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Luna Market Inc. D.B.A. Insomnia Labs Privacy Policy
Effective: September 1, 2024
Luna Market Inc. D.B.A Insomnia Labs (“Luna Market,” “we” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at creatorfi.finance (the “Site”) and online services (collectively, the “Service”).
Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
Information You Provide Us.
We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, social media, 3rd party platform connection, blockchain addresses, Luna Market password when you create an account to log in to our network (“Account”).
If you use our Services on your mobile device, we may collect your phone number and the unique device id number.
Our Service lets you store preferences like how your content is displayed, your location, safe search settings, notification settings, and favorite widgets. We may associate these choices with your ID, browser or mobile device, and you can edit these preferences at any time.
When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, blockchain address, and other requested information if you contact us via e-mail regarding support for the Services.
We may also collect Personal Data at other points in our Service that state that Personal Data is being collected.
Information Collected via Technology. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Information Collected by Our Servers. To make our Service more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, blockchain address, wallet type, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Service. This type of information is collected to make the Service more useful to you and to tailor the experience with us to meet your special interests and needs.
Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Service. This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Service. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at the address given in paragraph (1).
Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Service. These third party companies may supply us with Personal Data. We may add this to the information we have already collected from you via our Service in order to improve it. We do not collect Personal Data automatically, but we may tie the information that we collect automatically to Personal Data about you that we collect from other sources or that you provide to us.
Use of Your Personal Data
General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
Facilitate the creation of and secure your Account on our network;
Identify you as a user in our system;
Provide improved administration of our Service;
Provide the Services you request, including but not limited to facilitating facilitating loan matching with qualified lenders
Improve the quality of experience when you interact with our Service;
Send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
Protect you and other users from any conduct that violates the Terms of Use or to prevent abuse or harassment of any user;
Display your username
send you administrative e-mail notifications, such as security or support and maintenance advisories;
send you e-mail notifications related to actions on Service, including notifications of offers on your digital assets;
respond to your inquiries related to employment opportunities or other requests;
make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
in any other way we may describe when you provide the Personal Data; and
send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Luna Market.
We may use your Personal Data to contact you about our own and third parties’ goods and services that may be of interest to you.
Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Service; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Luna Market.
Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
As Legally Required. Regardless of any choices you make regarding your Personal Data (as described below), Luna Market may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Luna Market; (c) to protect or defend the rights or property of Luna Market or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
Other Disclosures. We may also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent. We do not sell your Personal Data.
Third Party Websites. Our Service may contain links to third party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data or Anonymous Data from you. You may also find marketplaces powered by the Service on other websites. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
Email Communications. We will periodically send you free, opt-in newsletters and e-mails that directly promote the use of our Service. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information in paragraph (1)). Despite your indicated e-mail preferences, we may send you occasional service related communications, including notices of updates to our Terms of Use or Privacy Policy.
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the address given in paragraph (1).
Data Access and Control. You can view, access, edit, or delete your personal data for many aspects of the Service via your account settings page. You can also make choices about Luna Market's use of your data. You can always choose whether you want to receive marketing communications from us. You can also opt out from receiving marketing communications from us by using the opt-out link on the communication, or by visiting your account settings page. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Data Access. You can access your Personal Data on your account settings page.
Data Portability. You can request a copy of your Personal Data by contacting us here and including "Please send me my Personal Data" in the subject line. Luna Market will verify your ability to access that email, then send you a digital export of the data we hold that is associated with your email address. We will use reasonable efforts to respond to your request within 7 days, but in all events within 28 days of our receipt of the request.
Data Erasure. You can delete your Personal Data on your account settings page. Alternatively, you may request that Luna Market delete your personal data by contacting us at data and including "Please delete my Personal Data" in the subject line. Luna Market will verify your ability to access that email, then delete the Personal Data associated with your email address. We will use reasonable efforts to respond to your request within 7 days, but in all events within 28 days of our receipt of the request.
Data Correction. You can modify your Personal Data on your account settings page.
Data Retention. We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. You can ask to close your account by contacting us as described above, and we will delete your Personal Data on request. We may, however, retain Personal Data for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.
Data Protection. We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our website. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Luna Market and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at the address indicated in Section 1 above.
