Privacy Policy

Your privacy is important to us. We have prepared this Privacy Policy to explain how we collect, use, and disclose personal information we obtain about you when you use the BTS Flipthru website (“Site”) and other services offered by BTS Flipthru (collectively, the “Services”). This Privacy Policy also explains the measures we take to safeguard the personal information and the choices available to you regarding the information. This Privacy Policy applies to all users of the Services, unless otherwise expressly indicated. The Services are provided by BTS Flipthru (“BTS Flipthru”, “we”, “our”, “us”).

Managing Your Information Preferences

If you have questions regarding this Privacy Policy, please e-mail us at [email protected].

California Consumers: If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement”.

Canadian Consumers: If you are a Canadian consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “Canadian Consumer Privacy Statement”.

Information We Obtain

We may obtain certain personal information about you that you choose to provide to us, including any information you choose to include in your account or in communications with us. The personal information we obtain includes:

• Contact information, such as name, email, username;
• Other personal information you provide to us, such as through emails or online chats.

Information We Obtain by Automated Means

When you interact with our Services, we obtain certain information by automated means, such as cookies. A “cookie” is a small text file placed on your computer to identify your computer and web browser. We use these automated technologies on the Services to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner may include the type of web browser you use, your device identification information, your IP address, the pages you view, and the time and duration of your visits to the Site. We use this information to help us understand how people use the Services, and to enhance the Services we offer. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with the Services; (3) tailor the Services around your preferences; (4) measure the usability of the Services and the effectiveness of our communications; and (5) otherwise manage and enhance our Services, and help ensure they are working properly.

Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Please note, however, that certain features of the Services may not work if you delete or disable cookies.

Our Site is not designed to respond to “Do Not Track” signals from browsers.

Third-Party Analytics Services

We use third-party analytics services on our Services, such as Google Analytics. The information we obtain through the Services may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

How We Use the Information We Obtain

We use the personal information we obtain about you to:

• Provide our Services, and manage our relationship with you;
• Establish and manage your account with us, and identify and authenticate you so you can access and use our Services;
• Personalize your experience with our Services;
• Increase and maintain the safety and security of our Services and prevent misuse;
• Communicate with you (including providing you with offers and other communications about our Services) and provide customer support;
• Operate, evaluate and improve our Services (including managing the Services, developing new services and offerings; enhancing and improving our Services; managing our communications; analyzing our Services; performing data analytics; and performing accounting, auditing and other internal functions);
• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
• Comply with and enforce applicable legal and regulatory requirements, industry standards, and our policies and terms.

We also may use the information in other ways for which we provide specific notice at the time of collection, and obtain consent to the extent required by law.

Information We Share

We may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to lawful requests by government agencies, such as law enforcement authorities; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss, or to protect the safety, property, or rights of BTS Flipthru or of any third party; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

Personal Information You Make Available to Others

By using the Services you may make certain of your personal information available to others. For example, when you post a photo on the Site, other users may see your username and other information that you choose to make available to others. Please be aware that whenever you share information on any public area of the Services, that information may be accessed by others.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Other Online Services and Third-Party Features

For your convenience and information, our Services may contain links to other online services, and may include third-party features such as apps, tools, widgets, and plug-ins. Our Services also may allow others to send you such links. These online services and third-party features may be owned and operated by third parties that are independent of us. A link to a third party’s online service or feature does not mean that we endorse it or that we are affiliated with it. The information practices of the relevant third parties, including information they may collect about you, are subject to the privacy notices of these parties, which we strongly suggest you review. We are not responsible for the content or privacy practices of any websites, apps or services that are not owned or controlled by BTS Flipthru.

Children’s Privacy

The Services are intended for users who are of the age of majority in their jurisdiction of residence. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personal information from a child under the age of 13, we will delete such information from our records.

Data Transfers

We may transfer the personal information we obtain about you to the United States or other countries which may not have the same data protection laws as the country in which you initially provided the information.

Privacy Policy Changes

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.

Contact Us

If you have any questions or comments about this Privacy Policy, you may contact us at [email protected].

California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the BTS Flipthru Privacy Policy and applies solely to California consumers. This Statement does not apply to BTS Flipthru personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, unique personal identifier (such as a device identifier; cookies, customer number, and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, and other similar identifiers;

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Policy and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you provide us information in connection with our Services;
• Your devices, such as when you visit our Site;
• Data analytics providers;
• Government entities;
• Operating systems and platforms; and
• Social networks.

Sale of Personal Information

We do not sell personal information in exchange for monetary consideration.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

How to Submit a Request

To submit an access or deletion request, please email us at [email protected]. To submit a request as an authorized agent on behalf of a consumer, please email us at [email protected]. To opt out of the sale of your personal information, please email us at [email protected]. For questions or concerns about our privacy policies and practices, please contact us as described in the “Contact Us” section of our Privacy Policy.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide certain information to verify your identity, such as your name and email address. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Canadian Consumer Privacy Statement

In addition to the Privacy Policy, the following provisions apply to residents of Canada.

Personal Information

Under the Personal Information Protection and Electronic Documents Act (Canada) and substantially similar provincial privacy laws (collectively, “Canadian Privacy Laws”) personal information means any information about an identifiable individual, which includes the information described above in this Privacy Policy as personal information.

Consent

By providing your personal information to us, you agree that we may collect, use, disclose, retain and otherwise process your personal information as described in this Privacy Policy. Under Canadian Privacy Laws, you have the right to withdraw your consent at any time to our collection, use or disclosure of your personal information, subject to reasonable prior notice and applicable legal and contractual restrictions. Depending on the nature of the personal information for which you choose to withdraw your consent, if you do withdraw your consent, we may not be able to provide our products and services to you. If you withdraw your consent in respect of any personal information that has been provided to third parties, we will advise such third parties of your withdrawal to the extent required by Canadian Privacy Laws.

Your Rights

Canadian Privacy Laws provide individuals in Canada with the following rights:

• To be informed about the personal information that we hold about you;
• To receive an accounting of the third parties to whom we have disclosed your personal information;
• To access the personal information we maintain about you;
• To be provided with information about how we process your personal information;
• To correct or supplement your personal information where you can demonstrate that it is inaccurate or incomplete;
• Where appropriate, to have your corrected or supplemental personal information transmitted to third parties who have had access to your personal information.

To exercise the above rights or to submit a request on behalf of a consumer, please email us at [email protected]. We will request information from you to verify your identity and/or authority to act on behalf of a consumer. For questions or concerns about our privacy policies and practices, please contact [email protected]. We will consider and process your request within a reasonable period of time and in any event within thirty days of receipt or such longer time as we may be permitted under Canadian Privacy Laws. Please be aware that your right to access, correct or supplement your personal information is not absolute and that, under certain circumstances, Canadian Privacy Laws may permit us to refuse your request. If we do refuse your request, we will explain why.

Data Retention

Except as otherwise permitted or required by Canadian Privacy Laws or other applicable Canadian laws or regulations, we will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or your consent.