Your privacy is important to us
You are the most important part of #be.
Your ability to understand and control the collection of personal data is our priority.
We value your privacy and your right to decide.
- What is User Data:
- The personal information you provide upon signing up.
- Browsing activities when the panel is not hidden and not in private browsing mode.
- Posts you willingly make to social media via #be.
- Metadata related to the above data, such as computer IP addresses, operating system, and browser type.
- Any other information capable of tracing back to an identifiable individual.
- User Data Usage: What We Do
- We store all information on secured servers. We use industry standard security software and procedures to restrict access, prevent hacking, and keep your data safe.
- We use secure protocol https for all communications, including for personal data.
- When the panel is open, we follow your browsing activities in order to understand your interests and give you credits best suited to those interests.
- In order to improve your experience, the system considers only the browsing activity related to websites and interests you choose to add.
- We provide a personal portal page where you and only you can view data related to your browsing activities.
- We give you the power to follow and unfollow brands and other third-party organisations, which may include further options to share more personal information during the process of interaction with them. You have the power at any time to unfollow and terminate the exchange, and only organisations you are “following” can contact you.
- User Data Usage: What We Don’t Do
- We never give any user data to any third party interacting with our service. We might however provide your data to other trusted third parties, in accordance with what indicated in the foregoing.
- When the panel is hidden or in private browsing mode, there is no communication of data from the user to our servers: we do not know what you are doing.
- For Which Purposes Does #be Use Your Data, And Upon Which Legal Basis?
We mainly use the data we collect to provide you with #be services.
This includes the following:
- Notifying you about your account and your interests. We will inform you if there has been any activity relating to your account and your interests. Our basis for doing so is the performance of the agreement we have with you;
- Aggregated Trends. We may use the data in an aggregated, entirely anonymous manner to highlight trends and patterns in the way that users engage in digital activities. We have a legitimate business interest in analysing this information, e.g. to enhance the experience on our website;
- Exercising our rights and fulfilling our obligations under the law. We use your personal data to perform our legal obligations. For example, to fulfill our tax obligations, or in case we receive a data disclosure request from a competent authority. We also use your personal data to prevent and investigate fraud or other illegal or undesired activities. We can also use your personal data to protect or exercise our rights or the rights of third parties. We have a legitimate business interest in doing so;
- Profiling. We may use your data to profile your preferences and to provide you with suggestions. Again, we have a legitimate business interest in offering you a service that matches your interests as closely as possible.
- Anonymising: We may use your data to create an anonymous profile based on your interests. This profile, strictly anonymous, could be shared with third parties, while we do not communicate your personal data to them (see next section). In this case, we will remain responsible for your data.
- Do We Disclose Your Data to Third Parties ?
Third Parties interacting with #be services
We define “third parties” as other users, brands, institutions, NGOs, and other private or public companies in general interacting with our system, and offering you relevant content.
No third party can contact you directly on #be.
Any third party that would like to contact you has to pass through #be.
#be acts as your personal filter and protects your privacy.
Third parties must clearly communicate a list of interests as reason to contact you.
#be will ask you to accept or decline the invitation of the third party according to the list of interests.
If you accept, the third party is able to initiate direct communication with you through #be.
If you accept, the third party is able to access data related to your list of interests and the data related to the interaction with you.
You can remove the connection with the third party at any time.
By removing the connection, the third party can no longer access the data described in this section.
The third parties will never receive personal data.
#be is dedicated to the protection of your privacy.
Other Third Parties
#be recognises that your data is yours.
We will not disclose your data beyond what is necessary to provide you with #be services. Your personal data are only available to #be employees to the extent this is necessary to this purpose. There are certain situations where #be will share information with third parties that we trusts. They are our:
- #be group companies: For internal reports and security and to optimise our services, we share certain personal data with our group companies;
- Service providers: we share your personal data with our service providers to the extent this is relevant. For example, to investigate and prevent fraud, to optimise our services or to analyse data, to store your data securely;
- Competent Authorities: we share your personal data with authorities to the extent this is relevant. For example, we may be required to disclose certain data under a court order that we receive. Even if a court orders us to share a particular user’s data, it would be extremely hard to identify which profile belonged to a given user;
- With your consent. We may disclose your data in cases where you have given your express permission for us to do so (typically for any uses not covered by this policy);
- Do We Transfer Your Data to Third Countries?
#be will process your personal data from its headquarters in Switzerland. It might also transfer your data to third parties located outside the EU, for example to other #be group companies. Data transfers towards Switzerland are covered by the EU Commission adequacy decision of 26 July 2000. An adequacy decision is a decision taken by the EU Commission establishing that a third country provides a comparable level of protection of personal data to that in the European Union, through its domestic law or its international commitments. As to other data transfers, we will only provide your personal data to third parties that handle your personal data confidentially and provide appropriate protection in line with European standards, so that personal data are protected appropriately (e.g. by concluding EU Model Contracts for the international transfer, of personal data as approved by the EU Commission).
If you have questions about the international transfer of your personal data or the appropriate safeguards that #be has taken to protect your personal data, please send an email to email@example.com.
- How Long Do We Keep Your Data?
We will retain your personal data for the duration of our relationship for providing you the service and for the other purposes highlighted above, save when a shorter retention period is required by law, or the data is no longer necessary for the purposes for which it was obtained.
Once our relationship with you has come to an end, and you request to close or delete your account, we will delete your personal data after 3 months from the deletion request, unless we need such data to:
- fulfil our legal obligations, including legal retention periods;
- investigate or defend legal claims;
- dispose of your questions, requests or complaints; and
- keep our records for analysis and audit purposes.
In such a case, we will retain only the data necessary for the scope and we will cancel it or keep in an anonymous form when no longer necessary.
- Your Rights
You are entitled to the following rights:
(a) you can ask to access, or rectify your data. You can access or change your data by logging into your account and visiting the page with profile data. Or you can send an email to firstname.lastname@example.org;
(c) you can delete your account at any moment by sending an email to email@example.com. Please specify in the subject field “Delete account”. Your account will be deleted within 24 hours within the receipt of your request. Please note that deleting your account is irreversible, and any data related to your account will be permanently deleted following three months from the deletion of your account;
(d) you have the right to data portability, which allows you to receive the personal data provided to #be in a structured, commonly used and machine-readable format. When applicable, you may have the right to transmit such a data to another data controller;
(e) you have also the right to restriction of processing, which allows you to request, subject to certain conditions, a restriction of processing.
You are also granted with the right to object at any time to processing that is carried out on the basis of the legitimate interest of #be or of a third party. In this case we will terminate the processing of your personal data, unless another legal basis for processing exists.
Finally, if you believe your data is been processed unfairly, or against the law, you can lodge a complaint before the Data Protection Authority of your habitual place of residence.
- 9. Contacts of the Data Controller
Date of last revision: May 2018