Privacy

Privacy Policy Statement

1. Purpose

BTS is committed to maintaining the trust and confidence of its customers and visitors to our web site. In particular, we want users to know that BTS is not in the business of selling, renting or trading email lists with other companies for marketing purposes. In this Privacy Policy we provide detailed information on when and why we collect personal information, how we use it, the limited conditions under which we may disclose it to others and how we keep it secure.

2. Scope

The BTS Web Site Privacy Policy applies equally to all individuals visiting www.bts.com. Specific considerations are provided for the client data housed by BTS for various applications hosted on bts.com, btspulse.com and btscoach.com subdomains (Application).

3. Privacy Policy

3.1. Active Information Collected

  • Certain features in this Application may require Personally Identifiable Information, which is information such as your name, title, occupation, employer name, business address, business telephone number, business fax number, business e-mail address or home phone number (collectively, Personally Identifiable Information or "PII").
  • When you visit and respond to the Application, our web servers may automatically collect web site usage information. Application usage information is non-PII that describes how visitors use and navigate in this Application. Application usage information may include, without limitation, the number and frequency of visitors to each web page, the length of stay on each web page, browser type, the preceding and subsequent page viewed, and an Internet Protocol ("IP") address.
  • As part of the process for submitting your personal information, we may use that information for several general purposes: to tell users about products, seminars and services if users or a user’s organization so request, to fulfill such a request, to contact users if we need to obtain or provide additional information; to verify the accuracy of our records, and to contact users regarding customer satisfaction surveys.
  • A cookie is a small text file containing information that a web site transfers to a computer's hard disk for record-keeping purposes. Cookies allow us to analyze our site traffic patterns and to provide a user-friendly BTS registration and log-in process. A cookie cannot give us access to a user’s computer or to information beyond what is provide to us by users. Most web browsers automatically accept cookies; consult browser's manual or online help for additional information on restricting or disabling the browser's handling of cookies. If cookies are disabled, participants can still view the publicly available information on our web site, but users will not be able to take advantage of offers or activities requiring a BTS account.
  • An IP address is a number that is automatically assigned to your computer or network when you are on the internet. When you respond to the Application, our servers log your IP address. BTS may use IP addresses for a number of purposes, including, without limitation, system administration, and audits of our Application. We may also use IP addresses in cooperation with internet service providers or law enforcement agencies to identify users if we deem it necessary to comply with law, to enforce compliance with this Privacy Policy or this Application’s Terms of Use, or to protect the Application or its users and visitors. Application usage information may be used by us to determine the applicable technology available in order to serve the visitor the most appropriate version of a web page, e-mail or other similar services.
  • Our web sites may contain links to information on other web sites. We do not have any control over these other web sites, and therefore we cannot be responsible for the protection and privacy of any information that is provided while visiting those sites. Those sites are not governed by this Privacy Policy. If questions exist as to how a site uses information, consult that site's privacy statement.

3.2. Use of Information Provided by You

BTS does not share PII collected through the Application with third parties except as set forth below or in this Privacy Policy. BTS may use the PII we collect from you on the Application or from e-mails you send directly to us as follows:

  • To perform the services that BTS has been engaged to perform by the Client (who may be your employer)
  • To respond to your inquiries, comments, questions or requests;
  • To monitor and statistically analyze usage of the Application and to improve the Application and/or our product and services offerings;
  • To administer the Application’s systems, to audit the Application and for other internal business purposes;
  • To contact you about the Application, including, without limitation, to notify you in our discretion of changes to this Privacy Policy, the Terms of Use, or other policies that affect your use of the Web Site;
  • To verify and monitor compliance with the Privacy Policy and Terms of Use;
  • To comply with a judicial, administrative or similar proceeding or order such as a subpoena, search warrant, discovery request or other valid law enforcement measure or investigation;
  • To protect the legal rights, interests and safety of the Application, our users or others in cooperation with copyright owners, internet service providers, wireless service providers and law enforcement agencies;
  • When we employ third parties to perform functions or services on our behalf, including, without limitation, third party hosting companies, communication services and data analysts; or
  • To share with and among our affiliates or in the event there is any transfer, sale, or assignment of any of our business and/or assets or in the event of any other corporate change.

BTS may also disclose personal information if required to do so by law or in the good faith belief that such action is necessary in connection with a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of a business of BTS and/or its subsidiaries or to:

  • conform to legal requirements or comply with legal process served on BTS or this web site;
  • protect and defend the rights or property of BTS and this web site;
  • enforce its agreements with users or a user’s organization, or
  • act in urgent circumstances to protect personal safety or the public.

3.3. Information Collected by Automated Means

  • We use various tools to enhance the Application user experience and track users of the Application, including cookies. Cookies are small pieces of text that a website places on your computer to help remember information about your visit. Cookies cannot read data off our computer’s hard drive or collect your personal information. We use information collected from cookies to improve your experience and the overall quality of our services. To access the features of the Application you must enable cookies using your browser’s preferences.
  • Information collected through passive means may be non-identifying or may be associated with you. In the latter case, it will be treated as PII.

3.4. Our Commitment to Security

  • Your privacy is important to us. BTS uses reasonable efforts and safeguards to protect the PII we collect on this Web Site from unauthorized access, use, modification or disclosure. The Application and all information that you submit through the application is collected, stored and processed within Company-controlled databases. We restrict access to your PII to those employees of ours and to those service providers who need to use it to manage the Application. Client data is retained in accordance with the retention policy of the applicable Client master service agreement / contract. We have implemented physical, administrative, and technical safeguards to protect your PII from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. BTS is certified and compliant with the international information security standard ISO 27001:2013.

