Sharing your Data with Third Parties
We also use third-party payment providers to process payments you make in respect of the Service. These third parties will have privacy policies addressing their use of your data to process your payments. Please check these policies before you submit any information to those third parties.
We will share your data if legally required in response to a valid law enforcement request or legal process to protect our rights and property or those of third parties, or as otherwise permitted or required by law.
Additionally, we may disclose your data:
- if we believe there is a serious and imminent threat to the life, health, or safety of yourself or another person;
- to investigate or report on activity which we believe on reasonable grounds to be unlawful;
- if the disclosure is required or authorized by law (for example, in response to a subpoena or where a regulatory authority has the power to request the provision of certain records or information);
- if the disclosure is reasonably necessary to enable an enforcement body to perform its functions, for example, the prevention, detection, investigation, prosecution, or punishment of criminal offenses, or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal; or
- if we have a good faith belief that such use is reasonably necessary to protect our legal and legitimate business interests.
Transfer of your Personal Data outside the European Economic Area
As we are a US-based company, we require the transfer of your data to the US for us to provide you with our Service.
By using the Bellabee Site and Bellabee App, you acknowledge this use of your data for our contract performance with you. If you are based in the European Union, and you do not agree to the transfer of your data outside of the European Economic Area (the “EEA”), please stop using our Bellabee Site and Bellabee App. If you order a Bellabee Device, we will need to transfer your data outside of the EEA to fulfill your order and meet our contractual obligations to you.
When we transfer your data to third parties located outside of the EEA, such transfers will either (i) be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), according to Decision 2004/915/EC and 2010/87/EU; or (ii) in reliance on the EU-US Privacy Shield Framework. Don't hesitate to get in touch with [email protected] if you would like to see a copy of the standard contractual clauses.
EU-US Privacy Shield and Swiss-US Privacy Shield
Bellabee, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data from European (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks and view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
Bellabee, Inc. is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Bellabee, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
Concerning personal data received or transferred according to the Privacy Shield Frameworks, Bellabee, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, don't hesitate to contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Protecting Your Information
We have implemented policies and procedures, including technical and organizational measures, designed to help safeguard your information from unauthorized access, use, or modification. However, unfortunately, the transmission of information via the internet or email is not entirely secure, and we cannot guarantee the security of your data transmitted through the Service or over email; any transmission is at your own risk. We advise you that we believe a persistent attacker with sufficient resources would be able to defeat the security measures we have in place.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, they will have their privacy policies, and we do not accept any responsibility or liability for these policies.
Please check these policies before you submit any information to those websites.
Retention of your Personal Data
We will retain your data as follows:
- purchase and account information: for the period that you are using the Service as an active user and as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and enforce our Terms of Service; and
- The Bellabee Device data that you submit to or through the Service: for as long as your account is active and a reasonable period after that in case you decide to re-activate the Service.
As explained above under “Our Use of Your Non-Identifiable Information,” after you have terminated your use of the Service, we will store your information in a non-identifiable, aggregated form.
You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your data and who we share it with. You also have the right to ask us to correct your data where it is inaccurate or incomplete, and we will endeavor to do so without delay.
In certain circumstances, you have the right to ask us to delete the personal data we hold about you:
- where you believe that it is no longer necessary for us to store your data;
- where we are processing your data based on legitimate interests, and you object to such processing, and we cannot demonstrate an overriding fair ground for the processing; or
- where you believe we are unlawfully processing the personal data, we hold about you.
In certain circumstances, you have the right to ask us to restrict (or stop any active) processing of your data:
- where you believe the personal data we hold about you is inaccurate, and while we verify its accuracy;
- where we want to erase your data as the processing is unlawful, but you like us to continue to store it;
- where we no longer need your data for our processing, but you require us to retain the data for the establishment, exercise, or defense of legal claims; or
- where you have objected to us processing your data based on our legitimate interests, and we are considering your objection.
To exercise any of these rights above, don't hesitate to contact us at [email protected] In addition, you have the right to complain to the data protection supervisory authority in your country.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals, where there are overriding public interest reasons, or where we are required by law to retain your data.
You may sign up to receive emails, newsletters, or other communications from us. If you would like to discontinue receiving such communications, you may update your email preferences by [using the unsubscribe link found in emails we send to you or at your member profile on our website or by contacting us at [email protected]
The Service is not directed to children and is not intended for persons under 18 years of age. Moreover, we do not knowingly collect personal data from subjects under 13 years of age. If a parent or guardian becomes aware that their child has provided us with personal data without their consent, don't hesitate to contact us at [email protected] If we become aware that a member is under 13 and has provided us with personal data, we will delete such information from our file.
California residents may request information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes or choose to opt-out of such disclosure. Personally, Identifiable Information is defined under US law and is information that, taken alone, identifies you and can be used to contact you online or offline. To make a request or to opt out at any time, don't hesitate to get in touch with us at [email protected] or the other contact information provided below. Our policy is not to disclose Personally Identifiable Information collected online to a third party for directing marketing without your approval.
If you wish to make a complaint about how we process your data, don't hesitate to get in touch with us in the first instance at [email protected] we will endeavor to deal with your request. This is without prejudice to your right to complain to the data protection supervisory authority in your country.
Questions, comments, and requests regarding this policy are welcomed and should be addressed to [email protected]