Global Privacy Notice
Effective Date: September 1, 2021
Blueshift Technology, Inc., headquartered in the U.S., (“Blueshift”, “we”, “us” and “our”) are committed to protecting the privacy of individuals who interact with us, such as our website visitors, customers, business partners, leads and prospects, recipients of marketing communications, end users and event attendees (“you” and “your”). This Privacy Notice generally explains the different ways in which Blueshift collects, uses and shares personal information when:
- You visit, interact with or use any of our websites, social media pages, Blueshift mobile apps (where linked to this Privacy Notice), online advertisements, marketing or sales communications (our “online Properties”);
- You visit, interact with or use any of our offices, events, sales, marketing and other offline activities (our “offline Properties”); and
- You purchase and use Blueshift products and services (including mobile apps) that have been deployed by one of our business customers, such as your employer (our “Services”).
When we mean to refer to any combination of the above, we use the term “Properties”.
This Notice does not generally cover the personal information we automatically collect in connection with your use of the Blueshift Services. For further details regarding the information collected and used by Blueshift in connection with the provision of the Services, see the Blueshift Products and Services Notice.
In connection with the provision of specific Properties, Blueshift may provide additional “just-in-time” disclosures or additional information about our data collection, use and sharing practices. These notices may supplement this Privacy Notice or clarify Blueshift’s privacy practices in the circumstances described or may provide you with additional choices about how Blueshift processes your data.
If you have any questions about this Privacy Notice, please contact us at email@example.com.
PART I: WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT
“Personal information” is information that identifies an individual or relates to an identifiable individual. Blueshift and third party service providers collect personal information and other information from various sources which generally fall into the following categories:
- Information you provide to us through your interactions with us and your use of the Properties
- Information we automatically collect from you in connection with your use of online Properties (see the Blueshift Products and Services Notice for information we automatically collect in connection with the Services)
- Information from third party sources and affiliated companies
We may combine information from these different sources for the purposes set forth in this Privacy Notice.
Information We Collect From You
We will collect personal information when you voluntarily provide it to us (including to our service providers or other parties who collect it on our behalf). For example, we collect personal information when you order, register for (or to use) or request information about Blueshift products, services or apps, subscribe to marketing communications, request support, complete surveys, provide in product feedback, or sign up for a Blueshift event or webinar. We may also collect personal information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact customer support.
The personal information we collect may include contact information (such as your name, address, telephone number or email address), professional information (such as your employer name, address, job title, department or job role), user IDs and passwords, photographs for security purposes, and contact preferences. We also collect information you choose to provide to us when requesting information or completing any ‘free text’ boxes in our forms (for example, for event sign-up, product feedback or survey requests), or the nature of your request or communication. In addition, we may collect personal information disclosed by you on message boards, chat features, blogs and other services or platforms to which you are able to post information and materials (including third party services and platforms). We also may record our telephone or other communications with you, to the extent permitted by applicable law.
When making a purchase from Blueshift, we may also collect billing and transactional information.
Information We Automatically Collect
We automatically collect certain information when you use, access or interact with our online Properties, including our online advertisements or marketing communications. This information does not necessarily reveal your identity directly but may include unique identification numbers and other information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer), your Internet Protocol (IP) address/MAC address/device identifier, device event information (such as crashes, system activity and hardware settings, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data that uniquely identifies your browser. We may also collect information about how your device has interacted with our online Properties, such as the pages accessed and other statistical information.
In connection with your organization’s deployment of certain Services, Blueshift may automatically collect information in relation to your use of the Services. See the Blueshift Products and Services Notice for more information regarding the types of data collected and used in connection with Blueshift’s provision of the Services.
If you are an individual user of Blueshift Services and you require more information regarding our data collection practices for Services deployed by your organization, please contact your IT administrator.
Information from Third-Party Sources and Affiliated Companies
From time to time, we may obtain information about you from third party sources unless prohibited by applicable law, such as public databases, resellers and channel partners, marketing partners, social media platforms, event organizers or other publicly available information.
Examples of the information we may receive from other sources include: name, address, telephone number, office location, approximate location (based on reverse IP lookup), account information, job role and publicly available employment profile, service and support information, information about your product or service interests or preferences, browsing habits, page-view information from some business partners with which we operate co-branded services or joint offerings, and credit history information from credit bureaus. We may use this information in conjunction with your contact details, professional information and Blueshift transaction history for the purposes set forth in this Privacy Notice, such as, for example, improving the accuracy of our records, better understanding you and your preferences, providing relevant marketing and support, and detecting and preventing fraud.
PART II: HOW WE USE YOUR INFORMATION
Blueshift uses personal information it collects for the following purposes (unless otherwise restricted by applicable law). For information on how Blueshift shares personal information, see Part III.