3.5. Data Subject Rights

  • Right of Access: An individual has the right to ask whether we process data about them and to have access to that data.
  • Right to Rectification: Where personal data is inaccurate or incomplete, an individual has the right to request that it be corrected or completed.
  • Right to Erasure: An individual has the right to require that BTS erases personal data without undue delay.
  • Right to Restrict Processing: An individual can exercise the right to a restriction of processing of their personal data under certain circumstances.
  • Right to Data Portability: An individual has the right to request that their personal data be provided to them and to transfer that data to another party.
  • Right to Object: An individual has the right to object to processing under certain circumstances
  • Automated Decision-Making Rights: An individual has the right to not be the subject of automated decision-making where the decision may impact them.

3.6. Exercising Data Subject’s Rights and Contacting BTS

This Application may contain pages through which you can change your preferences or update the PII. You can contact BTS directly in order to:

  • Update or correct the PII that we store about you;
  • Direct us to render inactive on our systems all your PII; or
  • Make a request related to the data subject rights listed in section 4.5.

We may be reached at data.privacy@BTS.com.

Please note that if you request us to render inactive your PII, we may still use aggregated non-PII, and some PII that you provided may continue to reside on backup servers and other non-active systems for data restoration purposes. We will not manually delete PII from such backup media.

3.7. User Consent

  • By using our web sites, users consent to the collection and use of the information provided by the user as outlined in this Privacy Policy. We may change this Privacy Policy from time to time and without notice. If we change our Privacy Policy, we will publish those changes on this page.
  • You can withdraw your consent at any time.

3.8. Consent to Transfer

  • Please be aware that any information you provide to us may be transferred within and/or outside of the country of origin to another BTS location. BTS carefully reviews international data transfers before they take place to ensure that they fall within the limits of local and international laws and regulations. By using the Application or by providing us with your information, you consent to this transfer.

3.9. Children

  • The BTS applications are not intended for use by children. If you are under eighteen (18) years of age, you may use the BTS Application only with the involvement of a parent or guardian. Further, BTS’s services are not directed to children or anyone under 18 years of age. BTS will not knowingly collect, maintain or use any personally identifiable information about anyone under 18 years of age. In the event we discover that a child under the age of eighteen (18) has responded to this Application with personally identifiable information, we will delete such child’s personally identifiable information from our database.

3.10. Breach Notification

  • It is the policy of BTS to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. Where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.

3.11. Acceptance and Privacy Policy Changes

  • By using this Application, you accept our privacy practices as outlined in this Privacy Policy. BTS reserves the right to modify, revise or otherwise update this Privacy Policy at any time for any reason. We will post any new or revised policies on the Application, but we will only use your PII in accordance with the privacy policy that was in effect at the time it was collected, unless you consent to any new terms regarding its use. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE EXIT THIS WEB SITE IMMEDIATELY.

Legal Notice

Unless otherwise indicated, this Web Site and its contents, including but not limited to all text, HTML code, CGI scripts, graphics, button images, and the site design and "look and feel," are the property of BTS and are protected pursuant to U.S. and foreign copyright and trademark laws. By accessing this Web Site, you agree to the following terms and conditions, which govern this Web Site:

  1. This Web Site and the material on this Web Site may not be modified, copied, distributed, republished, downloaded, uploaded or commercially exploited in any manner without the prior written consent of BTS except that you are permitted to download a copy of any of the materials on this Web Site on a single computer for personal noncommercial use, provided no copyright, trademark or other proprietary notices are removed. No intellectual property or other rights in or to this Web Site or its contents are transferred to you.
  2. The information on this Web Site is provided solely for illustrative purposes and does not create any business, contractual or employment relationship.
  3. THE MATERIAL ON THIS WEB SITE IS PROVIDED ’AS IS’ AND IS WITHOUT WARRANTY OF ANY KIND. BTS DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTIBILITY AND FITNESS FOR A PARTICULAR PURPOSE, WITH RESPECT TO THIS WEB SITE AND THE MATERIAL ON THIS WEB SITE. BTS ALSO MAKES NO REPRESENTATIONS OR WARRANTIES AS TO WHETHER THE INFORMATION ACCESSIBLE ON THIS WEB SITE IS ACCURATE, COMPLETE OR CURRENT.
  4. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS, IN NO EVENT SHALL BTS BE LIABLE FOR ANY DAMAGES OF ANY KIND OR CHARACTER, INCLUDING WITHOUT LIMITATION ANY COMPENSATORY, INCIDENTAL, DIRECT, INDIRECT, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES, LOSS OF USE, LOSS OF DATA, LOSS OF INCOME OR PROFIT, LOSS OF OR DAMAGE TO PROPERTY, CLAIMS OF THIRD PARTIES, OR OTHER LOSSES OF ANY KIND OR CHARACTER, EVEN IF BTS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, ARISING OUT OF OR IN CONNECTION WITH THIS WEB SITE OR THE CONTENTS OF THIS WEB SITE.
  5. The posting of any content or material to this Web Site and the creation of a link from this Web Site to any other Web Site are expressly prohibited without the prior written consent of BTS 
  6. BTS does not regularly review materials on Web Sites linked to this Web Site and does not necessarily endorse the materials appearing on any linked Web Sites.
  7. BTS reserves the right to change these terms and conditions at any time by updating this posting. Use of this Web Site following any such changes shall constitute acceptance of such changes.

This policy was last updated on May 22, 2018. For a list of the exact changes, please reach out to data.privacy@BTS.com

 

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