Consumer Data & Privacy
Last Updated: 05/25/2018
- A NOTE ABOUT CHILDREN. WE DO NOT INTENTIONALLY GATHER PERSONAL DATA FROM VISITORS WHO ARE UNDER THE AGE OF 13.
- A NOTE TO USERS OUTSIDE OF THE UNITED STATES. YOUR PERSONAL DATA MAY BE PROCESSED IN THE COUNTRY IN WHICH IT WAS COLLECTED AND IN OTHER COUNTRIES, INCLUDING THE UNITED STATES, WHERE LAWS REGARDING PROCESSING OF PERSONAL DATA MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.
- TYPES OF DATA WE COLLECT. “PERSONAL DATA”MEANS DATA THAT ALLOWS SOMEONE TO IDENTIFY OR CONTACT YOU, INCLUDING, FOR EXAMPLE, YOUR NAME, ADDRESS, TELEPHONE NUMBER, E-MAIL ADDRESS, AS WELL AS ANY OTHER NON-PUBLIC INFORMATION ABOUT YOU THAT IS ASSOCIATED WITH OR LINKED TO ANY OF THE FOREGOING DATA. “ANONYMOUS DATA”MEANS DATA THAT IS NOT ASSOCIATED WITH OR LINKED TO YOUR PERSONAL DATA; ANONYMOUS DATA DOES NOT, BY ITSELF, PERMIT THE IDENTIFICATION OF INDIVIDUAL PERSONS. WE COLLECT PERSONAL DATA AND ANONYMOUS DATA, AS DESCRIBED BELOW.
(A) INFORMATION YOU PROVIDE TO US.
- WE MAY COLLECT PERSONAL DATA FROM YOU, SUCH AS YOUR FIRST AND LAST NAME, GENDER, E-MAIL AND MAILING ADDRESSES, PROFESSIONAL TITLE, COMPANY NAME, AND PASSWORD WHEN YOU CREATE AN ACCOUNT TO LOG IN TO OUR NETWORK (“ACCOUNT”).
- WE MAY COLLECT PERSONAL DATA FROM YOU, SUCH AS YOUR FIRST AND LAST NAME, GENDER, E-MAIL AND MAILING ADDRESSES, PROFESSIONAL TITLE, COMPANY NAME, AND PASSWORD WHEN YOU COMPLETE ANY FIELD IN OUR CHECKOUT PROCESS(“ACCOUNT”).
- WHEN YOU ORDER SERVICES ON OUR SITE, WE WILL COLLECT ALL INFORMATION NECESSARY TO COMPLETE THE TRANSACTION, INCLUDING YOUR NAME, CREDIT CARD INFORMATION, BILLING INFORMATION AND SHIPPING INFORMATION.
- WE RETAIN INFORMATION ON YOUR BEHALF, SUCH AS FILES AND MESSAGES THAT YOU STORE USING YOUR ACCOUNT.
- IF YOU PROVIDE US FEEDBACK OR CONTACT US VIA E-MAIL, WE WILL COLLECT YOUR NAME AND E-MAIL ADDRESS, AS WELL AS ANY OTHER CONTENT INCLUDED IN THE E-MAIL, IN ORDER TO SEND YOU A REPLY.
- WE ALSO COLLECT OTHER TYPES OF PERSONAL DATA THAT YOU PROVIDE TO US VOLUNTARILY, SUCH AS YOUR OPERATING SYSTEM AND VERSION, PRODUCT REGISTRATION NUMBER, AND OTHER REQUESTED INFORMATION IF YOU CONTACT US VIA E-MAIL REGARDING SUPPORT FOR THE SERVICES.
- WE MAY ALSO COLLECT PERSONAL DATA, SUCH AS AT OTHER POINTS IN OUR SITE THAT STATE THAT PERSONAL DATA IS BEING COLLECTED.
(B) INFORMATION COLLECTED VIA TECHNOLOGY.
- TO MAKE OUR SITE AND SERVICES MORE USEFUL TO YOU, OUR SERVERS (WHICH MAY BE HOSTED BY A THIRD PARTY SERVICE PROVIDER) COLLECT INFORMATION FROM YOU, INCLUDING YOUR BROWSER TYPE, OPERATING SYSTEM, INTERNET PROTOCOL (IP) ADDRESS (A NUMBER THAT IS AUTOMATICALLY ASSIGNED TO YOUR COMPUTER WHEN YOU USE THE INTERNET, WHICH MAY VARY FROM SESSION TO SESSION), DOMAIN NAME, AND/OR A DATE/TIME STAMP FOR YOUR VISIT.
