Reviewed in June 2020
Bring Your Customer Back Foundation (hereinafter “BYCB Foundation”) aims to facilitate customer retention through enhancing the credibility of businesses across industries most affected by the coronavirus pandemic. This is achieved by conducting an external audit of facilities to ensure physical distancing and compliance with recommendations of the World Health Organization, the Center for Disease Control and Prevention, and the United States Department of Labor. In addition, BYCB Foundation grants access to best practices, tutorials, and technology solutions aimed at streamlining the implementation of actions to secure public health.
In order to access and use our products, service catalog, and content, you may be asked to register and provide us with personal information. Personal Information means information or data that can be used to contact, deliver content, conduct audit, or identify you.
This policy also explains your rights with respect to data we collect about you. Your information is controlled by BYCB Foundation, a non-stock corporation established and existing under the laws of the State of Delaware with primary place of business at 1607 Ponce de Leon Avenue, GM-06, San Juan, PR, 00909. If you have any questions or concerns about how your information is handled, please direct an inquiry to us at firstname.lastname@example.org.
If you do not agree with this policy, please do not access or use our services or interact with any other aspect of our business.
1. Data we gathered from our website users
1.1. We collect the following categories of data:
- Cookies and similar technologies (e.g., web beacons, pixels, ad tags, and device identifiers)
- Usage data and user behavior collected by cookies
What is a cookie?
HTTP cookie is a small piece of data that we send to your browser when you visit our website. After your computer accepts it or “takes the cookie”, it is stored on your computer as an identification tag. Cookies are generally employed to measure website usage (e.g., a number of visitors and the duration of a visit) and efficiency (e.g., topics of interest to our visitors). Cookied can also be used to personalize user experience on our website. If necessary, users can turn off cookies via browser settings.
1.2. How we process the data gathered
1.2.1. Analytics partners
The services outlined below help us to monitor and analyze both web traffic and user behavior.
2. Data we gather from our web forms
2.1. We collect the following categories of data:
When you fill out any of the forms located at our website, you share the following information with us:
- Phone number
- Company name
- Your position
- Number of your business locations
- Any other information you provided to us from your request
2.2. How we process the data gathered
The information about the request is transferred to our CRM. Later, it may be used to contact you with something relevant to your initial request, provide further information related to the topic you requested, and deliver quality service.
By sharing personal information with us, you are giving consent for us to rightfully use your data for the following business purposes:
- Send any updates regarding services you have shown interest in or provide further information related to the topic you requested
- Contact and communicate with you regarding your initial request
- To get your consent to further contact you regarding any other services you might be interested in
- Maintenance and support activities of our CRM system and related activities
All the information gathered via contact forms is processed by the following services:
- Gmail services that deliver notifications about the filled out contact forms to our employees (Privacy Shield)
3. Purposes and legal basis for data processing
If you fill out a contact form to become a BYCB Foundation member, we process your data in order to enter into a contract and to comply with our contractual obligations (to render services), or answer to your request. This way, we may use your personal information to provide services to you, as well as process transactions related to the services you inquired from us. For example, we may use your name or an e-mail address to send an invoice or to establish communication throughout the whole service delivery life cycle. We may also use your personal information you shared with us to connect you with other our team members. In case you use multiple services offered by BYCB Foundation, we may analyze your personal information and your online behavior on our resources to deliver an integrated offer. For example, to simplify your search across a variety of our services to find a particular one or to suggest relevant product information as you navigate across our website.
With an aim to enhance our productivity and improve our collaboration—under our legitimate interest—we may use your personal data (e.g., an e-mail, name, job title, or activity taken on our resources) to provide information we believe may be of interest to you. Additionally, we may store the history of our communication for the legitimate purposes of maintaining customer relations and/or service delivery, as well as we may maintain and support the system, in which we store collected data.
If you fill out contact forms for any other purpose, including the download of white papers or to request an assistance, we process data with a legitimate interest to prevent spam and restrict direct marketing of third-party companies. Our interactions are aimed at driving engagement and maximizing value you get through our services. These interactions may include information about our new commercial offers, white papers, articles, and events we believe may be relevant to you.
3.1. Data retention period
We set a retention period for your data collected from contact forms on our websites to six years. This data may be further used to contact you if we want to send you anything relevant to your initial request (e.g., updated information on the white papers you downloaded from our website).
3.2. Data recipients
We do not transfer data to third parties, apart from the cases described in the General data processing section and this section.
3.3. Data security and protection
These measures include without limitation: data encryption, password-protected access to personal information, limited access to sensitive data, encrypted transfer of sensitive data (HTTPS, IPSec, TLS, PPTP, and SSH) firewalls and VPN, intrusion detection, and antivirus on all the production servers.
