Last modified: November 7, 2019
1. What Information We Collect
a. Information You Provide Directly To Us
b. Information That Is Passively Or Automatically Collected
i. Device/Usage Information
ii. Cookies And Other Electronic Technology
c. Information Provided By Social Networking Services And Others
2. How We Use Your Information at BW
3. Legal Bases For Use Of Your Personal Data
4. No Disclosure to Third Parties for Their Own Marketing Purposes
5. When We Share Your Personal Information With Third Parties
6. Online Analytics And Tailored Advertising
7. Data Subject Rights And Your Choices
8. Retention Of Personal Data And Security
9. Outside The United States Consent To Processing And Transfer Of Information
10. Additional Information
a. Links To Third Party Websites
b. Social Media Widgets
12. Change Policy
13. Contact Information
1. What Information We Collect
a. Information You Provide Directly to Us
We may collect information from you in a variety of ways, such as when you:
• Register for an account on any of our websites (“Account”);
• Request certain features (e.g. newsletters);
• Fill out a survey or provide us with feedback;
• Engage in other activities that require your information to function; or
• Communicate with us.
You are not required to create an Account to gain access to some areas of our websites. If you do create an Account, we ask for certain information to process your registration, including an email address and password.
We may also collect (1) name, (2) gender, (3) age, (4) other demographic information, and (5) other information you voluntarily provide to us. Providing most of this information is optional. We also allow you select your preferences for receiving email communications.
b. Information that is Passively or Automatically Collected
In addition to the information you provide directly to us, when you use any of our websites, we automatically collect information about the computer, mobile device, or other devices you use to access the website and about how you use the website. For example, we receive data about links you click, photos you like, or poll you participate in. We also receive information such as your browser type, IP address, the type of device you use, operating system version, unique device identifier (“UDID”), the date and time of your visit and files you viewed on our site (e.g., HTML pages, graphics, etc.), Internet service provider, clickstream data, the pages you view and the websites you visited immediately before and after visiting the website. In some cases, we link this automatically collected data to other information we collect about you. We do this to improve the services and marketing we offer you.
i. Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access our websites. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information (based on IP addresses), unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the website; and (b) information related to the ways in which you interact with the website, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the website, the amount of time spent on particular pages, the date and time you used the website, the frequency of your use of the website, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
ii. Cookies and Other Electronic Technology
You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the website.
c. Information Provided by Social Networking Services and Others
We may supplement the information you provide to us with additional information gathered from other sources, such as publicly available information, or from third parties, such as marketers, partners, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other product or service we provide.
2. How We Use Your Information at BW
We use your information to operate and provide you with the websites and other services. This includes, but is not limited to:
a. For the purposes for which you provided it;
b. Authenticating your login;
c. Personalizing your experience on our websites;
d. Customizing and delivering information about our products and services by email;
e. To contact you with information, surveys, or advertising that we believe may be of interest to you regarding us or our websites;
f. To administer contests and surveys;
g. Providing customer support and sending confirmations about your Account, if an Account has been created;
h. For internal research and reporting;
i. Protecting our intellectual property or other rights; and
j. Managing and improving our business and our websites.
We also reserve the right to use and disclose non-personal data (e.g., de-identified or aggregate data) for any purpose. For example, we show aggregate performance measures to users to allow them view popular images or current comments.
3. Legal Basis For Use Of Your Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:
• To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them.
• Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent. Where you have provided consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing your consent. To withdraw your consent, please contact us at email@example.com.
• Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as:
o Providing a safe and enjoyable user experience;
o Customer service;
o Protecting our users, personnel, and property;
o Analyzing and improving our business; and
o Managing legal issues.
• Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
4. When We Share Your Personal Information With Third Parties
We may share your personal data only in the following ways:
a. Service providers and agents
We may share your information with our corporate affiliates, such as entities under common ownership or control.
c. Business transfers
d. Compliance with legal requests, and protection of our rights
We may disclose your information when we have a good faith belief we are required to do so by law, or in response to a subpoena, court order, or other legal mechanism. We may also disclose your information when we have a good faith belief that disclosure may prevent fraud or abuse of BW or its users or protect our property rights.
We may disclose your information when we believe we have your consent to do so, such as when you contact customer support, ask us about your Account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the device associated with your Account.
5. Online Analytics And Tailored Advertising
We may use third-party web analytics services on our websites, such as Google Analytics. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyze how users use the website, including by noting the third-party website from which you arrive, how often you use our app, the events that occur within our app, where the app was downloaded from, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the website. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by visiting https://tools.google.com/dlpage/gaoptout.
If you receive email from us, we may use certain tools such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications.
We may personalize the content and advertising that you see when using the website through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on our website and mobile application, as well as other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into BW, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
6. Data Subject Rights And Your Choices
a. Account Review
You may access, review, correct, and delete certain of your personal data by logging into your Account, if an Account has been created. Not every BW website allows users to create an Account.
b. Analytics and Advertising
You also can exercise certain opt-out rights by following the instructions at the end of the “Online Analytics and Tailored Advertising” section above.
c. Your Legal Rights
In addition, individuals in the European Union and some other jurisdictions outside the United States have certain legal rights to request that we:
• confirm whether we hold personal data about them,
• provide access to personal data we hold about them (including, in some cases, in portable form),
• update, amend and/or correct personal data we hold;
• delete certain personal data in appropriate circumstances;
• transfer personal data to a third party provider of services;
To exercise any of the above rights (or any other rights under applicable law), please contact us at firstname.lastname@example.org.
In addition to the rights above, residents of the European Economic Area also have the right to lodge a complaint with your relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
You can opt out of receiving marketing emails by following the unsubscribe instructions included in each email. Please note you may not opt out of certain transactional emails, such as when we email you to address Account issues or communicate about customer support.
7. Retention Of Personal Data And Security
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
We have implemented and maintain security practices to protect against the unauthorized access, use, modification, destruction or disclosure of your personal data. For example, when you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. However, no method of transmission or storage is completely secure, and we therefore cannot guarantee absolute security. If you have any questions about security on our website(s), please contact us using the contact information below.
8. Outside The United States Consent To Processing And Transfer Of Information
If you access our website(s) outside of the United States, you fully understand and unambiguously consent to the transfer of your personal data to, and the collection and processing of such personal data in the United States. The recipients of the personal data disclosures described in the “When We Share Your Personal Data with Third Parties” section above may be located in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate.
9. Additional Information
a. Links To Third Party Websites
Our website includes links to other sites that may collect personal data, and whose privacy practices may differ from those of BW. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to review their privacy policies.
b. Social Media Widgets
Our website may include social media features, such as Facebook and Twitter buttons. Such features may collect your IP address and information about the page you are visiting and may set cookies to function properly. Your interactions with these features are governed by the privacy policies of the company providing them.
BW websites are not directed to children. BW encourages all parents and guardians to instruct their children in the safe and responsible use of personal information on the Internet. As appropriate under applicable law, parents or legal guardians with questions or requests regarding their children’s personal data may contact us as described below. We define child/children (kid/kids) as individuals who are not of legal age to consent to the collection and processing of their personal information. For most areas of the world, those are individuals under 13. In the European Economic Area (EEA), they are individuals under 16. We adhere to local definitions of “children” for the Services located in jurisdictions where the age is different.
11. Change Policy
12. Contact Information
If you have questions or comments about our privacy practices, how your Personal Information has been used, or if you would like to correct or update Personal Information that you have provided to us, you may contact us at email@example.com.