Bonneville Labs Privacy Policy

Effective Date: January 1, 2018

Welcome! Safeguarding your privacy is important to us. Bonneville Labs is committed to maintaining your trust by protecting personal information that we collect and use.

This Privacy Policy describes how Bonneville Labs Companies Inc. and its affiliated companies and subsidiaries (“Bonneville Labs”, “we” or “us”) collect, use, and disclose your personal information in connection with the www.BonnevilleLabs website (“Website”), the Bonneville Labs communication network (“Member Network”), any Bonneville Labs downloadable App (“App(s)”), and any other website, application, or other service that we provide (collectively, our “Services”). Please read this Privacy Policy carefully before you use our Services. You should not use our Services if you are not comfortable with what is stated below, and your continued use of Services constitutes consent to the practices we describe in this Privacy Policy and the use and sharing of your information as provided herein.

Also, please know that this Policy is part of and incorporated into the Bonneville Labs Terms of Service: https://www.bonnevillelabs.com/terms-of-service. Generally, if we use terms in a specialized or particular way, we will capitalize and define them in this Policy, but if a special capitalized term occurs without a definition, it will have the definition assigned to it in the Terms of Service agreement (“Network Terms”).

This Privacy Policy applies to all categories of Users, including Visitors (persons or entities who use our Services in a limited way without becoming subscriber Members who have access to all of our Services), Members (persons who register with us and subscribe to our full menu of Services), Company Members (Members who are entities, companies, corporations, or organizations), and Authorized Users (persons who are employees or contractors of Company Members and use our Services under a Company Account), as those categories are further defined and delineated in the Network Terms.

This Privacy Policy primarily concerns personally identifiable information (“PII”), which is information belonging to an individual person and identifying that individual person. PII includes information such as, but not limited to, an individual person’s full name, mailing address, e-mail address, telephone number, mobile phone number, SMS number, social security number, government identification number (such as a driver’s license number of passport number), employer, and/or account number for a credit or debit card or for another financial product or service. Also included in PII is information about the computer or mobile device that you use to access our Services.

As of the Effective Date above, we will collect, use, and share your PII in the following ways under this Privacy Policy.

1. Information We Collect

We collect various types of PII in connection with the Services, namely:

Information you provide us directly;
Information we collect about your device(s) and your use of our Services, including through cookies, web beacons, and other internet technologies; and
Information we obtain from third-party sources.

2. Personal Information You Provide Us Directly

We collect various types of information and content that you provide us directly. For example, in order to enroll as a Member or to access some of our Services, you will be requested to provide us with your name, telephone number, email address, postal address, and (where applicable) your company or organization name. We also collect other content and information that you provide us directly, including the content and information you may add to the member network or other community profile and photographs or other information or documentation you submit or provide us and the communications that you transmit through our networks. We collect billing and payment information you provide when you access some of our Services or purchase products and services. We may collect information that you provide us when you interact with our customer service representatives. We also collect information that you provide us when you participate in any surveys, sweepstakes or events we may provide. In such instances, if you do not provide us with the requested information, we may be unable to deliver you the Services in full.

To the extent that you disclose to us any personal information of another individual, we assume that you have obtained such individual’s consent for the disclosure of such personal information as well as the processing of the same in accordance with the terms of this Policy. Accordingly, do not disclose to us PII which relates to another person unless you have that person’s consent.

3. Information about Your Device(s) and Your Use of the Services

We collect information about how you use our Services and, depending on the access permissions you have chosen for your device, other information, as specified below, from and about the computers, phones, and other devices where you install or access our Services. We use standard internet technologies, such as cookies, web beacons, and other technologies, to collect information about your computer or device and your online activity, as explained in more detail in the section on cookies.

“Cookies” are identifiers that we transfer to your browser or device that allow us to recognize your browser or device and tell us about your visit to our Services: for example, we will gather information about your navigation history through our Website, the number of your visits, the average time you have spent, the pages that you have viewed, and other statistics. When you use a web browser to access the Services, some browsers may allow you to configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Click the “Help” menu of your browser to learn more about how to change your cookie preferences. The operating system of your device may contain additional controls for cookies. Please note that disabling cookies may affect your ability to access and use certain features of the Services.