The data collected by third party providers is protected by them and is subject to their terms and privacy policies.
The data collected on our websites by BYCB Foundation, as well as the data, which you entrust us under NDAs and contracts, is protected by us. We follow the technical requirements of GDPR and ensure security standards are met without exception.
Though we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data is absolutely safe from intrusion by others during transmission through the Internet, or while stored on our systems, or otherwise in our care.
- Your rights
Below, you will find a list of the rights you are subject to. Please note that some of the enlisted rights may be limited for the requests, which expose personal information of another individual who is subject to the very same rights for privacy. In such a case, we will not be able to satisfy your request for data deletion if it contains information we are eligible to keep by law.
4.1. The right to be informed and to access information
You have legal rights to access your personal data, as well as request if we use this data for any purpose. Complying with our general policy, we will provide you with a free copy of your personal information in use within a month after we receive your request. We will send your information in use via a password-protected PDF file. For excessive or repeated requests, we are eligible to charge a fee. In case of numerous or complex requests, we are eligible to prolong our response time by as much as two additional months. Under such circumstances, you will be informed about the reasons for these extensions. In case we refuse to address a particular request, we will explain why it happens and provide you with a list of further actions you are eligible to proceed.
4.2. The right for rectification
In case you believe we store any of your personal data, which is incorrect or incomplete, you may request us to correct or supplement it. You also have the right to introduce changes to your information by logging into your account with us.
4.3. The right to erase, or “the right to be forgotten”
Under this principle, you may request us to delete or remove your personal data if there is no solid reason for your data continued processing. If you would like us to remove you from our database, please e-mail at email@example.com. The right to be forgotten may be brought into force under the following reasons:
- Data, which no longer has a relation to its original purpose for collection.
- You withdraw consent with respect to the original reason data was processed under, and there is no other reason for us to continue to store and process your personal data.
- You have objections to processing your personal data, and there are no overriding legitimate reasons for us to continue to process it.
- Your personal data has been unlawfully processed.
- Your personal data has to be deleted to comply with a legal obligation in a European Union or a Member State law to which BYCB Foundation is subject.
- Your personal data has been collected in relation to the offer of information society services.
4.4.The right to restrict processing
Under this right, you may request us to limit processing your personal data. In this regard, we are eligible to store information that is sufficient to identify which data you want to be blocked, but cannot process it further. The right to restrict processing applies to the following cases:
- Where you contest the accuracy of your personal data, we will restrict data processing until we have verified the accuracy of your personal data.
- Where you have objected to data processing under legitimate interests, we will consider whether our legitimate interests override yours.
- When data processing is unlawful, and you oppose data deletion and request restriction instead.
- If we no longer need your personal data, but you require this data to establish, exercise, or defend a legal claim.
- If we have disclosed your personal data in question to third parties, we will inform them about the restriction on data processing, unless it is impossible or involves disproportionate effort to do so. We will inform you if we decide to lift a restriction on data processing.
4.5. The right to object
You are eligible to object to processing your personal data based on legitimate interests (including profiling) and direct marketing (including profiling). The objection must be on “grounds relating to his or her particular situation.” We will inform you of your right to object in the first communication you receive from us. We will stop processing your personal data for direct marketing purposes, as soon as we receive an objection.
4.6. The right to data portability
You are eligible to obtain your personal data, which is processed by BYCB Foundation, to use it for your own purposes. It means you have the right to receive your personal data—that you have shared with us—in a structured machine readable format, so you can further transfer the data to a different data controller. This right applies in the following circumstances:
- Where you have provided the data to BYCB Foundation.
- Where data processing is carried out, because you have given BYCB Foundation your consent to do so.
- Where data processing is carried out to develop a contract between you and BYCB Foundation.
- Where data processing is carried out automatically. (No membership data is processed using automated means, so this right does not apply).
4.7. Withdrawal of consent
If we process your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any point in time. Please note, that if you exercise this right, you may have to then provide your consent on a case-by-case basis for the use or disclosure of certain personal data, if such use or disclosure is necessary to enable you to utilize some or all of our services.
4.8. The right to file a complaint
You have the right to file a complaint about manipulations applied to your data by BYCB Foundation with the supervisory authority of your country or a European Union Member State.
- Children’s privacy
BYCB Foundation is not directed to children. We do not knowingly collect personally identifiable information from children. If you, as a parent or guardian, become aware that your child has provided us with personal information without your consent, please contact us. If we become aware that a user is under the age of 13 and has provided us with personal information without verifiable parental consent, we will delete such information from our files.