Last Updated: June 29, 2019
A. WHO WE ARE
The company that is responsible for your personal information is BPM Marketing Limited.
B. WHAT WE DO
We provide you with a range of services, including websites, browser extensions and search applications. All of these are designed to help you manage your browsing experience in a more customizable fashion. We provide further detail below about the BPM Apps Services.
The Search Applications provide features to facilitate Internet search services while using the BPM Apps Products. This search functionality may be implemented through browser settings and extensions. These set your browser homepage, start page, new tab page and/or default search setting(s), depending on which BPM Apps Product you are using and what options you select. We may provide you a way to decline or opt-out of the setting(s) change by unchecking the appropriate checkbox during the download and installation process for the relevant BPM Apps Product that provides access to the Search Applications.
The BPM Apps Products are browser extensions, applications and/or websites that we offer to you. The extensions can be downloaded onto your browser and offer a range of functions, including allowing you to manage and convert your documents, managing your calendar and providing you access to other functionality across the internet. Some of these BPM Apps Products, such as Chrome new tab products, may be available through the online store operated by the browser developer (e.g., the Chrome web store) and the user disclosures and options may vary based on the stores’ requirements.
For certain BPM Apps Products, the search features (and other features such as maps, local radio and document management), may be customized by you on your device. In addition, you may be able to disable or remove the default search features by removing or disabling the applicable extension you downloaded or changing your default search within your browser.
C. HOW WE COLLECT INFORMATION
We may collect information from you in a variety of different ways. This is information that may identify you, and anonymous information, such as the number of your page views, link clicks, and login times. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. We provide further detail on the type of info we collect, and how we collect it, below:
27. Information You Provide To Us. We may collect and store any information you provide when using the BPM Apps Services or that you provide in some other manner. This information may include information such as:
Your name, email address, telephone number, username and password.
We also collect and store information and other content you post to the BPM Apps Services, where such features are made available.
Further, in order to permit us to protect the quality of our products and services, we may to the extent permitted by applicable law access your account and records on a case by case basis to investigate complaints or other allegations.
28. Automatically Captured Information. We automatically collect information from your computer and/or device when you use the BPM Apps Services. This allows us to assess how you have used the BPM Apps Services, the device you have used them on and helps us to analyze how we can optimize the BPM Apps Services for you in the future. This information may include:
Information about your hardware and software such as your IP address, your browser type and language and other browser-related information and a time-stamp
Information about how you use the Search Applications such as the keyword query, search query text, search results clicked, pages viewed and search history.
The content of any of our undeleted cookies, including a unique identifier (see section D “Cookies” below), software installed upon and/or devices connected to your computer and/or device, and the referring website address.
29. Other Technologies. We may use standard Internet technology, such as web beacons, cookies and other similar technologies, to track your use of the BPM Apps Services. Web beacons are small pieces of data that are embedded in images on the pages of sites. The information we obtain in this manner enables us to customize the services we offer as part of the BPM Apps Services for our users.
30. Third-Parties And Behavioral Advertising. Third Parties: We may receive information from third-parties, including our authorized service providers, affiliates, advertising companies, and ad networks. These third parties may display ads via the BPM Apps Services. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with these advertisements. We may also use this information to better understand you and your interests. This will allow us to improve and customize the BPM Apps Services. Please note, some of these third-party advertising companies may be members of the Network Advertising Initiative, or the Digital Advertising Alliance, each of which offers a single location to opt out of ad targeting from member companies. Behavioral Advertising. We work with various companies (such as advertisers, ad networks and data management platforms) to tailor online ads that you see elsewhere on the internet, including through behavioral advertising designed to target users’ interests and deliver more relevant advertising. To provide such ads, these third parties may collect and/or we may disclose to these third parties a unique ID that may be associated with your device’s platform or a device/internet browser combination We or these third parties may collect the following information (and similar information):
Demographic data collected on BPM Apps Services (e.g., age, zip or postal code, gender) and geographic location derived from your IP address on your visits to the BPM Apps Services and non-affiliated websites and applications;
Data about your use of or visits to the BPM Apps Services and non-affiliated websites and applications;
Data on your interaction with the advertisement displayed on third party websites and applications; and
Interest and usage data (such as the pages you view and links you click on) acquired from other companies.
We may disclose any or all of the collected information to third parties.
32. Mobile: Mobile devices may offer settings that enable users to limit how mobile device ad tracking occurs, using unique device identifiers such as the Apple IDFA and Google Android Advertising ID. Some information about those settings may be reviewed for Apple here and for Android here.
33. Do not track signals. BPM Apps Services systems are not configured to respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Web sites or online services.
To process your information as described above, we rely on the following legal bases:
• Provide you with the BPM Apps Services: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to provide you with a more customized and personal experience.
• Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users behavior on our services to continuously improve our offerings, ensure it is bug free, and we process information for administrative, fraud detection and other legal purposes.
E. HOW WE USE THE INFORMATION WE COLLECT
We may use information that we collect about you to:
• Deliver the BPM Apps Services to you;
• Respond to your queries with the best possible answers and search results;
• Provide you with customer support;
• Perform research and analysis about your use of, or interest in, the BPM Apps Services, or products, services or content offered by others;
• Communicate with you by e-mail, postal mail, display media and/or mobile devices about products or services that may be of interest to you either from us, or other third parties;
• Enable us and our search and advertising partners to develop and display content and advertising tailored to your interests, when you use the BPM Apps Services, other websites and services, or mobile applications;
• Verify your eligibility and deliver prizes in connection with contests and sweepstakes;
• Enforce our terms and conditions;
• Manage our business and protect the quality of the BPM Apps Services, which includes maintenance of the BPM Apps Services systems;
• Investigate complaints, abuse or other allegations; and
• Perform functions as otherwise described to you at the time of collection.
