Privacy Shield Policy

Privacy Shield Policy

BTS complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union or Switzerland to the United States. BTS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

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. Web Site Policy

3.1. Collection and Use of Personal Information

  • Personal information means any information that may be used to identify users, such as a user’s name, title, phone number, email address, or mailing address.
  • In general, users can browse our web sites without giving us any personal information. We reserve the right to use a third party reporting service to analyze traffic to this web site in order to understand our customers’ and visitors’ needs and to continually improve our sites for them. Such third party reporting service collects only anonymous, aggregate statistics. For example, we do not tie a specific visit to a specific IP address.
  • As part of the registration process, we ask users to create a BTS account where we may collect additional personal information. We 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.

3.2. Disclosure of Personal Information

  • BTS sometimes hires vendor companies to provide limited services on our behalf, including packaging, mailing and delivering items, sending postal mail, providing technical support, and processing registrations. We provide those companies only the information they need to deliver the service, and they are prohibited from using that information for any other purpose.
  • Because BTS is a global company, our goal is to abide by the strictest interpretations of the privacy laws governing personal information for each region in which we operate. While data protection laws vary widely among different regions, BTS and its offices and subsidiaries are governed by this Privacy Policy and will use personal information only as set forth in this policy.
  • 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. Children and Privacy

  • Our web site does not offer information intended to attract children. BTS does not knowingly solicit personal information from children under the age of 13.

3.4. Security of Personal Information

  • When users submit any form requiring sensitive personal information, we use a secure server. The secure server software (SSL) helps protect information as it travels over the Internet by encrypting that information before it is sent to us. We have also implemented industry-standard security mechanisms and procedures to protect data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

3.5. Use of Cookies

  • 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.

3.6. Links to Other Web Sites

  • 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.

3.7. Updating Personal Information

  • If users have a BTS account, users can update or correct information online or by emailing us at data.privacy@bts.com.

3.8. Unsubscribing

  • If users have set up a BTS account, users may change personal preferences at any time by following the instructions provided in the BTS account pages.

3.9. 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.

If questions or concerns exist about our collection, use or disclosure of personal information, please email us at data.privacy@BTS.com.

4. Applications housing client data on bts.com, btspulse.com and btscoach.com subdomains (Application) Policy

4.1. 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.
  • 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.

4.2. 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 is responsible for the processing of PII it may receive under each Privacy Shield Framework, including subsequent transfers to third parties BTS engages whom are acting on our behalf. BTS complies with the Privacy Shield Principles for al onward transfers of PII from the EU and Switzerland, including the onward transfer liability provisions. BTS may be liable in cases where those third parties BTS engages do not meet the obligation to process personal data in accordance with the Privacy Shield or other applicable EU data protection requirements. 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 would 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.

4.3. 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.

4.4. 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. 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.

4.5. Data Access and Integrity

  • BTS makes every effort to ensure that all data collected be accurate and complete. All data is virtually partitioned. With the exception of BTS’s IT staff and software developers, data is only accessible to users granted proper permissions. Permission structures are maintained by BTS’s Director of Digital Technology. When users with system access leave BTS, their usage rights are revoked.

4.6. Data Storage and Maintenance

  • Database copies containing client data are maintained at secure data centers. Access to database copies is limited to BTS’s IT staff and developers currently on project. Client data is retained in accordance with the retention policy of the applicable Client master service agreement / contract.

4.7. Employee Awareness

  • All employees are briefed as to data security policies and sign a non-disclosure agreement.

4.8. Consent to Transfer

  • If you are located in Canada, the European Union or elsewhere outside the United States, please be aware that any information you provide to us may be transferred to servers hosted in the United States. By using the Application or by providing us with your information, you consent to this transfer.

4.9. Updating/Correcting Your PII 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; or
    • Direct us to render inactive on our systems all your PII. 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.

4.10. 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.

4.11 Enforcement and Dispute Resolution

  • In compliance with the US-EU and Swiss-US Privacy Shield Principles, BTS commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: data.privacy@bts.com.
  • If a Customer's question or concern cannot be satisfied through this process BTS has further committed to refer unresolved privacy complaints under US-EU Privacy Shield and Swiss-US Privacy Shield to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus.
  • If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by BTS, EU and Swiss individuals may bring a complaint before the EU and Swiss Privacy Shield program can be found at https://www.privacyshield.gov/Individuals-in-Europe. You can always submit a complaint directly to your local DPA or the Swiss Federal Data Protection and Information Commissioner. Your DPA or the Swiss Commissioner may refer your complaint directly to the Department of Commerce on your behalf. If referred to the Department of Commerce, the Privacy Shield Team will then work with the organization to seek to resolve your concern. Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism http://go.adr.org/privacyshieldannex.html.
  • Our commitments under the Privacy Shield Frameworks are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
  • BTS commits to cooperate with EU and Swiss data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

4.12 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.
 

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