Privacy Policy

Last Modified: August 24, 2020

We at Behavioral Signal Technologies, Inc. (hereinafter – BST) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by BST as a controller, including the information collected on our Website https://behavioralsignals.com or through other channels as described below. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal information. It also describes your choices regarding use, as well as your rights of access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Website.

This Privacy Policy does not apply to the data BST processes on behalf of our customers (Customer Data) in our capacity as a processor. Your use of the BST Products and Services (the Service) as a customer of BST is covered under the BST Data Processing Agreement.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification or via our BST portal.

While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by mail to BST, Inc., 4470 W Sunset Blvd, Suite 94260, Los Angeles, CA 90027, US Attn: Privacy or contact us via email social@behavioralsignals.com

1. What Information We Collect About You

When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or register for the Service, we request that you provide Personal Information about yourself and we collect Navigational Information.
Personal Information
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.
Personal Information includes Navigational Information where such information can directly or indirectly identify an individual.
Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit, and pages viewed. Please see the “Use of Navigation Information” section below.
Sensitive Information
BST does not receive any sensitive personal information from you, like credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition, or information, or other employment, financial or health information.
Log Files
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, the Internet service provider (ISP), and the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, and access times and referring website addresses. This information is used by BST to provide general statistics regarding the use of the Website. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
Do not track Disclosure
We support Do Not Track (“DNT“). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.
Information About Children
The Website is not intended for or targeted at children under 18, and we do not knowingly or intentionally collect personal information about children under 18. If you believe that we have collected personal information about a child under 18, please contact us via email social@behavioralsignals.com, so that we may delete the information.

2. How We Use Information We Collect

Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. Customers who use our Services are obligated through our agreements with them to comply with this Privacy Policy.
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
– improve your browsing experience by personalizing the Websites and to improve the Service;
– send information or BST content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
– promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences;
– provide other companies with statistical information about our users — but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
– send information to you regarding changes to our Terms of Service, Privacy Policy, or other legal agreements;
– investigate and help prevent security issues and abuse; and
– meet legal requirements.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor located in the European Economic Area (“EEA”), BST is the data controller of your personal information. BST can be contacted via email social@behavioralsignals.com.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and to provide you with a better experience when you interact with BST. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about BST. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through browser-, operating system- or device-level settings.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. All Personal Information is protected using appropriate physical, technical, and organizational measures. For more on Security at BST, please contact us via email social@behavioralsignals.com.
Social Media Features
Our Websites include Social Media Features, such as the Facebook Like button, and Widgets, such as the Share Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
External Websites
Our Websites provide links to other websites of third parties. We do not control and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Website if you request so, as described in “To Unsubscribe From Our Communications” below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you request so, as described in the “How to Access & Control Your Personal Data” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your BST account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
The data our customers collect by using the Service is retained according to the relevant Terms of Service and Data Processing Agreements with our customers.

3. How we Share Information we Collect

Service Providers
We employ other third-party service providers to provide services on our behalf to visitors to our Website and our customers and users of the Service and may need to share your information with them to provide information, products, or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
BST Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by BST on the Website and the Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. How We Transfer Data We Collect Internationally

International Transfers
Your information, including Personal Information, may be transferred to — and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
International transfers to third parties
Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the EEA, the United Kingdom or Switzerland, we make use of the European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

5. Cookies and Similar Technologies

Cookies
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information in order to improve our services for you. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.
Flash Cookies and Other Third Party Tracking Technologies
The Adobe Flash Player (and similar applications) use technology to remember settings, preferences, and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as “Flash cookies.” BST does not use Flash cookies.
Third-Party Tracking Technologies
The use of cookies by any tracking utility company is not covered by our Privacy Policy.

6. How to Access & Control Your Personal Data

Reviewing, Correcting, and Removing Your Personal Information
– You have the following data protection rights:
– You can request access, correction, updates, or deletion of your personal information.
– You can object to the processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information.
– If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
– You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland, and certain non-European countries (including the US and Canada) are available here.)

To exercise any of these rights, please contact us by mail to BST, Inc., 4470 W Sunset Blvd, Suite 94260, Los Angeles, CA 90027, US, Attn: Privacy or contact us via email social@behavioralsignals.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
If you would like to access or control your data with one of our customers or users of the Service, please contact the customer or user directly. BST acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by contacting us by mail to BST, Inc., 4470 W Sunset Blvd, Suite 94260, Los Angeles, CA 90027, US Attn: Privacy or contact us via email social@behavioralsignals.com. Customers cannot opt-out of receiving transactional emails related to their account with us or the Service.
To Unsubscribe From Our Customers’ Communications
Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.

7. California Privacy Rights

This section applies only to California consumers. It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.

For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”).
How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:
– Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.
– Internet or network information, such as browsing and search history. We collect this information directly from your device.
– Geolocation data, such as IP address. We collect this information from your device.
– Inferences.
– Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Service.
The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we “disclose” this information for a business purpose are described in Section 3 of this Privacy Policy.
Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected used and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
BST does not sell Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).
How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent has written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information.
Please use the contact details below, if you would like to:
– Access this policy in an alternative format;
– Exercise your rights;
– Learn more about your rights or our privacy practices; or
– Designate an authorized agent to make a request on your behalf.

8. Data Protection Designated Person contacts

If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us by mail to BST, Inc., 4470 W Sunset Blvd, Suite 94260, Los Angeles, CA 90027, US Attn: Privacy or contact us via email social@behavioralsignals.com

9. Changes to This Privacy Policy

This Privacy Policy is effective as of December 23, 2017, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website.