(C) INFORMATION COLLECTED FROM YOU ABOUT OTHERS . IF YOU DECIDE TO INVITE A THIRD PARTY TO CREATE AN ACCOUNT, WE WILL COLLECT YOUR AND THE THIRD PARTY’S NAMES AND E-MAIL ADDRESSES IN ORDER TO SEND AN E-MAIL AND FOLLOW UP WITH THE THIRD PARTY. YOU OR THE THIRD PARTY MAY CONTACT US AT support@BT21CLUB.com TO REQUEST THE REMOVAL OF THIS INFORMATION FROM OUR DATABASE.
(D) INFORMATION COLLECTED FROM THIRD PARTY COMPANIES. WE MAY RECEIVE PERSONAL AND/OR ANONYMOUS DATA ABOUT YOU FROM COMPANIES THAT PROVIDE OUR SERVICES BY WAY OF A CO-BRANDED OR PRIVATE-LABELED WEBSITE OR COMPANIES THAT OFFER THEIR PRODUCTS AND/OR SERVICES ON OUR SITE. THESE THIRD PARTY COMPANIES MAY SUPPLY US WITH PERSONAL DATA,. WE MAY ADD THIS INFORMATION TO THE INFORMATION WE HAVE ALREADY COLLECTED FROM YOU VIA OUR SITE IN ORDER TO IMPROVE THE SERVICES WE PROVIDE.
- USE OF YOUR PERSONAL DATA
(A) GENERAL USE. IN GENERAL, PERSONAL DATA YOU SUBMIT TO US IS USED EITHER TO RESPOND TO REQUESTS THAT YOU MAKE, OR TO AID US IN SERVING YOU BETTER. WE USE YOUR PERSONAL DATA IN THE FOLLOWING WAYS:
- TO FACILITATE THE CREATION OF AND SECURE YOUR ACCOUNT ON OUR NETWORK;
- IDENTIFY YOU AS A USER IN OUR SYSTEM;
- PROVIDE IMPROVED ADMINISTRATION OF OUR SITE AND SERVICES;
- PROVIDE THE SERVICES YOU REQUEST;
- IMPROVE THE QUALITY OF EXPERIENCE WHEN YOU INTERACT WITH OUR SITE AND SERVICES;
- SEND YOU A WELCOME E-MAIL TO VERIFY OWNERSHIP OF THE E-MAIL ADDRESS PROVIDED WHEN YOUR ACCOUNT WAS CREATED;
- SEND YOU ADMINISTRATIVE E-MAIL NOTIFICATIONS, SUCH AS SECURITY OR SUPPORT AND MAINTENANCE ADVISORIES;
- RESPOND TO YOUR INQUIRIES RELATED TO EMPLOYMENT OPPORTUNITIES OR OTHER REQUESTS;
- TO MAKE TELEPHONE CALLS TO YOU, FROM TIME TO TIME, AS A PART OF SECONDARY FRAUD PROTECTION OR TO SOLICIT YOUR FEEDBACK; AND
- TO SEND NEWSLETTERS, SURVEYS, OFFERS, AND OTHER PROMOTIONAL MATERIALS RELATED TO OUR SERVICES, FOR OTHER MARKETING PURPOSES OF COMPANY, AND REGARDING RELEVANT PARTNER OFFERS.
(B) CREATION OF ANONYMOUS DATA. WE MAY CREATE ANONYMOUS DATA RECORDS FROM PERSONAL DATA BY EXCLUDING INFORMATION (SUCH AS YOUR NAME) THAT MAKE THE DATA PERSONALLY IDENTIFIABLE TO YOU. WE USE THIS ANONYMOUS DATA TO ANALYZE REQUEST AND USAGE PATTERNS SO THAT WE MAY ENHANCE THE CONTENT OF OUR SERVICES AND IMPROVE SITE NAVIGATION. COMPANY RESERVES THE RIGHT TO USE ANONYMOUS DATA FOR ANY PURPOSE AND DISCLOSE ANONYMOUS DATA TO THIRD PARTIES IN ITS SOLE DISCRETION.
