Effective/Last Updated: May 25, 2018
- Privacy Philosophies
Although our business and social network community have unique services and offerings, they share a similar privacy philosophy. BNI follows these privacy principles in our conduct in the collection, use, release and security of Information both online and offline:
- Providing you with NOTICE of our information practices.
- Giving you with CHOICES about how your data will be used.
- Providing you with the opportunity to UPDATE or CORRECT your personal information.
- Using information SECURITY
- Limiting the SHARING of your information.
- Committing to COMPLYING with applicable privacy requirements.
- Providing you with means to CONTACT US about privacy-related issues.
- Information We Collect About You
- General. In order to better provide you with the products and services offered on the Site, we collect two types of information about our users: personally identifiable information and aggregate information.
Personally identifiable information refers to information that lets us know the specifics of who you are. When you engage in certain activities on our Site, such as purchasing a product, submitting content and/or posting content on any of our blogs, or sending us feedback, we may ask you to provide certain information about yourself. Examples of personally identifiable information may include your first and last name, email address, mailing address, telephone numbers, age group, gender and other identifying information. When setting up your profile on our Site, you may be asked to provide an e- mail address, phone number, and address.
Aggregate information refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site, and what other sites may have directed you to us. This information, which is collected in a variety of different ways, is compiled and analyzed on both a personal and an aggregated basis. This technology enables us to determine (i) your IP Address of your computer and its geographic location from installing the applications onto your computer, mobile device or through your GPS of your mobile device; (ii) your search terms or interactive behavior via BNI’s websites; (iii) your purchasing behavior; (iv) source of the information sought by you during your search; and (v) the age of your results data (collectively, “Shared Information”). We may use the information you provide in aggregate form for internal business purposes, such as generating statistics and developing marketing plans.
- Other Information You Provide. We may also collect and store any personal information you enter on our Site or provide to us in some other manner, including personal information that may be contained in any comment you post to our Site. This includes identifying information, such as your name, address, e-mail address, and telephone number (if provided and applicable); your likeness (both still and moving); and, if you transact business with us or our partner, limited financial information such as your payment method (valid credit card number, type, expiration date or other financial information).
- Information About Others. We may also collect and store personal information about other people provided to us by users, potentially including their businesses, contact details including email addresses and/or IP addresses. This data is used in the legitimate interests of providing information to potential members, for the purposes of generating invitations to Chapter meetings and other BNI events, and for the provision of certain other information related to the potential purchase of goods or services from BNI.
- Sweepstakes and Contests. When BNI offers sweepstakes or contests, personal information is collected with the sole purpose of notifying you if you win the sweepstakes or contest.
- Automatic Collection of Data. Information concerning your computer hardware and software is automatically collected and may be shared with other BNI or affiliated websites. This information may include: your IP address, browser type and language, domain names, access times, referring website addresses and the content of any undeleted cookies that your browser previously accepted from us (see “Cookies” below). BNI uses this information to maintain the quality of its service and to provide general statistics about website visitors.
- Cookies. When you visit our Site, we may use one or more “Cookies” to make our Site easier for you to use and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our Site, such as the web pages you visit, the links you click, and the amount of time you spend on the website. You can remove or block cookies using your settings in most browsers, but if you choose to decline cookies, you may not be able to sign in or use some of the features offered on our Site.
- Other Technologies. We may use the ever-evolving Internet technology, such as web beacons and other similar technologies, to track your use of our Site. We also may include web beacons in company e-mail messages, newsletters, or notifications to determine whether messages have been opened and/or acted upon. This enables us to customize the services we offer our Site visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
- Information Collected By Third Parties. We may allow third parties, including advertising companies, and ad networks, to display advertisements on our Site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our Site does not provide any personal information to these third parties. This information may allow them to deliver targeted advertisements and gauge their effectiveness. If you have questions or concerns about this, please email our DPO at email@example.com.
- Storage and Transfer of Personally Identifiable Information. BNI may store and process in the United States or any other country in which BNI or its affiliates, subsidiaries, or agents maintain data facilities.
