Bigtincan Mobile Pty Ltd
ABN 72 152 604 003 (“Bigtincan”) of
Level 6, 338 Pitt Street, Sydney New South Wales, Australia 2000
Last Modified: September 6, 2018
1. The Information We Collect And Store
We may collect and store the following information when running the Bigtincan Service:
Information You Provide. When you register an account, we collect some personal information, such as your name, phone number, credit card or other billing information, email address and home and business postal addresses. You may also ask us to import your contacts by giving us access to your third-party services (for example, your email account) or to use your social networking information if you give us access to your account on social network connection services. You may also provide us with your contacts’ email addresses when sharing folders or files with them. We may also receive Personal Information (for example, your email address) through other users, for example, if they have tried to share something with you.
Files. We collect and store the files you upload, download, or access with the Bigtincan Service (“Files”). If you add a file to your Bigtincan Hub that has been previously uploaded by you or another user, we may associate all or a portion of the previous file with your account rather than storing a duplicate.
Log Data. When you use the Service, we automatically record information from your Device, its software, and your activity using the Services. This may include the Device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your Files, and other interactions with the Service.
2. How We Use Personal Information
Personal Information. In the course of using the Service, we may collect personal information that can be used to contact or identify you (“Personal Information”). Personal Information is or may be used: (i) to provide and improve our Service, (ii) to administer your use of the Service, (iii) to better understand your needs and interests, (iv) to personalize and improve your experience, and (v) to provide or offer software updates and product announcements. If you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in any of those communications, or update your account settings information.
Geo-Location Information. Some Devices allow applications to access real-time location-based information (for example, GPS). Our mobile apps do not collect such information from your mobile device at any time while you download or use our mobile apps as of the date this policy went into effect but may do so in the future with your consent to improve our Services. Some photos and videos you place in Bigtincan Hub may contain recorded location information. We may use this information to optimize your experience. If you do not wish to share files embedded with your geo-location information with us, please do not upload them. If you don’t want to store location data in your photos or videos, please consult the documentation for your camera to turn off that feature. Also, some of the information we collect from a Device, for example IP address, can sometimes be used to approximate a Device’s location.
Analytics. We also collect some information (ourselves or using third party services) using logging, such as IP address, which can sometimes be correlated with Personal Information. We use this information for the above purposes and to monitor and analyze use of the Service, for the Service’s technical administration, to increase our Service’s functionality and user-friendliness, and to verify users have the authorization needed for the Service to process their requests.
3. Information Sharing and Disclosure
Your Use. Any information you choose to provide should reflect how much you want others to know about you. Please consider carefully what information you disclose and your desired level of anonymity. We do not sell your personal information to third parties. We may also share or disclose your information with your consent, for example, if you use a third-party application to access your account (see below). Through certain features of the Service, you may also have the ability to make some of your information public. Public information may be broadly and quickly disseminated.
Compliance with Laws and Law Enforcement Requests; Protection of Bigtincan’s Rights. We may disclose to parties outside Bigtincan Hub files stored in your Bigtincan Hub and information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of Bigtincan Hub or its users; or (d) to protect Bigtincan’s property rights. If we provide your Bigtincan Hub files to a law enforcement agency as set forth above, we will remove Bigtincan’s encryption from the files before providing them to law enforcement. However, Bigtincan will not be able to decrypt any files that you encrypted prior to storing them on Bigtincan Hub.
Non-private or Non-Personal Information. We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of our Service.
4. Changing or Deleting Your Information
If you are a registered user, you may review, update, correct or delete the Personal Information provided in your registration or account profile by changing your “account settings.” If your personally identifiable information changes, or if you no longer desire our service, you may update or delete it by making the change on your account settings. In some cases we may retain copies of your information if required by law. For questions about your Personal Information on our Service, please contact info@Bigtincan.com. We will respond to your inquiry within 30 days.
5. Data Retention
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, you may delete your account by contacting us at info@Bigtincan.com. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we do not delete from our servers files that you have in common with other users.
6. Bigtincan Community
Our Service offers publicly accessible community services such as blogs, forums, and wikis. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. For questions about your Personal Information on our Service, please contact firstname.lastname@example.org.
Our Site includes links to other Web sites whose privacy practices may differ from those of Bigtincan. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.
The security of your information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security, you can contact us at email@example.com.
8. Our Policy Toward Children
Our Services are not directed to persons under 16. We do not knowingly collect personally identifiable information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@Bigtincan.com. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information from our files.
While Bigtincan applies the same level of care to its customers around the world, Bigtincan also complies with the European Union’s General Data Protection Regulation (“GDPR”), which went into effect on May 25, 2018. Specifically, Bigtincan complies with the GDPR requirements by providing its customers with full knowledge of what data is transferred from a customer environment and how Bigtincan encrypts the data, whether it is in transit or at rest, ensuring in accordance with the GDPR that the data would be unintelligible to any person who is not authorized to access it. As a data processor of data provided by our customers, you can learn more about how Bigtincan treats data and complies with the GDPR by reviewing our Data Processing Addendum which is available upon request from Bigtincan. We offer our customers a Data Processing Addendum (DPA), which incorporates the EU Standard Contractual Clauses (“SCCs,” also known as the EU Model Clauses) and include Bigtincan’s organizational measures. The SCCs are a valid and recognized legal mechanism for ensuring that any personal data leaving the European Economic Area will be transferred in compliance with EU data-protection laws. Bigtincan continues to maintain the operational processes necessary to meet the stringent SCC requirements for the transfer of personal data to processors, which in turn allows us to provide our customers with contractual guarantees for the protection of their personal data. Bigtincan offers a DPA that includes GDPR-specific language to ensure that Bigtincan and our customers have appropriate GDPR-specific contractual provisions in place to allow for the legal transfer of personal data.
If you have questions regarding either of these statements or to obtain additional documentation, you may view our website or contact us at gdpr@Bigtincan.com.
10. Contacting Us
Privacy Notice for California Residents
Effective Date: January 1, 2020
Last Reviewed on: February 15, 2020
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Bigtincan’s website, https://www.bigtincan.com/ (“Website”), has collected the following categories of personal information from its consumers in California within the last twelve (12) months:
|A. Identifiers.||Name, email address, telephone number, Internet Protocol address.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, email address, telephone number.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of Bigtincan products or services considered on our website.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Bigtincan obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete.
- Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information or ask a question about our products or services, we will use that personal information to respond to your inquiry.
- To provide, support, personalize, and develop our Website, products, and services.
- To process your information requests.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
Bigtincan will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Bigtincan may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers.
- Data aggregators.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
[Category A: Identifiers.]
[Category B: California Customer Records personal information categories.]
[Category D: Commercial information.]
[Category F: Internet or other similar network activity.]
[Category G: Geolocation data.]
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Data aggregators
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Bigtincan disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, providing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Bigtincan delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal, regulatory or other governmental obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Phone: (617) 981-7557
- Email: firstname.lastname@example.org
- Physical Address: Bigtincan Mobile Pty Ltd, Level 6, 338 Pitt Street, Sydney, New South Wales, Australia 2000.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at:
Attn: Bigtincan Privacy officer
Phone: (617) 981-7557
Address: Bigtincan Mobile Pty Ltd, Level 6, 338 Pitt Street, Sydney, New South Wales, Australia 2000
Changes to Our Privacy Notice
Bigtincan reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Phone: (617) 981-7557
Bigtincan Mobile Pty Ltd
Attn: Legal – Global Privacy Officer
Level 6, 338 Pitt Street, Sydney, New South Wales, Australia 2000