A Note to Users Outside of the United States. If you are a non-U.S. user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at creatorfi.finance/privacy-policy. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Service and this Privacy Policy to check for any changes.
13. Additional Notice to California Residents
In accordance with the California Consumer Privacy Act (the “CCPA”), the following table summarizes our personal information collection, use, and sharing practices in the preceding twelve (12) months since we last updated this Privacy Policy.
Personal Identifiers & Contact Information
Examples: Name, username, password, email address, customer number, IP address, unique device ID, tracking technologies (e.g., pixel tags, cookies) to collect usage information
Business Purpose(s) for Which Information is Used: (i) Maintaining and servicing Accounts (ii) Processing and fulfilling orders and transactions (iii) Register you as a customer or a candidate (iv) Process and deliver or accept services (v) Notify you about changes to our terms and conditions of use or privacy policies (vi) Request that you write a review or take a survey (vii) Administer and protect our business website (viii) Deliver relevant Website content and advertisements and measure or understand the effectiveness of the advertising (ix) Make suggestions and recommendations about services that may interest you (x) Respond to inquiries through the Website and (xi) Verify and respond to consumer requests
Categories of Sources from Which Information Received: Users of our Website, App, or Services
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that that need access to such information to perform services for us (ii) Data analytics providers and (iii) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes.
Internet Activity & Technical Data
Examples: Domain information, pages visited, cookie information, session information (such as time spent on certain pages and page interaction information), date and time of your visit, webpages visited, links clicked, browser ID, browser type, device ID, operating system, form information downloaded, domain name from which our site was accessed, and cookies
Business Purpose(s) for Which Information is Used: (i) Improve the Website experience for all visitors (ii) Understand the demographics of our Website visitors (iii) Operate and maintaining the Website (iv) Detect security incidents (v) Debug to identify and repair errors that impair existing intended functionality of the Website (vi) Protect against malicious or illegal activity and prosecuting those responsible and (vii) Verify and responding to consumer requests
Categories of Sources from Which Information Collected: Users of our Website, App, or Services and the devices or browsers they used
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that that need access to such information to perform services for us and (ii) Data analytics providers
Geolocation Data
Examples: IP Address
Business Purpose(s) for Which Information is Used: (i) Improve the Website experience for all visitors (ii) Understand the demographics of our Website visitors (iii) Detect security incidents (iv) Debug to identify and repair errors that impair existing intended functionality of the Website (v) Protect against malicious or illegal activity and prosecuting those responsible and (vi) Verify and responding to consumer requests
Categories of Sources from Which Information Received: Users of our Website, App, or Services and the devices or browsers they used
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that that need access to such information to perform services for us and (ii) Data analytics providers
Financial Data
Examples: Card number
Business Purpose(s) for Which Information is Used: (i) Manage payments, fees, and charges and (ii) Collect and recover funds
Categories of Sources from Which Information Received: Users of our Website, App, or Services
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, third-party payment processors, and service providers that that need access to such information to perform services for us (ii) Data analytics providers and (iii) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes
Transaction Data
Examples: Details about your payment and details about the services you considered, purchased or provided
Business Purpose(s) for Which Information is Used: (i) Manage payments, fees, and charges and (ii) Collect and recover funds
Categories of Sources from Which Information Received: Users of our Website, App, or Services
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, third-party payment processors, and service providers that that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes (iii) Data analytics providers and (iv) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes
Profile Data
Examples: Username, email address, password, purchases, orders, customer interests, customer preferences, customer feedback, and survey responses
Business Purpose(s) for Which Information is Used: (i) Notify you about changes to our terms and conditions of use and privacy policy (ii) Request that you write a review or take a survey (iii) Deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising and (iv) Make suggestions and recommendations about services that may interest you
Categories of Sources from Which Information Received: Users of our Website, App, or Services
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes (iii) Data analytics providers and (iv) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes
Usage Data
Examples: Information about how you use our Website, App, or Services
Business Purpose(s) for Which Information is Used: (i) Deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising and (ii) To use data analytics to improve of website, product/services, marketing, and customer relationships
Categories of Sources from Which Information Received: Users of our Website, App, or Services and the devices or browsers they used
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes and (iii) Data analytics providers
Marketing and Communications Data
Examples: Your preferences in receiving marketing from Luna Market and your communication preferences
Business Purpose(s) for Which Information is Used: (i) Manage payments, fees, and charges (ii) Collect and recover funds and (iii) Notify you about changes to our terms and conditions of use and privacy policy (iv) Request that you write a review or take a survey and (v) Deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising
Categories of Sources from Which Information Received: Users of our Website, App, or Services and the devices or browsers they used
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes and (iii) Data analytics providers
We do not knowingly sell or otherwise disclose the PII or PI of minors under 16.
