Enhanced Privacy Notice
Bscly (“Company,” “Bscly” “we,” “us”) respects your privacy and understands that you care about your personal information and how it is used. We value your trust in sharing your personal information with us and strive to protect your privacy, as further described in this Enhanced Privacy Notice. Our basic Privacy Policy is on our website.
COOKIE NOTICE
We and our service providers and third-party partners, including vendors, use cookies, web beacons and other technologies on our website (“Site”) to collect information that helps us provide you with our service. A “cookie” is a small text file that is placed on your computer or other Internet-connected device to uniquely identify you or to store information in the browser. A “web beacon” links web pages to servers and may be used to transmit information collected through cookies back to a web server.
Different types of Cookies
First-party cookies are ones that Bscly places (or has a service provider place for us), which enable you to use the Site and its features to the fullest extent and allow us to perform certain internal analytics activities. Third-party cookies are placed by certain third parties when you visit the Site. These third-party cookies enable certain functionalities to be provided on the Site. These third parties may collect and use this information pursuant to their own privacy policies.
Some cookies are essential to the Site in order make our Site work correctly and are, therefore, deemed strictly necessary. You may block placement of these cookies through your browser settings, but without them, the performance of the Site may be adversely affected, and you may not be able to take full advantage of our services and features. These cookies may also be used to assist in fraud prevention, security, and to enable purchasing capabilities.
If you access the Site using a mobile, tablet or other internet enabled device, functionality cookies and similar technologies may collect a unique identifier assigned to a device (“UDID”), geolocation data or other traffic information for that device. These features help us improve your experience with the Site. For example, functionality cookies help us improve your visit to the Site by determining the appropriate device location during a session or storing language settings.
We and our service providers also use analytics cookies and similar technologies to collect information about your use of the Site to help create reports and statistics on the performance of the Site, which enable us to improve the way they work. Analytics cookies and similar technologies collect information such as your IP address, type of device, operating system, referring URLs, country information data and time of page visits, and pages visited. This information allows us to identify overall patterns of usage on the website, and help us record any difficulties you have with the Site.
INFORMATION COLLECTED FROM COOKIES
We use the information we collect to allow you access and use our Site and for the following general purposes:
– Protect our Networks: Cookies and similar technologies help us identify and prevent threats to our Site. They are necessary to protect your information and our business from outside threats.
– Allow you to Access our Site: Cookies and similar technologies permit your connection to our Site: our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, other software or hardware information, and your geographic location.
– Access Usage of Site: We use information about your usage of our Site, such as pages you have visited and search queries you have run, to assess how our Site is used.
In addition, third parties that support our Site by providing other services, such as allowing tracking aggregate service usage, may also use cookies and other technologies to collect information relevant to the provision of those services. For more information on how third parties use cookies and similar technologies on our Site, please see the section below on How Third Parties Use Information from Cookies and Similar Technologies on our Site.
THIRD-PARTY USE OF COOKIES
We work with third parties that provide services to support our Site, such as Google Analytics. We may not have access to these cookies, although we have access to statistical information arising from the cookies provided to customize the Site and for other purposes as set forth here and in our other policies. These companies may also transfer this information to other parties where required to do so by law, or where such other parties process the information on their behalf.
Please note that Bscly does not control third-party cookies and their use is likely governed by the privacy notices or policies of the third parties employing them, which are not covered by Bscly’s policies.
YOU HAVE A RIGHT TO MANAGE COOKIES
You have choices regarding cookies and can opt out of them entirely. However, without cookies, you may not be able to use all of the features of our Site. Similarly, if you upgrade or change your browser or device or delete your cookies, you may need to use these opt-out tools again.
– Managing Cookies Via Your Browser Settings
You opt out of cookies at any time by selecting the appropriate settings in your browser. Most browsers will tell you how to change your browser settings to notify you when a cookie is being set or updated, or to restrict or block certain types or all cookies. Please visit www.allaboutcookies.org, or select the “Help” menu in your browser. If you use different devices to view and access our Site you will need to adjust your cookie options in the browser on each device.
– Managing Analytics Cookies
To opt out of Google Analytics cookies click here https://tools.google.com/dlpage/gaoptout
– Do Not Track
The Site does not process or respond to “Do Not Track” signals, since uniform standards for “Do Not Track” signals have not been adopted. To learn more about “Do Not Track”, please visit https://allaboutdnt.com
CHANGES TO THIS COOKIE NOTICE
From time to time, we may change this Cookie Notice to reflect changes to our privacy practices and our Site. This may be related to changes in the law, changes in our Site or treatment of your personal information. Where necessary, we will notify you of these changes. We will always display clearly when the Cookie Notice was last amended.
For California Residents
CALIFORNIA PRIVACY RIGHTS
California Shine the Light Law
Subject to certain limitations, California residents may ask us to provide them with (1) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. To make this request, California residents may contact us as at help@bscly.com or by writing to us at 184 Kent Avenue #C405, Brooklyn, NY 11249. Please indicate “CA Privacy Rights” in the subject field of your request.
