@example.com. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you are a California resident, you have the right not to receive discriminatory treatment by Bipsync for the exercise of your rights conferred by the California Consumer Privacy Act.
Treatment of Authorized User Personal Information Following Termination
If you are an Authorized User who is utilizing the Bipsync Services under your organization’s Agreement with Bipsync, then following the termination of your or your organization’s access to or use of the Bipsync Services, Bipsync may, if required by the Agreement or your organization, but subject to the requirements of applicable law or any Governmental Authority, deliver to your organization any personal information we have in our possession.
Our Policy Toward Children
Our Services are not directed to children under 13 (or other age as required by local law) and we do not knowingly collect personal information from children. If we learn that we have collected personal information of a child in violation of applicable law, we will take steps to delete such information and terminate the child’s account as soon as possible.
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Bipsync does not share personal information with third parties for their own marketing purposes.
Privacy Shield Dispute Resolution
In compliance with the Privacy Shield Principles, Bipsync commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Bipsync at firstname.lastname@example.org.
Bipsync has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to any unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland. Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
As a Privacy Shield participant, Bipsync commits to binding arbitration at the request of an individual to address any complaint relating to our privacy notice or our information practices that has not been resolved by other recourse and enforcement mechanisms. For additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Bipsync’s compliance with the Privacy Shield.
Privacy Shield Compliance
US DPO:Cynthia Van
UK DPO:Charlotte White