Choices for Access, Deletion, Opt-Out of Sale, and Right to Non-Discrimination for California Residents or As Required by Law:
If you are a California resident, you have the right to know what personal information we collect, disclose, and “sell” about you (as that term is defined in the CCPA). Additionally, you have the right to access, delete and opt out from the “sale” of your personal information.
Your Rights:
Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
Right to Opt-Out. The right to opt-out of the sale of your personal information to third parties (Note: we do NOT sell your personal information to third parties.);
The right to designate an authorized agent to submit one of the above requests on your behalf; and
The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.
To exercise these privacy rights and choices, please follow the instructions below:
How to Request That We Identify or Provide You Access to Personal Information: You may request that we identify or provide you access to your personal information twice in a 12-month period. To do so, please email us at privacy@creatorfi.finance. In response to a request to identify your personal information, we will identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months. In response to a request to access your personal information, we will produce an “Access Report” detailing the personal information we have collected, disclosed, and/or sold about you. This Access Report will be delivered by mail or electronically at your request.
How to Request Deletion of Personal Information: You may request that Luna Market delete the personal information it has collected and/or maintained about you. To do so, please email us at: privacy@creatorfi.finance. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.
How to Opt-Out of the Sale of Personal Information: We do not sell, share, or rent your personal information in any way.
Verification:
Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an Account with us, we will verify your identity through existing authentication practices for the Account (e.g., login and password). If you are not a registered Website, App, or Services user, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.
Questions; Contacting Luna Market; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address: 71 Broadway, Suite 14L New York, NY 10006.
If you are resident in the EU, you should know that, in operating our products and services on behalf of our customers, Bipath operates as a processor only, and is not a controller in relation to any personal information processed about you. Therefore, Bipath cannot respond to requests to exercise rights under data protection laws – these should be directed to our customers.
What information we collect, how we collect it and why
Customer Content
Customer Content consists of the communications that are sent through the use of Bipath products and services, like the body of a text message or phone call.
We may collect Customer Content in connection with your use of our products or services. For example, if you use our messaging services, we collect the messages being sent and received so that we can convey those messages to and from the carrier networks and surface the content in your customer portal and in our API. Similarly, to transmit voice calls to and from the telecommunications carrier networks, we have to collect the voice communications being sent and received to route them appropriately, and then surface that information in our portal and our API. You can also use our products and services to record voice communications or have them transcribed, in which case, we will also collect those voice recordings or transcriptions.
If you are using our tracking code on your website, we also collect on your behalf the information about the visitors to your website such as their IP address, their landing page, referring URL, and the online ads that led them to your website. The tracking code uses cookies to identify the visitors to your websites so that the tracking code can display the correct tracking number to your end users and associate phone, form, or text activity to the correct website visit.
If you are using caller ID services that we offer through a sub processor, we will collect information about your end users such as the caller’s name, phone number, and the city in which the phone number is registered (not available in all countries or for all phone numbers). In addition, Customers can enable our premium caller ID service which uses one of our sub processors to collect address and other demographic information about an end user, such as marital status and occupation.
As stated above, Customers have the control over which information they want to collect and what they are doing with that information. We provide the tools to collect the information. So, if you are an end user of one of our Customers and you believe that your information is being collected by them, you should check out their terms of service and privacy policy to find out how they collect, use, store, and share your information. We are not responsible for our Customers’ privacy policies or privacy practices.
You should not use Bipath products or services to receive, send, or otherwise process Personal Health Information (PHI) as defined by the Health Insurance Portability and Accountability Act of 1996 as amended (HIPAA), unless you have a Business Associate Agreement (BAA) with Bipath or your use case for Bipath products and services does not require a BAA. Bipath disclaims all liability for PHI sent, received, or processed through Bipath products or services without a Business Associate Agreement.