(A) THIRD PARTY SERVICE PROVIDERS. WE MAY SHARE YOUR PERSONAL DATA WITH THIRD PARTY SERVICE PROVIDERS TO: PROVIDE YOU WITH THE SERVICES THAT WE OFFER YOU THROUGH OUR SITE; TO CONDUCT QUALITY ASSURANCE TESTING; TO FACILITATE CREATION OF ACCOUNTS; TO PROVIDE TECHNICAL SUPPORT; AND/OR TO PROVIDE OTHER SERVICES TO THE COMPANY. THESE THIRD PARTY SERVICE PROVIDERS ARE REQUIRED NOT TO USE YOUR PERSONAL DATA OTHER THAN TO PROVIDE THE SERVICES REQUESTED BY COMPANY.
- THIRD PARTY DATA COLLECTION.
(A) INFORMATION DISCLOSED TO AD NETWORKS. WE USE THIRD-PARTY ADVERTISING COMPANIES TO SERVE ADS WHEN YOU VISIT OUR SITE. THESE COMPANIES MAY COLLECT AND USE INFORMATION (NOT INCLUDING YOUR NAME, ADDRESS, EMAIL ADDRESS, OR TELEPHONE NUMBER) ABOUT YOUR VISITS TO THIS AND OTHER WEBSITES IN ORDER TO PROVIDE ADVERTISEMENTS ABOUT GOODS AND SERVICES TO YOU. IF YOU WOULD LIKE MORE INFORMATION ABOUT THIS PRACTICE AND TO KNOW YOUR CHOICES ABOUT NOT HAVING THIS INFORMATION USED BY THESE COMPANIES, GO TO WWW.NETWORKADVERTISING.ORG/MANAGING/OPT_OUT.ASP.
- YOUR CHOICES REGARDING YOUR PERSONAL DATA
(A) CHOICES. WE OFFER YOU CHOICES REGARDING THE COLLECTION, USE, AND SHARING OF YOUR PERSONAL DATA.
(I) WE WILL PERIODICALLY SEND YOU FREE NEWSLETTERS AND E-MAILS THAT DIRECTLY PROMOTE THE USE OF OUR SITE OR SERVICES. WHEN YOU RECEIVE NEWSLETTERS OR PROMOTIONAL COMMUNICATIONS FROM US, YOU MAY INDICATE A PREFERENCE TO STOP RECEIVING FURTHER COMMUNICATIONS FROM US AND YOU WILL HAVE THE OPPORTUNITY TO “OPT-OUT” BY FOLLOWING THE UNSUBSCRIBE INSTRUCTIONS PROVIDED IN THE E-MAIL YOU RECEIVE OR BY CONTACTING US DIRECTLY (PLEASE SEE CONTACT INFORMATION BELOW).
(B) CHANGES TO PERSONAL DATA. YOU MAY CHANGE ANY OF YOUR PERSONAL DATA IN YOUR ACCOUNT BY EDITING YOUR PROFILE WITHIN YOUR ACCOUNT OR BY SENDING AN E-MAIL TO US AT THE E-MAIL ADDRESS SET FORTH BELOW. YOU MAY REQUEST DELETION OF YOUR PERSONAL DATA BY US, BUT PLEASE NOTE THAT WE MAY BE REQUIRED TO KEEP THIS INFORMATION AND NOT DELETE IT (OR TO KEEP THIS INFORMATION FOR A CERTAIN TIME, IN WHICH CASE WE WILL COMPLY WITH YOUR DELETION REQUEST ONLY AFTER WE HAVE FULFILLED SUCH REQUIREMENTS). WHEN WE DELETE ANY INFORMATION, IT WILL BE DELETED FROM THE ACTIVE DATABASE, BUT MAY REMAIN IN OUR ARCHIVES. WE MAY RETAIN YOUR INFORMATION FOR FRAUD OR SIMILAR PURPOSES.