Communicate, Respond to Requests and Engage In/Process Transactions
Blueshift may use personal information to communicate with you, respond to your requests or provide information requested by you. Blueshift may also use personal information, including financial, credit card and payment information, to process your transactions.
Facilitate the Delivery of the Service and Account Administration
Blueshift may use personal information to provide you with the Services, to manage your account, and to communicate with you about your use of our Services. This may include managing product downloads, updates and fixes, providing support and recommendations, and sending other administrative or account-related communications, including release notes. Blueshift will also use personal information to facilitate the delivery of the Services and this may include tracking entitlements, verifying compliance, controlling access to the Service, and maintaining the security and operational integrity of the Blueshift IT infrastructure and our Services. See the Blueshift Products and Services Notice for details regarding the information Blueshift collects in connection with your use of the Services and in order to operate the Service.
Facilitate and Evaluate Use of the Online Properties
Blueshift may use personal information to provide you with the online Properties, to facilitate your use of the online Properties (such as facilitating navigation and the login process, preserving information between sessions and enhancing security), to improve quality, to evaluate page response rates and personalize and determine content.
Improve our Properties
Blueshift uses personal information and other data Blueshift collects from you to better understand our customers, users and website visitors and the way they use and interact with the Properties, including their user experience. Blueshift uses this information to provide a personalized experience, to implement the preferences you request, to improve quality and reliability, to diagnose issues with and improve the Properties and related user experiences, and to make recommendations.
Improve the Accuracy of our Records
We may use the personal information we receive from you or third parties to better understand you and/or maintain and improve the accuracy of the records we hold about you.
Blueshift uses personal information and other data Blueshift collects from you, in combination with other data we may have, in order to provide you with support in relation to our Properties.
Blueshift may use personal information to post testimonials on its Online Properties. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You can request your testimonial be updated or deleted at any time by sending a request with your name, testimonial location and contact information.
Blueshift will use information it obtains from you, your interactions with Blueshift over time and across the Properties, and from third party sources to provide you with marketing and promotional communications, to deliver targeted and relevant advertising and marketing to you, to determine the effectiveness of our marketing and promotional campaigns, to better understand you and your preferences, and to position and promote our products and services. Our marketing will be conducted in accordance with your advertising / marketing preferences and as permitted by applicable law.
Blueshift may use personal information to help monitor, prevent and detect fraud, enhance security, monitor and verify identity or access, and combat spam or other malware or security risks.
Quality Control and Training
Blueshift may use or access personal data for the purposes of quality control related to the Properties and staff training.
Third Party Social Networks
Conferences and Events
Blueshift and our partners may use personal information to communicate with you about our events or our partner events. After the event, Blueshift may contact you about the event and related products and services, and may share information about your attendance with your company and our conference sponsors and partners, where legally permitted to do so. If a partner or conference sponsor directly requests your personal information at their conference booths or presentations, your personal information will be handled in accordance with their privacy practices. We recommend that you review the privacy practices of such partners and sponsors.
Provide Online Communities and Blogs
We may use personal information and other information disclosed by you on our message boards, chat features, blogs and other services or platforms to which you are able to post information and materials for the purposes of providing you and our customers with a forum to discuss Blueshift Properties, responding to your request, providing you with support, improving our Properties or any other purposes set forth in this Privacy Notice. Any information that is disclosed in those forums becomes public information and may therefore appear in public ways, such as through search engines or other publicly available platforms, and may be “crawled” or searched by third parties. It could also be read, collected or used by other users to send you unsolicited messages. Please do not post any information that you do not want to reveal to the public at large.
Education and Training
If you sign up for a Blueshift certification course or seminar, Blueshift will use your personal information to facilitate the delivery of such course or seminar. To the extent your organization has paid for your certification course or seminar, Blueshift may provide the status of your course or seminar to your organization upon notice to you.
Protect Our Employees and Facilities
Blueshift may use personal information as necessary to protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our sites, you may be photographed or videotaped as part of maintaining the security of such sites.
Other Legitimate Business Purposes
We may use your personal information when it is necessary for other legitimate purposes such as protecting Blueshift’s confidential and proprietary information.
PART III: HOW WE SHARE YOUR INFORMATION
We take care to allow your personal information to be accessed only by those who really need access in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We may share personal information about you with third parties in the following circumstances.
We may share your information with third parties, such as vendors, consultants, agents and other service providers who work on our behalf. Examples include vendors and service providers who provide assistance with marketing, billing, processing credit card payments, data analysis and insight, hosting, technical support and customer service. Unless described in this Privacy Notice or one of our other privacy notices, we do not share, sell, rent, or trade any of your personal information with third parties for their own promotional purposes.