What we use your information for
Generally, we use all the information that you provide to us or that we collect to provide our products and services to you, to deliver your communications to their intended destination, to provide reporting on your communication programs in your customer portal, to analyze our customers’ use of our products and services, to improve our products and services, and to detect fraudulent or unlawful activity in connection with Bipath accounts.
Below are some additional details regarding how we use categories of information we collect.
Customer Content.
We use Customer Content for the purposes of including it in your reporting in your customer portal or through the API, conveying it to and from telecommunications carrier networks, or recording and transcribing it per your instruction. We may also use Customer Content stored on our systems to troubleshoot issues such as call quality concerns.
Promotional emails.
We will use your email address to send you information about other Bipath products, services, or events that you might be interested in. If we are required to do so by applicable law, we will obtain your prior consent before marketing to you.
You can choose not to receive marketing emails from Bipath at any time. If you wish to stop receiving Bipath marketing emails you may click on the unsubscribe link that will appear at the bottom of any Bipath marketing emails or you can contact customer support.
We will use publicly-available Customer Account Data about your company, such as your industry, the size of your company, and your company’s website URL, to help us understand our customer base better and to tailor information we send you about other Bipath products, services, or events.
If you provide us with a physical address in order to obtain a number for which Bipath is required to have your physical address on file, we’ll use that address so that we can confirm we can allow you to have that number. We may also check the physical address you provide and/or your billing address, as well as other information you provide or that we obtained from your use of our service about your identity such as your name, email address, and IP address, with our fraud prevention and identity validation providers (to confirm you have provided us with accurate details). We may also use your address information to calculate taxes. We may also have to share these addresses with the telecommunications provider from whom Bipath obtained the phone number or local authorities upon their request. Unless prohibited from doing so by law, we’ll let you know if we have to share your address information like this.
We use your payment information so we can bill you and be paid for your use of our products and services.
Who we may share your information with
Unless you give us your permission, we won’t share your Customer Content, Customer Account Data, or Customer Usage Data with third parties, except as described below:
Cloud Communication Providers and Telephony operators as necessary for proper routing and connectivity. Customer Content and certain Customer Usage Data is shared with and received from communication providers and telephony operators to the extent necessary to route and connect those communications from the sender to the intended recipient. How those providers and telephony operators handle your Customer Content and Customer Usage Data is generally determined by those operators’ own policies and local regulations.
Third-party service providers or consultants. We may share your information stored on our systems with third-party service providers or consultants who need access to the information to perform their work on Bipath behalf, like sharing relevant Customer Account Data with our payment processor so it can process payments on our behalf, or our storage provider for storing your information on our behalf. These third-party service providers are limited to only accessing or using this information to provide services to us and must provide reasonable assurances that they will appropriately safeguard the information.
Compliance with Laws. We may disclose your information stored on our systems to a third party if (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to obtain legal advice; (iii) to enforce our agreements and policies, (iv) to protect the security or integrity of the Bipath Site or our services and products, (v) to protect ourselves, our other customers, or the public from harm or illegal activities, or (vi) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If Bipath is required by law to disclose any of your information that directly identifies you, then we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, subpoena or court or administrative order. Further, we object to requests that we do not believe were issued properly.
Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, customer information we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of Bipath may continue to use your information as set forth in this notice.
We do not share your information (including, but not limited to, the personal information of your end users) with third parties for their direct marketing purposes, unless you give us your consent to do so.
International Operations and Transfers Out of the EEA and Switzerland
Please note that when you use our customer portal, or our other products and services, your Customer Content, Customer Account Data, or Customer Usage Data may be sent to the United States and possibly other countries. Some, but not all of this, may be in connection with routing your communications that are sent via our products and services in the most efficient way. We store customer information on servers located in the United States, and we may also store this information on servers and equipment in other countries.
We take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests, and that transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end, where appropriate to do so (e.g. because our customer is established in the EU), we enter into appropriate data transfer agreements incorporating the EU Commission approved standard contractual clauses, or rely on other mechanisms provided for by data protection law. You have a right to ask our customers for more information about the safeguards they have in place to ensure the adequate protection of transferred information.