“Web beacons” and similar technologies are small bits of code, which are embedded in web pages, ads, and e-mail, that communicate with third parties. We may use web beacons, for example, to count the number of Users who have visited a particular web page, to deliver or communicate with cookies, and to understand usage patterns. We also may include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

There are other local storage and Internet technologies – such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage – that operate similarly to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions. Please note that these technologies are distinct from cookies, and you may not be able to control them using standard browser tools and settings. For information about disabling or deleting information contained in Flash cookies, please click here https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

We use cookies, web beacons, and these other technologies for the following general purposes on and within the Services:

Administering and improving our Services, including helping us measure and research the effectiveness of our content, features, advertisements, and other communications. For example, we measure which pages and features website visitors are accessing and how much time they are spending on our webpages. We may include web beacons in e-mails, for example, to understand whether messages have been opened, acted on, or forwarded.
Storing your sign-in credentials and preferences so that you don’t have to enter those credentials and preferences every time you log on to a Service.
Helping us and third parties provide you with relevant Content and advertising by collecting information about your use of our Services and other websites.

By continuing to use the Services, you consent to our use of cookies, web beacons, and other Internet technologies as described above.

When you use our Services with a computer or a mobile device, we will collect certain information that your device sends us such as information your browser sends us (such as your browser type and version), your device’s Internet Protocol address, your location (if geolocation is enabled), your operating system, and statistics about how you use the Services. The information we collect automatically from your access devices can be summarized as follows:

Your browser type and operating system;
IP address and device identifiers;
Your browsing behavior on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services;
Websites you visit before or after our Website;
Whether you have opened or forwarded our e-mails or connected to offers or links that we send you; and
Your general or specific geographic location, such as through GPS, Bluetooth or WiFi signals to the extent permitted by the settings of your devices.

Finally, please know that if you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by Bonneville Labs at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.

4. Information from Third-Party Sources

If you are a User who is an Authorized User accessing our Services under a Company Account, we obtain information about you from your Company or organization, when they create or supplement your profile in the Company Account and/or in the Member Network. As an Authorized User accessing our Services under a Company Account, you may review and amend your Company Account profile at any time in accordance with Section 9 below at https://members.bonnevillelabs.com/profile.

We also receive information about you from publicly and commercially available sources and other third parties as permitted by law. We may combine this information with other information we receive from or about you, where necessary, to provide the Services you requested.

5. Use of Personal Information

We may use the PII that we collect as necessary and appropriate for the following purposes:

To provide our products and services. We use your PII to provide you with the Services that you or your company or organization have requested; to respond to inquiries we receive from you or your company or organization; to verify your identity; to further or complete a transaction that you or your company or organization has initiated; to deliver notifications and other operational communications; and to resolve any customer service issues you may have.
To manage and improve our Services and to analyze how users navigate and use our Services. We may use your PII to facilitate our internal operations, including troubleshooting, data analysis, testing, research, customization, and enhancements and improvements to the Services. As part of these efforts, we strip PII of its sensitive and individual data and make it anonymous so that it is no longer PII (“non-PII”), and then we aggregate that non-PII and subject it to analysis in its aggregate form. Quantitative analyses of aggregated non-PII data can tell us how often Users access a particular feature of the Services, and we can use that knowledge to make the Services more efficient, and to make them as useful to as many Users as possible. We also use anonymous non-PII, some of which is obtained via pixels or web beacons, for internal research and development purposes, to improve and test the features and functions of our Sites.
To perform accounting and administrative tasks, and to enforce or manage legal claims, if necessary.
To deliver advertising and promotional communications to you, including targeted advertisements; to contact you with offers and information about our products, services, features, and events; to send you newsletters or other information about topics that we believe may be of interest; to conduct online surveys; and to otherwise promote our products, services, features, and events.
To maintain security and to protect, enforce, or defend legal rights, privacy, safety or property, whether yours, ours, or those of our employees or agents or other Users.
To enforce compliance with Bonneville Labs’ Network Terms and to comply with applicable law and government requests.