- SECURITY OF YOUR PERSONAL DATA. COMPANY IS COMMITTED TO PROTECTING THE SECURITY OF YOUR PERSONAL DATA. WE USE A VARIETY OF INDUSTRY-STANDARD SECURITY TECHNOLOGIES AND PROCEDURES TO HELP PROTECT YOUR PERSONAL DATA FROM UNAUTHORIZED ACCESS, USE, OR DISCLOSURE. WE ALSO REQUIRE YOU TO ENTER A PASSWORD TO ACCESS YOUR ACCOUNT INFORMATION. PLEASE DO NOT DISCLOSE YOUR ACCOUNT PASSWORD TO UNAUTHORIZED PEOPLE. NO METHOD OF TRANSMISSION OVER THE INTERNET, OR METHOD OF ELECTRONIC STORAGE, IS 100% SECURE, HOWEVER. THEREFORE, WHILE COMPANY USES REASONABLE EFFORTS TO PROTECT YOUR PERSONAL DATA, COMPANY CANNOT GUARANTEE ITS ABSOLUTE SECURITY.
11.Residents of the European Economic Area (“EEA”)
BT21 CLUB works with users around the world, including in the EEA. If you are located in the EEA, your personal information is processed by Shopify’s Irish affiliate, Shopify International Ltd. As part of our service, we may transfer your personal information to other regions, including to Canada and the United States. In order to ensure that your information is protected when transferred out of the EEA, Shopify relies on the EU-U.S. Privacy Shield (described in more detail below), as well as inter-company agreements between our various affiliates that may process your information on behalf of Shopify International Ltd.
If you are located in the EEA, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, port to another service provider, or object to certain uses of your personal data.
Additionally, if you are located in the EEA, we note that we are generally processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above, unless we are required by law to obtain your consent for a particular processing operation. In particular we process your personal data to pursue the following legitimate interests, either for ourselves, or other third parties.
- To prevent risk and fraud on our platform;
- To provide communications, marketing, and advertising;
- To provide reporting and analytics;
- To provide troubleshooting, support services, or to answer questions;
- To test out features or additional services; and
- To improve our services, applications, and website.
When we process personal information to pursue these legitimate interests, we do so where we believe the nature of the processing, the information being processed, and the technical and organisational measures employed to protect that information can help mitigate the risks to the data subject.
- How do we protect your personal information across borders?
BT21 Club complies with the EU-U.S. Privacy Shield Framework, regarding the collection, use, and retention of personal information from data subjects in the European Economic Area (“EEA”), and with the Swiss-U.S. Privacy Shield Framework regarding the collection, use and retention of personal information from data subjects in Switzerland. In this regard, we have certified that we adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfers, security, data integrity and purpose limitation, access, recourse, enforcement and liability.
If you are located in the EEA or in Switzerland, and believe that your personal information has been used in a manner that is not consistent with the relevant privacy policies listed above, please contact us using the information below. If your complaint or dispute remains unresolved, you may also contact the International Centre for Dispute Resolution®, the international division of the American Arbitration Association® (ICDR/AAA). This organization provides independent dispute resolution services, at no charge to you. ICDR/AAA can be contacted at http://go.adr.org/privacyshield.html.
If, after attempting to resolve a dispute through ICDR/AAA, you feel that your concerns about the use of your personal information have not been resolved, you may seek resolution of the issue through binding arbitration. For more information about the binding arbitration process, please visit http://www.privacyshield.gov.
By participating in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, BT21 CLUB’S participating U.S. entities are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, please visit https://www.privacyshield.gov. You can view BT21 CLUB’S certification statement.
- Control over and access to your personal information
In the course of offering our services, BT21 Club uses a number of machine learning algorithms and forms of automated decision-making. For example, we use automated decision-making: to prevent risk and fraud by us; to help us avoid fraudulent transactions from our customers.
Most of these algorithms (excluding the personalization features and a subset of customer risk/fraud screening, discussed in more detail below) are not fully automated and include some human intervention (for example, customer risk and fraud scores are provided to merchants, who must intentionally decide how to act on them). Our personalization algorithms are fully automated, Similarly, we have a small subset of fully automated fraud screening blacklists, which, if we believe a transaction was made using stolen or fraudulent payment information, may stop a customer from completing a transaction--but only for a period of between a few hours and a few days.
- Control over and access to your personal information
BT21 Club understands that you have rights over your personal information, and takes reasonable steps to allow you to access, correct, amend, delete, port, or limit the use of your personal information. If you are unable to change your personal information within your account settings, or if you are concerned about data collected as you visit BT21 CLUB’S websites or use our support services, please contact us to make the required changes. It’s important to remember that if you delete or limit the use of your personal information, the Services may not function properly.
If you have any questions about your personal information or this policy, or if you would like to make a complaint about how BT21CLUB processes your personal data, please contact Us by email at support@BT21CLUB,