- How We Use the Information We Collect
- General. We will primarily use your personally identifiable information to provide support or service offerings to you. Specifically, BNI collects and uses your personal information in order to:
- operate the Site and to deliver the services that you have requested;
- manage your account and provide you with customer support;
- perform research and analysis about your use of (personal and aggregate), or interest in, our products, services, or content, or products, services or content offered by others; this information may be used, by way of example only, to help us understand the demographics of potential members, identify chapters with openings for certain professions, inform future marketing campaigns, and judge the success of marketing strategies;
- cross market your services/products with our services and our affiliates’ services;
- verify your eligibility and deliver online and/or offline in connection with contests and sweepstakes;
- enforce our terms and conditions;
- manage our business;
- enable and leverage applications such as BNI Connect to provide user functionality; and
- perform functions as otherwise described to you at the time of collection.
- General. We will primarily use your personally identifiable information to provide support or service offerings to you. Specifically, BNI collects and uses your personal information in order to:
When you join BNI or visit a BNI-related website, we will not collect any personally identifiable information about you unless you choose to provide such information to us. You agree that when you provide your personal identifiable information to us, BNI and its affiliated BNI franchisees may use your information to promote you and BNI. We want your information and preferences to be accurate and complete. You may request access to any personal information and preferences that you have provided to us and correct, modify or update such information and/or preferences by sending an email with your request to firstname.lastname@example.org.
The collection of your e-mail address and name if and when requested during account registration enables BNI and its affiliates to send you any requested newsletter(s) or to send you any requested mailings or offers. If applicable, you will be allowed to indicate upon registration that you are or are not interested in receiving offers or information from our partners and/or us and we may occasionally send you e-mails regarding product and event information or promotions. Only BNI and its affiliates will send you these solicitations, and only if you have previously not indicated that you do not wish to receive them. If applicable and you prefer not to receive such e-mails, please opt out or otherwise do not opt-in to receive these e-mails. If applicable, you may opt-out of receiving e- mails from BNI when you register within your account settings at our Site.
BNI provides links to send e-mail messages to our Site for your convenience and your e-mail address is used so that our Site may reply to your inquiry. BNI tracks the pages on our Site that our users visit in order to determine which areas of the website are the most popular. This data is used to deliver customized content and advertising within our Site to customers whose behavior indicates that they are interested in a particular subject area.
The vast majority of data collection from our visitors is used to assess the type of people visiting that website and to determine what content is most frequently accessed by those visitors. This information helps BNI improve its websites by offering content that more specifically meets the interests of our Site visitors.
- Financial Information. If BNI collects your financial information, it may use your financial information or payment method to process payment for any purchases, subscriptions or sales made on our Site, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
- Data Retention
Your data will only be retained for as long as necessary to fulfil the purposes for which it was obtained. For members of BNI, at a minimum this will be for the duration of your membership and likely longer depending upon applicable laws, rules and regulations. For non-members of BNI, this will be for the duration needed to align with your engagement with us, such as, by way of example only, to enable us to send invitations to Chapter meetings, for maintaining subscriptions to email newsletters, or for the duration of your participation in one of our core groups prior to Chapter launch. Please see our Data Retention Policy, accessible at http://bnitos.com/retention.html for more information.
- With Whom We Share Your Information
- General. We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our Site or while using our services.
- Personally Identifiable Information. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared.
- We may share your personal information with:
- Authorized Service Providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include processing credit card payments, delivering products and services, providing customer service and marketing assistance, performing business and sales analysis, supporting our Sites’ functionality, and supporting other features and promotions offered through our Site. We will only provide these service providers with the limited information that they need to provide us with such services, including limited access to personal information needed to perform their functions. However, they are not permitted to share or use such information for any other purposes. When you enter into transactions with others or make payments on our Site, we will either (a) link you to a third party who handles the transaction outside of our Site, or (b) share transaction information with only those third parties necessary to complete the transaction. We will require those third parties to agree to respect the privacy of your information.
