Welcome and Introduction
We always seek to improve our Services to you, and that requires that we collect, store, share, and use information about you and your usage preferences. As we do so, we are absolutely committed to protecting your privacy and the security of your personal information.
DESCRIPTION OF SERVICES
LAWFUL BASIS FOR PROCESSING
When you enter into an agreement with us, either in hard copy or by clicking “I Accept” or similar language online, we will process your Data for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your Data is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that Data have been fulfilled and after we no longer have a legal obligation to keep that Data.
In all cases, we will comply with applicable law and we will cease processing your Data after the legal obligation or other necessity passes.
The Services are directed solely to persons 18 years of age or older or of children under 18 who are supervised by a parent, guardian, or other caregiver. Other than for Data collected for the specific purpose of providing the Services to users, we do not knowingly collect Data from users who are under 13. If we become aware that we have gathered Data from a person under 13, except to provide the Services to such person, then we will attempt to delete such Data as soon as possible, subject to our obligations under applicable law. If you believe that we have gathered Data from a person under 13 in contravention of this policy, please contact us at [email protected].
INFORMATION WE COLLECT AND HOW WE USE IT
A. Registration Data
Data Description: Registration Data consists of the name, e-mail address, and other contact information you provide us using the Services, both when you register your account and thereafter. Registration Data also includes your username, membership type (e.g., ad-supported or paid membership), and membership end date. Lawful Basis for Processing: Our lawful basis for processing Registration Data is our contract with you. We can only provide the Services to you if we have the Registration Data, so we need to store and access that Registration Data during the term of our contract. How We Use It and Who We Share It With: Registration Data is accessible only to us. We use it only to provide the Services to you. At times, we will share the Registration Data with third parties at your request or to fulfill requests that you make to us. We may use your Registration Data to offer goods or services to you, but only after obtaining your specific consent.
B. In-Field Data
C. Usage Data
Data Description: Usage Data consists of the following and similar information: Information about your interactions with the Services which includes the date and time of any requests you make. This also may include details of your use of Third-Party Applications and advertising you receive. The timing of the information you post to the Services including messages you send and/or receive via the Services and your interactions with our customer service team, but not including the content of those interactions and messages. Technical data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and application version. Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Services to you. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from you. How We Use It and Who We Share It With: Usage Data is accessible to us and to you. We do not share it with third parties, except at your specific request, but we may use Usage Data to make improvements to the Services. We may also use Usage Data in an aggregated format that is not identifiable to any individual, and that aggregated information belongs solely to us. To the extent we are required to delete any Usage Data about you, we may still retain aggregated and anonymized information that may have originated as your Usage Data.
D. Payment Data
1. Data Description: Payment Data is the information necessary for us to process your payments for premium Services. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but will include information such as: Name; Date of birth; Credit or debit card type, expiration date, and certain digits of your card number; Address and postal code; and Mobile phone number
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from you.
3. How We Use It and Who We Share It With: We only use Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.
E. Supplemental Mobile Data
1. Data Description: Supplemental Mobile Data consists of the following and similar information: Your precise mobile device location – If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Services. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements; Your voice data – If you give us permission, this enables us to access the voice commands captured via your device microphone to enable you to interact with the Services with your voice. Please note you will always have the ability to turn off the microphone feature; Your contacts – If you give us permission to access your contacts, this enables us to access individual contacts stored on your device to help you find friends who use the Services; The Company user profile includes age, gender, and other personal characteristics use for the purpose of delivering certain features; and Your photos – If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll.
2. Lawful Basis for Processing: Our lawful basis for processing Supplemental Mobile Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Supplemental Mobile Data we receive from you.
3. How We Use It and Who We Share It With: We only use Supplemental Mobile Data when you specifically authorize it, and we only share it with those parties who are strictly necessary for the purpose you have authorized.
A. Current and Potential Employees
We often use the services of third parties to help us to recruit new employees and independent contractors and to manage our interactions with current employees and independent contractors. We do our best to contractually ensure that these third-party service providers comply with the policies we have adopted. However, we can’t guarantee their compliance in every case.
Our lawful basis for processing Data about potential and current employees and independent contractors is our contract with them and our legitimate interest in processing that Data, both to facilitate the formation of a formal relationship and to manage that relationship once it is formed. We only use employment Data for the direct purpose of the employment or independent contractor relationship, and we cease using it as soon as that relationship ends. However, we may keep and process that Data after the relationship ends when we are required to do so by applicable law or to preserve legal claims that may arise.
B. Emergency Use of Contact Information
When you sign up with us, we will ask you to provide your personal street address and contact information for two emergency contacts (“Emergency Data”). If you ever send an SOS from your Bivy Stick, we will pass along the Emergency Data to the Geo that issues the SOS. We will never use Emergency Data for any other purpose without your explicit permission.
SHARING YOUR INFORMATION
Except where a specific limitation is noted above, we may share your Data as follows:
If we ever plan to use any Data in the future for any other purposes not identified above and we do not have a separate lawful basis for that processing, we will only do so after obtaining your specific consent.
TECHNOLOGIES WE USE
The technologies we use for automatic Data collection may include the following:
YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR DATA
We only use your Data for marketing purposes if you give us your specific consent. If, after giving your consent, you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, or if you wish to stop receive marketing e-mails from us, please follow the instructions below. (Note that if you are a resident of the European Union, we will never use your personal data for third-party marketing purposes unless you have clicked on a box online to expressly give consent for such use.)
PRIVACY FOR EU RESIDENTS
For employees and other authorized users operating in their role as administrators or users of our services, our lawful basis is the legitimate interest we have in providing the services to their employer.
If you are a client or customer who accesses the Data of third parties in connection with your services rendered to us, you, your employees, and your other authorized users agree to be bound by the provisions of the GDPR with respect to any Data with which you come in contact using Services, including without limitation the personal data belonging to individuals with whom you communicate or whose personal data you access using the Services. Specifically, you agree that you, your employees, or other authorized users will:
A. Never access, process, transfer, view, use, or store any Data of any third party without express authorization, and then only for purposes directly related to fulfilling your contractual obligations under your agreement with any third party (“Data Secrecy”);
B. Keep all Data strictly confidential and disclose Data only on a strict need-to-know basis to other employees or authorized users only as required for fulfilling an individual’s contractual obligations (“Confidentiality”); however, you agree that you shall not disclose or otherwise make accessible Data under any circumstances to anyone who has not been obliged to Data Secrecy and Confidentiality.
C. Ensure that your obligations of Data Secrecy and Confidentiality are observed forever, both during and after the expiration and/or termination of any agreement with us or any contractual relationship you may have with an employer or other party.
D. Upon our request to provide Company with satisfactory evidence that you have complied with your obligations of Data Secrecy and Confidentiality as set forth in this agreement.
The GDPR also requires us to take appropriate technical and organizational measures to protect the security of Data belonging to residents of Europe. We make commercially reasonable efforts to ensure the privacy and security of the Data of our European visitors and customers, and we are happy to give you a complete description of our most current efforts, if you will write us at [email protected].
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
ACCESS AND ACCURACY
You have the right to access the information we hold about you in order to verify the 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 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 information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your information as appropriate. As appropriate, this amended information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate information about you enables us to give you the best possible service.
You can help by keeping us informed of any changes such as a change of your personal contact information. 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 [email protected]. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.