6. Sharing of Personal Information

We may disclose your PII in the following circumstances to the following parties:

Among Bonneville Labs companies. Our Services are provided by affiliates of Bonneville Labs Companies Inc., depending on where you are located and the services you use. Bonneville Labs shares personal information with those affiliates for the purposes mentioned above. These affiliates use your information in accordance with this policy.
Our Community. Our Services include online and offline Member communities, forums and networks that allow you to share and connect with others. We make this possible for Bonneville Labs Members by creating a profile for new Members and Authorized Users which contains your name and, if you are an Authorized User, the name of your company or other organization. This profile is created automatically and is accessible to other members of the forum or network, some of which include all Bonneville Labs Members. You can supplement your profile by adding additional information about yourself and, if applicable, about your company or organization. By posting content and comments and you may be able to share your profile with a broader audience.
Third-Party Service Providers. We rely on Third-Party Service Providers to perform a variety of services on our behalf: to host data and platforms, fulfill our product and service requests, answer your questions, send e-mails on our behalf, process payment card or other transactions, and analyze data to improve our products and services.
Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose PII to other parties:
- to provide you with the Services you or your company or organization request, such as a disclosure of your information to a landlord in connection with a lease agreement, or to auditors or consultants;
- to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;
- to detect, suppress, and prevent fraud or verify and enforce compliance with the policies governing our Services; or
- to protect our rights, property, and safety or those of our respective affiliates, business partners, customers, employees, Users, and where otherwise required by law.
Other Parties in Connection with a Corporate Transaction. We will disclose your personal information to an acquirer in the event we sell or transfer all or a portion of a business or assets to that third party, such as in connection with a merger or in the event of a bankruptcy reorganization or liquidation.
Partners, With Your Consent. We may request your consent to share PII with those third parties who are our business Partners, so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.
Other Parties at Your Company’s or Organization’s Direction. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when your company or organization requests such sharing. For example, we periodically work with Partners to make products or Services available to individual Members or participating Company Members. If you or your company or organization requests to participate, we may share your information with the relevant Partner in connection with the requested product or Service.

Our Services contain links to other sites that we do not own or operate. We provide links to these third-party sites as a convenience to our Members. Such links are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms, which we recommend you read carefully. The collection, use, and disclosure of your personal information will be subject to the privacy policies of the third party and not this Policy.

7. Third Parties That Provide Content or Functionality on Our Services

We also partner with certain third parties to collect, analyze, and use PII. For example:

Third-parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they may collect information about you, such as your IP address and the pages that you view.
Advertising providers help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.
Other content providers may offer products and services on our Services and may operate contents, sweepstakes, or surveys on our Services.

These third parties collect or receive certain information about your use of our Services, including through the use of cookies and web beacons (described above) and this information may be collected over time and combined with information collected across different websites and online services.

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative and the Digital Advertising Alliance to learn more. Further information in local languages may be available at Your Online Choices.

8. Information Security

We have in place various procedures to safeguard your information. Although we use commercially reasonable efforts consistent with industry standards to keep your PII secure, we cannot guarantee complete security. If you are a Member or an Authorized User under a Company Account, your account is protected by a password for your privacy and security. You bear the responsibility and obligation to prevent unauthorized access to your Account and your PII by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or your mobile device and closing your browser and signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors beyond the control of Bonneville Labs, may compromise the security of a User’s information at any time.

9. Accessing, Reviewing and Updating Your Information

In accordance with applicable law, you may have the right to access, update, or correct inaccuracies in your PII in our custody and control, subject to certain exceptions prescribed by law. You generally have the right to control the use of your PII in the following ways:

General and Marketing Communications. If you do not want to receive general communications from us, which will include marketing materials from us and from our Partners, you may opt-out of receiving such communications, and we ask that you please indicate your preferences in an email to privacy@BonnevilleLabs.com. Please remember that even if you opt out of receiving general and marketing communications from us, we may still send you important information related to your account or to the Services.
Text Messages. If you are receiving texts sent via the Service and you wish to opt out, reply STOP to any such message, or send an email with your cellphone number and the subject line “Opt-Out” to privacy@BonnevilleLabs.com
Profile Changes. Because we have Users who reside in California, our Privacy Policy complies with the California Online Privacy Protection Act (“CalOPPA”). Under CalOPPA, you have the right to change, edit, or delete any of the PII we have collected from you during your use of our Services. If you are a Member or an Authorized User under a Company Account, you can add, edit, or update your personal information, or delete your registration account profile in whole or in part here: https://members.bonnevillelabs.com/profile . Please know that when you update or delete your information, we may maintain a copy of the unrevised information in our records, but never in a manner that would identify you personally. Also, please keep in mind that if you delete your registration account profile in whole or in part, certain aspects of the Services may no longer be available to you unless and until you re-register.
Location Information. You can prevent us from collecting location information from your mobile device by changing the settings on your device; however, please keep in mind that many aspects of the Services provided by Bonneville Labs are dependent upon geographical searching, and so if you do not provide us with location information. you may not be able to make use of the full functionality and benefits of the Services.
Social Media Notifications. If you connect a social media account such as Facebook or Instagram to your Member Account profile, you may receive updates on what your friends are doing on the Services. However, you can manage these notifications by toggling your social settings to ensure your privacy or by disconnecting such social media integration.
Cookies. Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie or to prevent cookies from being placed on their hard drive. You can read more about cookies at http://www.allaboutcookies.org/cookies/.
Google Analytics. One of the Third-Party Service Providers that we use for non-PII data analytics is Google Analytics. If you do not want Google Analytics to collect and use information about your use of the Service, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).
Marketing and California’s Shine the Light Law. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice which identifies the categories of PII that we share with any third parties for marketing purposes, and which provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to Privacy@BonnevilleLabs.com.

If you have questions about accessing, reviewing, or updating your information, please send an e-mail to Privacy@BonnevilleLabs.com. Or, you may send a letter to Privacy Director, Bonneville Labs, 626 Bancroft Way Suite A, Berkeley, CA 94710.

10. Our Response to DO NOT TRACK Preferences

If you use a popular browser (such as, but not limited to, Safari, Chrome, Internet Explorer, or Firefox) you can set the “Do Not Track” (or DNT) preference setting on your browser to opt-out of online behavioral tracking, which is done by various companies, particularly by those that, like Bonneville labs, provide targeted advertising. Your right to opt-out of such tracking is protected under CalOPPA. We do track our Users to provide targeted advertising, and, therefore, we do respond to Do Not Track (DNT) signals, as we are required to do under CalOPPA.

11. International Transfers

The Services are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to another country in accordance with applicable law. By using the Services, you are agreeing to the transfer of your information to the United States and processing of such information in the United States in accordance with this Policy. If you access the Services from a jurisdiction in the European Union or from another jurisdiction with laws governing data collection and use, please note that you are using Services with privacy and security safeguards designed to comply with the applicable state and federal laws of the United States.

12. Children

The Children’s Online Privacy Protection Act (“COPPA”) requires online service providers to obtain parental consent before they knowingly collect PII from children who are under 13 years of age. We do not knowingly collect or solicit PII from children under 13. If you are a child under 13, please do not attempt to become a User, and do not attempt to or send any personal information about yourself to us through our Services. If we learn that we have collected PII from a child under age 13 without parental consent, we will delete that information as quickly as possible as may be required by COPPA and other laws. If you believe that a child under 13 may have provided us personal information without parental consent, please contact us at Privacy@BonnevilleLabs.com.

13. Minors

We do not allow minors to register as Members and we do not knowingly gather PII from minors. If you are a minor over the age of 13 but under the age of 18, you may only use our Services under the direct supervision of a parent or authorized guardian, which parent or guardian must register as a Member in your place.

14. Changes to This Privacy Policy in the Future

Privacy laws and guidelines are part of a changing legal environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. If we make an update or revision, we will also update the Effective Date above, and we will alert you to changes by placing a notice on our Website, and/or by emailing you, and/or by some other means. Please note that if you do not read new updates to the Privacy Policy, those updates, once noticed and published, will still govern your use of the Services, and you are still responsible for understanding any update. If you use the Services after any changes to the Privacy Policy have been posted (as indicated by the Effective Date above), that means you agree to all of the changes.

15. Questions or Comments

If you have any questions or comments regarding our Policy, please contact us:
Via Email: Privacy@BonnevilleLabs.com
Via U.S. Mail: Privacy Director, Bonneville Labs, 626 Bancroft Way Suite A, Berkeley, CA 94710