- Business partners: From time to time, we may offer promotions, sweepstakes or third-party offerings on our Site. If and when you make purchases, engage in these services and/or products, offered through our Site or our services, we may share personal information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant’s offer or program, you consent to us to providing your email address and other information to that merchant. You have the right to withdraw your consent at any time by emailing us at email@example.com.
- Franchisees: We may share your personal information with BNI Master Franchisees or (Sub)franchisees of BNI, who are joint controllers of data (“Data Controller”) with our affiliate BNI Worldwide Development Limited, in order to, by way of example, direct you to a BNI Chapter (whether Franchisee-owned or company-owned) or potentially provide you with additional information about franchise opportunities based on your interest. As joint Data Controllers, Master Franchisees and (Sub)franchisees have separate obligations for implementing appropriate technical and organizational measures to ensure and to demonstrate that their processing activities are compliant with the requirements of the European Union’s General Data Protection Regulation (“GDPR” or the “Regulation”).
- Other Situations. We also may also disclose your information:
- In response to a subpoena, court order, or other requests for cooperation from a law enforcement or other government agency (including civil and criminal matters); to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion. This may include respecting requests from jurisdictions outside of the United States if we have a good faith belief that response is required by law under the local laws in that jurisdiction, apply to users from that jurisdiction, and are consistent with generally accepted international standards. We may also share information when we have a good faith belief it is necessary to prevent illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our Terms of Service, accessible at https://www.bni.com/terms-and-conditions. This may include sharing information with other companies, lawyers, courts or other government entities where applicable.
- To protect and defend the rights or property of BNI or one of BNI’s referral networks; and, act under exigent circumstances to protect the personal safety of members and users of BNI, its websites, or the public.
- Aggregated and non-personal information. We may share aggregated and non- personal information we collect. We may also share it with third parties to develop and deliver targeted advertising on our Site and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. This information does not contain any personal information and may be used to develop services that we hope you and other users will enjoy using.
- About User-Generated-Content
We do not screen, filter or monitor user submissions to our Site, nor do we scrape or glean personal information from any such submissions to the extent that any comment or other user submission contains personal information (including name, likeness, email address, whether such information pertains to the submitter or someone else), such personal information may be viewed by authorized users of our Site with whom you have shared that information, subject to our Terms of Service. We do not gain access to any of your personal content, and only use “meta” information to enable the successful operation of our service. (See “User Submissions” below).
- Third-Party Websites
Your Data Protection Rights and Accessing Your Information under GDPR
Because our affiliate BNI Worldwide Development Limited is established in Ireland, we will be governed by the GDPR. This means that we are going to be working continuously to ensure that we are satisfying our obligations under the Regulation. You can review and update your personal information and exercise your other rights by contacting us. More information about how to contact us is provided below.
- You have the right to be provided on request with a copy of your personal data.
- You have the right to rectification of inaccurate data we may have recorded about you.
- You have the right to the erasure of your data (“Right to be Forgotten”) which we no longer have justification for recording.
- You have the right to object to processing of your data which is being done on the basis of our legitimate interests.
- You have the right to refuse to be contacted for direct marketing purposes.
- You have the right to restrict the processing of your personal data when:
- the basis for its processing is in dispute;
- its accuracy is in dispute;
- we cannot establish a lawful basis for its processing, but you do not wish it to be erased;
- we no longer need your data, but you need it for the establishment, exercise, or defense of legal claims;
- you object, where applicable, to our processing your data on the basis of our legitimate interests, pending verification of whether our interests override.
- You have the right to be provided with a copy of your data in machine readable format, or to have it transferred directly to another data controller (“Data Portability”).
- Your Choices About Collection and Use of Your Information
- You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Site because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Site.
