We aim to collect, use and disclose only such information as is required to enable us to manage your account, to provide the Service, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, for service improvement and other purposes as described in Section 2 – Use of Information. We will maintain the confidentiality of any contact information you provide to us on signing up for our Services or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below (See Section 3 – Disclosures and Transfers), unless you agree that we may disclose it to other third parties.
“Personal Information” is personally identifiable information, such as your name, address, e-mail address, credit card information, birth date and gender. At the time of collection, we will clearly identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website or be able to access and use the Website at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website.
Information Collected By Us. We may collect Personal Information in respect of the Service through registration processes; communications with you; information downloads; service purchases; access to your contact lists through social media sites and from your device, user support; and surveys and depending on the communication method that you have elected to connect through, we may have access to other information about you from third party sites. Through your use of the Services we will have access to your query history including details of your marketing strategies that are transmitted or received to your BackPocket account. For purposes of optimizing the Service, we track all interactions and information given to BackPocket for every question asked and answered, including direct conversations between yourself and other users and our marketing expert contributors. Information specific to your business and marketing strategies may be tracked to help improve your team's experience, but will not be disclosed to any other party. In aggregate and anonymized, this data can be used to help the service learn and improve to provide all users with better experience.
Minors: The Service is intended primarily as a tool and resource for business users and therefore do not knowingly collect any Personal Information about minors who are 13 years old or younger and our Services are intended primarily for business users.
“Non-Personal Information” is information of an anonymous nature such as aggregate, anonymized information such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Website. Business contact information such as the name, title, business address, e-mail address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.
We collect information for the following purposes:
Registration: In order to order our Services you must provide certain Personal Information to us such as your full name, address and email address. We also request your business name and certain contact information which is Non-Personal Information. The Service may include the ability to compile a list of details about your business, your team and your marketing strategies in order to improve your experience.
Service: Through the Service, as a customer or user you may share information related to the execution of your business and marketing strategies, and as an advisor you may share information related to your professional knowledge and skills. The Service may use an anonymized copy of the information you may have provided in order to improve its quality.
Marketing Communications: If you opt-in to receive marketing communications from us, we will keep you up to date on our products and services. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each communication.
Statistics: we collect statistics about use of the Services. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.
From time to time we may employ third parties to help us improve the Website and/or the Services. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website and/or the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.
Important Exceptions: We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
Security: The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information for the Services to third parties password.
We generally process Personal Information in order to fulfill contracts we have with our customers and to pursue our legitimate business interests listed above. Otherwise, we will obtain consent from an individual in respect of processing of Personal Information if required by law to do so. Further, individuals located in the EEA (“EEA citizens”) have certain rights under European law (including under the General Data Protection Regulation) (“EU Data Protection Law”) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals located in to the EEA who wish to exercise these rights, should contact us at email@example.com. EEA citizens also have the right to make complaints to regulatory authorities in respect of our privacy practices.
EU Data Protection Law sets out a number of different reasons for which we may collect and process your personal data in certain circumstances. Where EU Data Protection Law applies, the legal bases we rely upon include:
Consent: We can collect and process your data with your consent, where required by the EU Data Protection Law. For example, if you have given your consent to receiving marketing material from us.
Contractual obligations: We need your personal data to comply with our contractual obligations. For example, where you have provided us with your email address to receive access to our Services, we will use this information in order to effectively deliver and communicate information to you in regard to such products and services.
Compliance with legal obligations: If the law requires us to, we may need to collect and process your data for legal compliance reasons. For example, we can pass on details of people involved in fraud or other criminal activity.
Legitimate interest: We may require your data to pursue our legitimate interests or those of a third party in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, it is in our legitimate interests to (a) ensure that content from our Website is presented in the most effective manner for you and your computer and that we provide you with the information, products and services that you request from us, (b) to keep our Website and our Services safe and secure;(c) for measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (including individual and pseudonymous analysis and profiling); (d) to allow you to participate in interactive features of our Services (if applicable), and (e) to use marketing related information about you that we have lawfully collected.
If you are an EEA citizen, Personal Information that we process in relation to you may be transferred and stored at, a destination outside the EEA that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.
We may transfer your personal data outside the EEA:
in order to host or store it;
in order to enable us to provide goods or services to and fulfil our contract with you or the company your work for;
where we are legally required to do so;
where it is in our legitimate interests and we have concluded these are not overridden by your rights.
Where your information is transferred outside the EEA, we take steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as where applicable relying on a recognised legal adequacy mechanism and contracts, to help ensure your rights and protections travel with your data and that your personal data is treated securely and in accordance with this Policy.
If you are an EEA Citizen, you have the following additional rights under certain circumstances:
to be provided with a copy of your personal data held by us;
to request the rectification or erasure of your personal data held by us;
to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns about your information);
to object to the further processing of your personal data, including the right to object to marketing; and
to request that your personal data be moved to a third party.
Access and Accuracy: You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
Contact Us: If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at: firstname.lastname@example.org.
Last Updated: January 23, 2019