FOR VISITORS, PLATFORM USERS, AND END USERS
Last Updated: April 1, 2019
1. To explain important disclosures about the way we use information that you share with us as Visitors, Platform Users, and End Users.
2. To ensure that you understand what information we collect with your permission, and what we do and, most importantly, do not do with that information.
3. To hold us accountable for protecting your rights and your privacy under this policy.
Highlights of what you’re consenting to:
2. The transfer of your information outside of the country where you live.
For purposes of this policy:
“Personal Data” for non-residents of the European Economic Area means any information that can be used to identify, contact, or precisely locate a person, including name, email, address, and telephone number.
“Personal Data” for residents of the European Economic Area means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes IP address and advertising ID (IDFA/AAID).
“Non-Personal Data” means information not included in the definition of Personal Data, such as pages or ads visited, time spent on pages, browser and device type, and referring and exit pages. For non-residents of the European Economic Area, IP address and advertising IDs (IDFA/AAID) are Non-Personal Data.
“Legal basis” means your data are handled according to the following legal provisions:
1. With regard to data communicated in forms, etc. with your consent
2. With regard to services you use for the performance of a contract,
3. Otherwise, with particular regard to statistical data and online identifiers based on legitimate interests as below
“Legitimate interests” means when handling your data, we pursue the following legitimate interests:
1. Improving our service
2. Protecting against misuse
“Data sources” means unless otherwise specified, we obtain the data from you (including via devices used by you).
Information We Collect/Receive and How We Use that Information
In general, there are three categories of information we collect: (1) information that we can use to provide additional features and improved experiences if you choose to share that information; (2) information that we must have for you to use the Bonzai Services; and (3) information collected from your interaction with the Bonzai Services as an End User of a digital advertisement (hereinafter referred to as “ad” or “ads”).
When you provide Personal Data directly to us, this information is used by Bonzai solely for the purposes identified at the point you provide it. Information we collect may be transferred, stored, used, and/or processed as follows:
Contact Information. When you contact us through the “Contact Us” page on the Website or become a Platform User of the Bonzai Services, you will be asked to provide us with certain Personal Data about yourself which may include your name, email address, job title, name of your company, company location, company type, role, company size, telephone number, and any other information that you may voluntarily wish to disclose.
Consistent with any permissions you may have communicated to us, we may use this information to directly communicate with you for marketing and promotional purposes via emails, notifications, or other messages, and to communicate with you for research purposes including via emails, notifications, or other messages. Platform Users may also receive communications concerning Bonzai product updates, training sessions, or events or webinars. If you want to stop receiving such materials from Bonzai, you follow the unsubscribe instructions at the bottom of each email.
Billing Information. In certain circumstances, to use the Bonzai Services, you may be required to provide additional information which may include, registered business address, contact no and email id of account representative(“Billing Information”). Bonzai uses this information to process payments.
III. User Activity Data. In an ongoing effort to improve the Website and the Bonzai Services, we automatically collect certain information when Visitors visit the Website and when Platform Users use the Bonzai Services (collectively, the “User Activity Data”). This information may include IP address, browser and device type and language, referring and exit pages and URLs, date and time, amount of time spend on pages, what sections of the Website Visitors visit, and other, similar aggregate user data concerning your use of the Website and the Bonzai Services.
We may use this data to manage and improve your experience using the Website and the Bonzai Services. In some areas of the world, certain User Activity Data may be Personal Data. Where this is the case, we comply with applicable laws regarding our use and processing of Personal Data.
Ad Interaction Data. When End Users interact with ads generated using the Bonzai Services, we may collect information on behalf of Bonzai’s customers which may be the advertiser, publisher, advertising agency, and/or their agents. Data collected through interaction with the Bonzai Services may include time spent viewing an ad, page views, video views, number of ads clicked, IP address, device ID, GPS coordinates, advertising identifiers (IDFA/AAID), Personal Data that you affirmatively elect to share with us through text field forms, and other information about your interaction with the ads (“Ad Interaction Data”).
With respect to End User data, Bonzai is acting as a “Data Processor” on behalf of our customers, which may include the advertiser, publisher, and/or their agents who are the Data Controller of your data who may use this information for their lawful advertising purposes to provide you with a more tailored online advertising experience. We may also use the information internally to improve the functionality of the Bonzai Services.
Sharing and Disclosure of your Personal Data
We may share your information at your direction or as described below at the time of sharing.
1. Customers. We share Ad Interaction Data with our customers who may use this information for their lawful advertising purposes to provide you with a more personalized online advertising experience.
2. Third-Party Service Providers. Bonzai may share your information with Third-Party Service Providers that support us in delivering the Bonzai Services to our customers. We may also share your information with companies that help us operate and market the Bonzai Services, such as to bill our customers, analyze our Website Visitors, provide customer and technical support, database, analytics, and hosting services, and other operational support. We ensure that such service providers are contractually required to protect your Personal Data at all times.
III. Safety and Compliance with the Law. Bonzai may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law.
2. Other. Bonzai may also may disclose your information under circumstances not mentioned here with prior consent of the person or third-party that submitted the information to us.
Retention of information
Further, Bonzai will delete your contact information and financial information from its active databases upon request made by you via email at firstname.lastname@example.org. Such information will be deleted as soon as reasonably possible in accordance with its policies and applicable law. However, Bonzai shall retain your Information, which shall not be visible to other users or visitors, to be used in certain circumstances including, but not limited to, resolve disputes, troubleshoot problems, enforce the Bonzai Terms and Conditions and as required by applicable law. Please note that some Information is never completely removed and/or deleted from Bonzai’s databases due to technical and legal constraints, including stored backup systems and archives. In the light of the above, it is not possible for your Information to be completely removed and/or deleted from the Bonzai’s databases in response to Your requests.
