otherwise changed from time to time (the “Privacy
Policy”), explains the manner in which BPB
Technology LLC (“BPB”,
"we", "us", "our") collects, uses, maintains
and discloses user information obtained through the BPB.com website (the “Site”). BPB
is the data controller of your Personal Data.
By using the Site, you ("User") consent to the data
collection and use practices, the features on the Site, or advances in
will be prominently posted on the Site. Capitalized terms not defined herein
shall have the meanings ascribed to them in the User Agreement
does not conver any information that we may receive
about you through channels external to BPB.
We collect Personal Data and
Anonymous Data, as described below.
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.
Data” means data that is not associated with or linked to your
Personal Data; Anonymous Data does not, by itself, permit the identification of
● We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, date of birth, government issued identification, photographs, biometric information (including but not limited to device fingerprinting), company name, and password when you use our Site.
● We may also collect other Personal Data provided by third party identity verification services or via social networking websites.
● If you tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
● 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 when seeking support services, such as email, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.
● We may collect other data, including but not limited to, referral URLs, your location, blockchain analytics information related to blockchain addresses you provide.
Some information is collected
automatically by our servers:
● 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, and/or a date/time stamp for your visit.
● 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 retain information on your behalf, such as transactional data and other session data linked to your Account.
When you register for or otherwise
use our Services, we may receive information about your criminal convictions
which we perform certain verification or compliance checks. We carry out these
checks in order to detect or prevent any unlawful or fraudulent acts and to
comply with our legal obligations.
Where we need to collect personal
data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we
have or are trying to enter with you. In this case, we may have to close your Account but we will notify you if this is the case at the
We will only use your Personal Data
when the law allows us to. Most commonly, we will use your Personal Data in the
● Where we need to perform the contract we are about to enter into or have entered into with you;
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
● Where we need to comply with a legal or regulatory obligation.
Please note that we may process your
personal data without your knowledge or consent where this is required or
permitted by law.
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 and perform identity verification through a service provider;
● provide improved administration of our Site and Services;
● improve the quality of experience when you interact with our Site and Services;
● send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
● send you administrative e-mail notifications, such as account activity, transaction processing, security or support and maintenance advisories;
● identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
● notify you about important changes to our Terms; and
● respond to your inquiries related to employment opportunities or other requests.
All data collected automatically
will be used to administer or improve our services.
● We use IP address to make our Site and Services more useful to you, and to perform identity verification.
● 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 Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
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 Site navigation. We reserve the right to use Anonymous Data and
aggregated and other de-identified information for any purpose and disclose
Anonymous Data to third parties in our sole discretion.
BPB does not sell user data to
any third party.
We provide you with choices
regarding certain Personal Data that BPB uses,
particularly around marketing and advertising. We have established the
following personal data control mechanisms:
We may use your Personal Data to
determine what may be of interest to you. This is how we decide which products,
services, and offers may be relevant for you.
By using our Services or requesting
information from us, you opt-in to receive marketing communications, except in
Vermont customers can opt-in to
receive promotional offers by contacting us.
We will obtain your express consent
(opt-in) before we share your Personal Data with any company outside of the BPB group for that company's own marketing purposes.
You can ask us or third parties to
stop sending you marketing messages at any time by following the opt-out links
on any marketing message sent to you or by contacting us.
We disclose your Personal Data as
● It may be necessary to disclose your information to law enforcement agencies, regulators, government/public officials, or other relevant third parties to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of BPB, our users, or the public.
● We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to verify your identity; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by us.
BPB may contain links to other third party websites which are regulated by their own
privacy policies. BPB is not responsible for the
privacy policies of these third party websites even if
they were accessed using the links from our Site.
Other than as stated in this Privacy
Policy, BPB does not disclose any of your
personal information to third parties unless required to do so by law
enforcement, court order, or in compliance with legal reporting obligations.
We share your Personal Data within
the BPB group of companies which are based in
various locations globally. If you are based in Europe, this will involve
transferring your data outside the European Economic Area (EEA)
In addition, many of our external
third parties are also based outside of the EEA so their processing of your
Personal Data will involve a transfer of data outside the EEA.
Whenever we transfer your Personal
Data out of the EEA, we ensure a similar degree of protection is afforded to it
by ensuring at least one of the following safeguards is implemented:
● We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
● We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
● In respect of transfers to entities in the US, we may transfer Personal Data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want
further information on the specific mechanism used by us when transferring your
Personal Data out of the EEA.
You can update your information by contacting support and making a request.
We will retain your information for
as long as your Account has not been closed or as needed to provide you access
to your Account. If you wish to close your Account, open a ticket in our
support center. We will retain and use your information as necessary to comply
with our legal obligations, resolve disputes, and enforce our Terms.
We collect web browser Information
in order to enhance your experience on our Site and track how the Services are
being used. Cookies are small data files that are stored on your computer’s
hard drive, and in addition to using cookies to provide you with a better user
information collected can include, but is not limited to, your IP address,
referral URLs, the type of device you use, your operating system, the type of
browser you use, geographic location, and other session data. Cookies are not
permanent and will expire after a short time period of inactivity. You may opt
to deactivate your cookies, but it is important to note that you may not be
able to access or use some features of our site. Please note that BPB is not responsible or can be held liable for any
loss resulting from your decision or inability to use such features. For more
Do Not Track ("DNT") is an optional browser setting that allows you to
express your preferences regarding tracking by advertisers and other third-parties. At this time, we do
not respond to DNT signals.
We take the protection of your
personal information seriously. We use industry-standard data encryption
technology and have implemented restrictions related to the storage of and the
ability to access your personal information. BPB
servers and business operations are entirely located in the United States.
Please note that no transmission
over the Internet or method of electronic storage can be guaranteed to be 100%
Under certain circumstances, you
have rights under data protection laws in relation to your Personal Data which
are set out in more detail below:
If you wish to exercise any of the
rights set out above, please contact us
You will not have to pay a fee to
access your Personal Data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these
We may need to request specific
information from you to help us confirm your identity and ensure your rights to
access your Personal Data (or to exercise any of your other rights). This is a
security measure to ensure that Personal Data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
We try to respond to all legitimate
requests within one month. Occasionally it may take us longer than a month if
your request is particularly complex or you have made a
number of requests. In this case, we will notify you and keep you
Unfortunately, if you're under 18,
you can't use our Services. We do not knowingly solicit or collect information
from anyone under 18. If we become aware that a person under the age of 18 has
provided us with personal information, we'll delete it immediately.
If you have any questions about our
For Vermont customers:
In accordance with Vermont law, BPB will not share your non-public personal financial
information with nonaffiliated third parties, except as required or permitted
by law, or if you specifically consent to the disclosure. In addition, BPB will not share credit reports with third parties,
including affiliates, except with your express consent.