We may provide your information to our channel partners, such as distributors and resellers, and to other business partners, to fulfill product and information requests, to effectively deliver unified support, and to provide customers and prospective customers with information about Blueshift and its products and services. From time to time, Blueshift may engage in joint sales or product promotions with selected business partners. If you purchase or specifically express interest in a jointly-offered product, promotion or service, we may share relevant personal information with those partners.
You should note that Blueshift does not control our business partners’ use of such information. Our partners are responsible for managing their own use of the personal information collected in these circumstances, including providing information to you about how they use your personal information. We recommend you review the privacy policies of the relevant partner to find out more about their handling of your personal information.
We may disclose information to any party where we believe it necessary in order to protect the vital interests of any person.
Compliance with laws or any competent law enforcement body, regulatory body, government agency, court or third party: We may disclose information where we believe disclosure is necessary or required (i) by law or regulation, in order to comply with legal process or government requests (including in response to public authorities to meet national security or law enforcement requirements); or (ii) to exercise, establish or defend our legal rights.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization or similar event. We will inform any buyer that your information shall only be used in accordance with this Privacy Notice.
With Your Consent
We may disclose your personal information for any other purpose with your consent.
PART IV: INTERNATIONAL TRANSFERS OF INFORMATION
Personal information, including personal information collected in the European Economic Area (“EEA”) or Switzerland, may be transferred, stored and processed by us and our services providers, partners and affiliates in the United States and potentially other countries whose data protection laws may be different to the laws of your country, for example to Canada, The Philippines, Singapore, India, Australia and Israel. Some of these countries are not deemed ‘adequate’ by the European Commission. We will protect your personal information in accordance with this Privacy Notice wherever it is processed and will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws. These steps include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information. In relation to Blueshift’s role as a processor of customer content, our Binding Corporate Rules will apply to any transfers of personal data.
Blueshift complies with the US-EU and US-Swiss Privacy Shield Framework regarding the collection, use, and retention of personal information from individuals in the European Union member countries and Switzerland. Blueshift has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Privacy Principles shall govern.
Blueshift is responsible for the processing of personal data it receives under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Blueshift complies with the Privacy Shield Principles for all onward transfers of personal data from the European Union and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Blueshift is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Blueshift commits to endeavor to promptly resolve complaints about privacy and collection or use of personal information (See ‘How to Contact Us” for contact details).
Under certain conditions, more fully described on the Privacy Shield website here, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
PART V: SECURITY AND CONFIDENTIALITY
Blueshift maintains (and requires its service providers to maintain) appropriate organizational and technical measures designed to protect the security and confidentiality of any personal information we process. For example, Blueshift employs physical access controls, encryption, Internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. Blueshift staff who may have access to personal information are required to keep that information confidential. However, no security procedures or protocols are ever guaranteed to be 100% secure and so we encourage you to take care when disclosing personal information online and to use readily available tools, such as Internet firewalls, anti-virus and anti-spyware software, and similar technologies to protect yourself online.
PART VI: YOUR PRIVACY RIGHTS AND CHOICES
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it and the purposes for which it is used.
However, we will normally collect personal information from you only, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some very rare cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time, or upon request, what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
PART VII: OTHER INFORMATION
How Long we Retain Your Information: We will retain personal information we collect from you where we have a justifiable business need to do so and/or for as long as is needed to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, legal, accounting or other purposes). You can request deletion of your personal information at any time (see “Your Privacy Rights and Choices” section for further information) and we will consider your request in accordance with applicable laws.
When we have no justifiable business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Our Properties are not directed to individuals under the age of 16. We do not knowingly collect personal information from such individuals. If you become aware that a child has provided us with personal information, please contact us at firstname.lastname@example.org. If we become aware that a child under the age of 14 has provided us with personal information, we will take steps to delete such information.
Automated Decision Making
We do not employ solely automated decision-making, as a matter of course, that results in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you. Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review. If you are to be subject to automated decision making, we will make it clear at the time and you have the right to contest the decision, to express your point of view, and to require a human review of the decision.
External Links and Social Media Features
Do Not Track
Some Internet browsers—like Internet Explorer, Firefox, and Safari—include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our online Properties do not currently process or respond to “DNT” signals. Blueshift takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. To learn more about “DNT”, please visit “All About Do Not Track”.
Changes to this Privacy Notice
Blueshift will review and update this Privacy Notice periodically in response to changing legal, technical and business developments. When we update this Privacy Notice we will note the date of its most recent revision above. If we make material changes to this Privacy Notice, we will take appropriate measures to inform you in a manner that is consistent with the significance of the changes we make and is in accordance with applicable law. We encourage you to review this Privacy Notice frequently to be informed of how Blueshift is protecting your information.
PART IX: HOW TO CONTACT US
If you have any questions or concerns regarding this Privacy Notice, you may write to us at email@example.com.