In some areas of the world, cookies and other identifiers may be Personal Data. Where this is the case, we comply with applicable laws regarding our use and processing of Personal Data. Except in the case of residents of the European Economic Area, by accessing and using our Website, you consent to the use of the cookies and other technologies described above. Residents of the European Economic Area will be able to accept or reject cookies each time they access the site.
2. Marketing Communications. You may choose to sign-up for marketing or other communications from Bonzai on the Website. Should you choose to unsubscribe from any lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all Bonzai communications or by emailing email@example.com.
Your Rights & the EU General Data Protection Act
We are committed to GDPR compliance when enforcement begins on May 25, 2018. If you are a resident of the European Economic Area, you have the following rights with respect to data for which Bonzai is the Data Controller:
1. The right to request access to, or ask us to provide you with copies of, Personal Data that we hold about you at any time, which may be subject to a fee specified by law for processing your request (but not for making a request for access). If Bonzai is the Data Controller with respect to your data, we will respond to your request within a reasonable period, and if Bonzai is the Data Processor with respect to your data, we may redirect your request to Bonzai’s customer acting as the Data Controller with respect to your data. We may decline a request for access to Personal Data in circumstances prescribed by relevant privacy laws. If we decline a request, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
2. The right to ask us to delete any Personal Data that we hold about you free of charge, unless we are required to maintain a copy of this data pursuant to applicable law;
3. Under certain circumstances, the right to demand that the processing of your personal data should be restricted;
4. The right to obtain your personal data in a common, structured and mechanically readable format;
5. The right to ask us to update and correct any out-of-date or incorrect or inaccurate Personal Data that we hold about you free of charge. We will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we refuse to correct your Personal Data, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
6. The right to opt out of any marketing communications that we (or any third-party to whom we have disclosed your Personal Data with your consent) may send you or to withdraw your prior consent or object to any further processing of your Personal Data;
7. The right to request information about any automated decisions made using your Personal Data that have legal consequences for you or which significantly affect you;
8. If you have any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data, you can also contact our data protection officer in detail; and
9. The right to lodge a complaint with your local Data Protection Authority concerning Bonzai’s processing of your Personal Data.
If you wish to exercise any of the above rights, send us an email at firstname.lastname@example.org headed “Data Subject Request.” Before we process any request, we may ask you for certain Personal Data to verify your identity, and in situations where Bonzai is the Data Processor, consult with the Data Controller of your data. Where permitted by local law, we may reject requests that are unreasonable or impractical. Please allow us a reasonable time to respond to your inquiries and requests.
Security of your Personal Data
Bonzai uses reasonable technical and organizational security measures to safeguard Personal Data that is submitted to us voluntarily through our Website or the Bonzai Services or collected through interactions with the Bonzai Services. However, no security measures are perfect or impenetrable. We cannot control the actions of third-parties with whom you elect to share your Personal Data and we cannot accept liability for improper access to that data. We cannot guarantee that only authorized persons will view your Personal Data. We cannot ensure that information you share on our Website and/or through the Bonzai Services will not become publicly available.
International Visitors and Customers
Please be informed that our servers are located in Singapore and Australia. In case You are located outside of Singapore or Australia, please be aware that any Information that You provide us, including PII, will be transferred from your country of origin to Singapore and Australia. This is done on the basis of contractual regulations stipulated by law that ensure appropriate protection of your data and that are available for you to view on request. Your decision to provide the Information to us, or to allowing us to collect such Information through the Bonzai Platform, constitutes your consent to transfer of Your Information to our servers. If you do not consent to the transfer Your Information, please do not submit Your PII to Bonzai. In case you would like Bonzai to access, correct, amend, delete, or export any of Your PII that You would have shared with Bonzai, please email email@example.com.
Third-Party Social Media Features
The Website is not intended for children under 16 years of age. You must be at least 16 years old to use the Website and/or the Bonzai Services. We do not knowingly collect Personal Data from any child under 16 years of age. If you are under 16 years of age, do not use the Bonzai Services and do not provide any Personal Data to us. If you are a parent of a child under 16 years of age and become aware that your child has provided Personal Data to Bonzai, please contact us at firstname.lastname@example.org and you may request access, correction, deletion, and/or objection rights.
Links to Other Sites
Our Website and the ads we serve on behalf of customers may, from time to time, contain links to external websites. Bonzai encourages you to review the privacy and security policies of any externally linked websites whose information practices may be different from ours. Bonzai assumes no responsibility or liability for the information, collection, and disclosure practices of any external websites that a Visitor can access through the Website or the Bonzai Services. Please check the privacy policies of these external websites before you submit any Personal Data or other information to them.
Bonzai Digital Pte Ltd, UOB Plaza 1, 80 Raffles Place, Level 36, Singapore 048624
External Data Protection Officer and contact information:
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21, 20354 Hamburg, Germany
For all requests concerning the security of your data, please contact our data protection officer at email@example.com.
If you have a particularly sensitive request, please contact our Data Protection Officer by postal mail, as communication by e-mail can always be flawed by security vulnerabilities.
A note to data subjects residing in the European Economic Area: If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, data subjects covered under the GDPR framework have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work, or place of the alleged infringement.
Requirement or obligation to provide data
Insofar as this is not expressly stated, when data are collected, the provision of data is neither required nor obligatory.