California Consumer Privacy Protection Act
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Site. This notice supplements the information in our Privacy Notice above. Certain terms used below have the meanings given to them in the CCPA. The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information by the Site:
– Categories of Personal Information We Collect About You
• The categories of personal information we may have collected about you or your use of our Site are:
• Identifiers, such as your contact information (name, email address, postal address, phone number), government identifiers (national identifier, passport number) or unique personal identifiers (cookies, IP address);
• Internet or other network or device activity, such as browsing history, browser type and language, operating system or usage;
Geo-location information, such as city and state associated with a unique identifier.
More details on the categories of personal information we may collect are set forth in our Privacy Policy in the footer of our website.
– Business or Commercial Purposes for Which We Collected or Disclosed the Personal Information
The business or commercial purposes, as defined under the CCPA, for which we collected or sold the personal information, are:
• performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services;
• auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• debugging to identify and repair errors that impair existing intended functionality;
• undertaking internal research for technological development and demonstration; and to advance the commercial or economic interests of the Company, such as by inducing another to subscribe to or provide information or services, or enabling or effecting, directly or indirectly, a commercial transaction.
More details concerning the business or commercial purposes are set forth in our Privacy Policy at the footer of our website. We may disclose the categories of personal information about our California consumers for our operational purposes where the use of such personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.
We share any or all of the personal information collected from and about you over the past twelve (12) months with our data analytics providers for various business purposes.
California Consumer Privacy Rights and Choices
California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:
The right to access and disclosure. You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you during the past 12 months:
• the categories and specific pieces of personal information we have collected about you;
• the categories of sources from which we collected the personal information;
• the business or commercial purpose for which we collected or sold the personal information;
• the categories of third parties with whom we shared the personal information; and
• the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
The right to deletion. You may have the right to request that we delete the personal information we have collected from you. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
How to exercise your access and deletion rights. California residents may exercise their California privacy rights by submitting your to help@bscly.com, indicating “CA Privacy Rights” in the subject field of your email. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, you may need to provide your name and email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.
Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:
Where you have requested the categories of personal information that we have collected about you, we will provide such list in a written email to the email address you provide.
Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.
Where you have requested that we delete personal information that we have collected from you, we will delete, deidentify, or aggregate, as appropriate, any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.
The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
Authorized Agents. You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
FOR EUROPEAN UNION/EEA USERS
The EU General Data Protection Regulation (GDPR) provides certain rights regarding the processing of personal data of EU/EEA data subjects. This section of the Privacy Notice applies if you are in a country that is a Member of the European Union or EEA, and supplements the information in the Privacy Notice.
Bscly is the data controller for the processing of your personal data, as defined under the GDPR, collected by the Company from visitors to www.bscly.one (the “Site”).
LEGAL BASIS FOR DATA PROCESSING
We collect and process your personal data for the purposes set out in the Privacy Policy in the footer of our website and for the reasons set forth here. Our legal basis to process personal data includes processing that is: (1) necessary to comply with legal requirements (for example, where we have a legal or regulatory obligation or to defend claims); and/or (2) necessary for our legitimate interests (for example, to improve our Site).
EU/EEA DATA SUBJECT RIGHTS
Where we process your personal data, you have a number of rights related to how the data is processed and can exercise these rights at any point in time. You can exercise these rights by emailing us at help@bscly.com, and indicating “GDPR Request” in the subject line.
The right to access and rectification. You have the right to access, correct and update your personal data at any time.
The right to object to or restrict processing. Under certain circumstances, you have the right to object to or restrict our processing of your personal data. For example, where we process personal data based on our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data. However, you have an absolute right to object to our processing of your personal data for direct marketing purposes, and no exception applies to such a request.
The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with the relevant Supervisory Authority about how we process your personal data.
The right to erasure. Under certain circumstances, you have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.
The right to data portability. With respect to the personal data you have provided to us, in addition to the general right of access described above, you may have, subject to certain exceptions, rights to (i) receive a copy of it in a structured, commonly used and machine-readable format, (ii) transmit the data to another data controller, and (iii) depending on the circumstances, have us perform that transmission.
RETENTION OF PERSONAL DATA
We will keep your personal data for as long as we need it to fulfull the purposes for which the personal data was collected, or while there is a legitimate reason for doing so, and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.
INTERNATIONAL DATA TRANSFERS
Personal data of our EEA users may be transferred outside the EEA to countries that may not have data protection rules that require the same level of protection, but we will make sure that there are appropriate mechanisms and controls in place to protect your data. This may include data transfer agreements, a copy of which you can obtain by emailing us at help@bscly.com; we rely on the recipient’s participation in the EU-U.S. Privacy Shield program. We use these data transfer mechanisms – and not consent – as the legal basis for our own transfers of personal data from within the EEA to outside the EEA (even when other aspects of our handling of personal data take place on the basis of consent).
Effective May, 2020