- When you enter your information on our Site you may be given a choice or otherwise allowed to indicate whether you want to receive email notifications and/or newsletters. If applicable, at any time you can choose to stop receiving notification emails through the link at the bottom of the notification emails; and commercial or promotional emails or newsletters from us by clicking on the link at the bottom of any of our emails. You will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party (such as a credit card processing partner or an event provider) before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
- Protecting Your Personal Information
We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized BNI employees, contractors and certain third party service providers are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your sensitive personal information between your system and ours. There are risks inherent in sharing information, and though we provide some privacy settings for information that you share, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of any person with whom you share your information, and cannot guarantee that only authorized recipients will view your information. We cannot control the actions of other users with whom you share your information. We cannot guarantee that only authorized persons will view your information. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. We are not responsible for third party circumvention of any of our privacy settings or security measures. Please be careful and conscientious with whom you share your videos and choose a strong password that you do not use for other services. For information about how to protect yourself against identity theft, please refer to the Federal Trade Commission’s website at www.ftc.gov/bcp/menus/consumer/data.shtml.
- Communities and Forums Offered on our Site
Any personally identifiable information or personally sensitive data that you disclose through our Site, or other online forums hosted on our Site, may be collected and used by others. We recommend caution when giving out personal information to others in these online forums. We encourage you to review the privacy statements of websites you choose to visit via hyper-links posted on our Site so that you can understand how those websites collect, use and share your information. BNI is not responsible for the privacy policies or other content on third-party websites accessed through its websites.
- User Submissions
We may provide areas on our Site where you can post information about yourself, including your name and email address, communicate with others; upload content; and post comments. Such postings are governed by our Terms of Service. Also, whenever you voluntarily disclose personal information on our Site, that information will be available and can be collected and used by others who have authorized access to your content. We encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information.
- Children’s Privacy
Our Site is a general audience site, and we do not knowingly collect personal information from children under the age of 13. Our Site is not intended for use by children. You may access our Site only if you are of legal age to lawfully form a binding contract. If you are under the age of 18 and do not have a parent’s or legal guardian’s permission to use our Site, you may not access our Site or use any services. If you are 13 years of age or older, then you can only use our Site and services with the consent of your parent or legal guardian.
- Transfers of Personal Data Outside of Europe
- The global extent of BNI’s business necessitates the transfer of data to its franchisees and times members on a worldwide basis. Some countries to which we transfer your data have not been designated by the European Commission as having at a national level an adequate level of data protection. In these cases, we rely on (a) Privacy Shield, and (b) Commission-approved standard contractual clauses (“SCC”) with our franchisees to safeguard your data.
- Privacy Shield
For transfers out of the EU and Switzerland and to the United States of America, BNI Global, LLC has self-certified that it complies with the EU-US and Swiss-US Privacy Shield Framework as prescribed by the US Department of Commerce regarding the retention, use, collection, and notice principles. BNI additionally adheres to the Privacy Shield Framework recommendations pertaining to the transfer of information to third parties, access, security, data integrity and purpose limitation and enforcement. Additional information on the Privacy Shield Program can be viewed at https://www.privacyshield.gov.The Federal Trade Commission (FTC) has jurisdiction over BNI’s compliance with the Privacy Shield. BNI will annually renew its Privacy Shield certification to help ensure the treatment of all personal data continues to be accurate and processed in accordance with the Privacy Shield Framework and applicable Principles. In cases of onward transfer to third parties of EU and Swiss Personal Data received pursuant to the EU-US and Swiss-US Privacy Shield Framework, BNI is potentially liable. All questions or complaints regarding the processing and use of personal data should be directed to firstname.lastname@example.org.
BNI has elected JAMS as its independent dispute resolution mechanism in accordance with requirements set forth by Privacy Shield. If questions or complaints are not resolved satisfactorily through contacting BNI, users can file a complaint with JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with BNI and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority (DPA) and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
- No Rights of Third Parties
- How to Contact Us
BNI Worldwide Development Ltd
Phone: +353 94 902 1553
BNI’s Data Protection Officer can be contacted at the above address or phone number, or by email at email@example.com.
If you are not satisfied with our responses or are otherwise concerned with how we process your personal data, you have the right to make a complaint to our supervisory authority, Ireland’s Data Protection Commissioner – www.dataprotection.ie.
©2018 BNI Global LLC. All rights reserved.