F. WITH WHOM WE SHARE YOUR INFORMATION
We share your information with others as indicated below:
• Authorized service providers: We may share your information with our authorized service providers that perform certain services on our behalf. In certain instances, these service providers may collect information directly from you on our behalf. These services may include:
providing customer service, technical and operational support, and email services, including registration and account services;
marketing assistance, performing business and sales analysis, billing and payment processing (if we ever accept payments from our users),
supporting our BPM Apps Services functionality, and supporting contests, sweepstakes, surveys and other features offered through our BPM Apps Services, as well as when we have notified you, or you have requested, that we do so.
• These service providers may have access to information, which is needed to perform their functions and provide you with the BPM Apps Services.
• Advertisers and Ad Networks: As described above advertisers and ad networks, and other third parties may collect information themselves from the BPM Apps Services (or we may provide them with the information described above) for purposes of delivering relevant ads. This assists us in in advertising our services and also providing you with relevant ads based on your browsing interests.
• Business partners: When you engage in promotions offered through the BPM Apps Services, we may share information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant.
• Search Partners. If you have accessed the BPM Apps Services through a BPM Apps Product or third party application installed on your computer or mobile device, then our search partners that developed or distributed the search application may collect information about you including the queries you submit via our BPM Apps Services, the search application or your browser, as well as the search results and ads you click on and the address of the web pages you previously listed.
• Share with a friend/product specific feature. We share information with your friends where you use the “share with the friend functionality” on some of our BPM Apps Services.
• Other Situations. We may disclose your information (i) in good faith compliance with a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency, (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others; (iv) to comply with applicable law or cooperate with law enforcement; (v) to enforce our BPM Apps Services terms and conditions or other agreements or policies; and (vi) in connection with a substantial corporate transaction, such as the sale of our business or the BPM Apps Services (or a majority of the assets of either), a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis.
G. HOW LONG WE KEEP YOUR INFORMATION
All Data collected, including but not limited to: Retention Period Primary Basis for Retention Period
PI: Personal Information Two (2) years period following user inactivity Security, legal requirements and to facilitate seamless user re-engagement
PII: Personal Identifiable Information Data is kept for the life of the customer relationship plus a period of two (2) years Security, legal requirements and to facilitate seamless user re-engagement
Application (Meta) Data Once IP Address has been deleted these data points are no longer Personal Information as they cannot be linked back to a user No longer personally identifiable after a period of two (2) years
H. WHERE WE STORE YOUR INFORMATION
Information we collect, or permit third parties to collect may be transferred to, stored and processed outside your country of residence in any country or territory where one or more of our affiliated group companies, third party service providers or advertising companies or advertising networks are located or maintain facilities, including but not limited to the United States and Ireland.
I. THIRD-PARTY WEBSITES
J. YOUR RIGHTS
Depending on your location you may have some or all of the following rights in relation to how we use your information:
1. Access ‑ you may request access to your information and receive copies of it;
2. Correction to have inaccurate/incomplete information corrected and updated;
3. Object to, or Limit or Restrict, Use of your Information: You can ask us to stop using all or some of your information or to limit our use of it.
4. Deletion – in certain circumstances, you can request a right to be forgotten (this is a right to have your information deleted or our use of your information restricted, including for example, a right to not have a user’s name appear in a search result). We will honor such requests unless we have to retain this information to comply with a legal obligation by European or Member State law or unless we have an overriding interest to retain it
5. Portability- in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your information to transfer to another provider)
6. Consent Management – Where we rely on consent to process your information, you may withdraw consent at any time and you do not have to provide a reason for your withdrawal to withdraw consent at any time where processing is based on consent.
If you wish to exercise any of these rights or wish to object to our use of your information, please write to us at the address listed below and we will consider your request in accordance with applicable laws.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person.
K. HOW WE PROTECT YOUR INFORMATION
The security and confidentiality of your information is very important to us, thus we take certain security measures (including physical, electronic and procedural measures) to help safeguard your information from unauthorized access and disclosure. Please know that, despite our best efforts, no security measures are perfect or impenetrable.
You are solely responsible for maintaining the confidentiality of any password you may use to access the BPM Apps Services. You agree not to transfer your user name or password, or lend or otherwise transfer your use of or access to the BPM Apps Services, to any third party. You are fully responsible for all activity that occurs in connection with your user name or password. You agree to immediately notify us of any unauthorized use of your user name or password or any other breach of security related to your account or the BPM Apps Services, and to ensure that you log off/exit from your account (if applicable) at the end of each session. We are not liable for any loss or damage arising from your failure to comply with any of the foregoing obligations.
L. DATA PROTECTION OFFICER
They can be reached by contacting email@example.com
M. CHILDREN’S PRIVACY
Our BPM Apps Services are intended for general audiences over the age of 13 years old. We do not knowingly collect information from children under the age of 13 years old. If you are not over 13 years old then DO NOT DOWNLOAD OR USE THE BPM APPS SERVICES
N. NO RIGHTS OF THIRD PARTIES
P. YOUR CALIFORNIA PRIVACY RIGHTS
Under the California Shine The Light law, California residents may opt-out of the disclosure of information to third parties for direct marketing purposes (as those concepts are defined in that law) However, we do not currently engage in the type of sharing covered by that law.
Q. HOW TO CONTACT US
BPM Marketing Limited
23 Fitzwilliam street Upper
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